HomeMy Public PortalAboutGray's Crossing Specific Plan FEIR I
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GRAY CROSSING S PECIFI C PLAN/
1 TENTATIVE MAP
FINAL ENVIRONMENTAL IMPACT REPORT
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SCH No. 2002072115
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Submitted to:
TOWN OF TRUCKEE
10183 Truckee Airport Road
I Truckee, CA 96161
1 Submitted by:
PMC
PACIFIC muNICIPAL
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C 0 N 5 U l T A N T 5
1 September 2003
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GRAY'S CROSSING SPECIFIC PLAN/
TENTATIVE MAP
Final
Environmental Impact Report
SCH No. 2002072115
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' Prepared for:
' TOWN OF TRUCKEE
10183 Truckee Airport Road
Truckee, CA 96161
Prepared by:
' PACIFIC MUNICIPAL CONSULTANTS
140 Independence Circle, Suite C
' Chico, CA 95973
Phone: 530.894.3469
' Fax: 530.894.6459
www.pacificmunicipal.com
September 2003
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' TABLE OF CONTENTS
SECTIONS
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1.0 INTRODUCTION 1 -1
2.0 RESPONSE TO COMMENTS 2 -1
' Letter Number and Commentor Response on Page
I • 1. Scott Ferguson, Chief, California Regional Water
Quality Control Board, Lahontan Region 2 -32
2: Bruce De Terra, Chief, California Department of Transportation 2 -52
' 3. Larry Eng, Deputy Regional Manager, California Department of
Fish and Game 2 -66
III 4. Jeff Dowling, Forester, California Department of Forestry and Fire Protection 2 -69
• 5. Bob Jensen, Chair, Town of Truckee Planning Commission 2 -70
' 6. Ted Owens, Mayor, Town of Truckee 2 -73
7. Craig Woods, General Manager, Tahoe - Truckee Sanitation Agency 2 -79
I 8. Bradley Stapley, P.E., Assistant General Manager, Truckee Sanitary District 2 -80
9. David Gotschall, General Manager, Truckee Tahoe Airport District 2 -82
I 10. Terrell, Watt, AICP, Terrell Watt Planning Consultants 2 -84
11. Stefanie Olivieri, President, Mountain Area Preservation Foundation 2 -116
' 12. Stefanie Olivieri, President, Mountain Area Preservation Foundation 2 -121
13. Lot Owners, Prosser Woods Estates 2 -122
14. Karen Sessler, Area Resident 2 -125
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15. Robert Yoder and Nancy Davis, Area Residents 2 -128
• 16. Adrian Juncosa, Area Resident 2 -129
' 17. Gretchen Bennitt, Air Pollution Control Officer, Northern Sierra Air Quality
Management District 2-134
III 18. Rick McConn, Project Manager, East West Partners 2 -136
19. Julie Cooley - Rieders, Area Resident 2 -139
I 20. Mike Huber, Area Resident 2 -140
21. Dennis Dickinson, Area Resident 2 -142
' 3.0 ERRATA TO THE DRAFT EIR
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' Town of Truckee i Gray's Crossing Specific Plan Project
September 2003 Final Environmental Impact Report
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TABLE OF CONTENTS '
TABLES
Table 2 -1 Public Agencies and Persons Commenting on the Draft EIR 2 -1 '
Table 2 -2 Comparison of Roadway LOS Methodologies
Assuming a Two -Lane SR 267 2 -55
TECHNICAL APPENDICES (BOUND SEPARATELY) '
Appendix A Draft Natural Resource Management Plan for Gray's Crossing Truckee,
California. Prepared by Audubon International. Dated August 2003.
Ecological Design for Gray's Crossing. January 2003.
Appendix B Preliminary Drainage Plan for Gray's Crossing. Prepared by SCO Planning
& Engineering.
Appendix C Cumulative Water Quality Analyses Report for Lahontan Development
1996 -2002. Huffman & Carpenter, Inc., January 2003.
Appendix D Tables 2 -1 and 2 -2, Lahontan Basin Plan.
Appendix E North Lahontan Region Project Guidelines for Erosion Control (provided
by Lahontan Regional Water Quality Control Board).
Appendix F Standard BMP /SWPPP Inspection Checklist 1
Appendix G Timber Harvest Plan for Gray's Crossing Dated July 9, 2003
Appendix H Root Drip Line Trench Calculation
Appendix I Complete List of BMPs Proposed To Date for the Gray's Crossing Project
Appendix J Comments Regarding the Viability of a Nine -hole Golf Course Option.
Economics Research Associates. August 6, 2003.
Appendix K Proposed Cross - Section Treatment for SR 89 South of Alder Drive /Prosser
Dam Road /SR 89 Intersection Provided by SCO Planning and Engineering
Appendix L Adrian M. Juncosa, Ph.D Resume
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Appendix M Gray's Crossing Estimated Construction Traffic Provided Applicant
Appendix N Supplemental LOS Analysis Provided by LSC Transportation Consultants I
Appendix 0 Master Response 3.4.4 Water Supply Effects from the Mortis Valley
Community Plan Update Final EIR
Gray's Crossing Specific Plan Project ii Town of Truckee
Final Environmental Impact Report September
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Appendix P Additional Background Information Provided by Project Applicant
1 Regarding Sewer Facility Sizing
Appendix Q Remy, Thomas, Moose and Manley, LLP (Attorney for the Applicant) Letter
' Dated September 7, 2003, Addressing the Provision of a Phase I
Assessment
Appendix R Cross Section for Clustered Alternative Concept Provided by Project
Applicant's Consultant (SCO Planning & Engineering)
Appendix S North Tahoe/Truckee Employer Commute Survey prepared for the North
Lake Tahoe Resort Association. LSC Transportation Consultants, Inc.,
• WATER SUPPLY TECHNICAL APPENDIX (BOUND SEPARATELY AND AVAILABLE AT THE TOWN OF
TRUCKEE COMMUNITY DEVELOPMENT DEPARTMENT)
Truckee Donner Public Utilities District, Water System Master Plan (1997)
Truckee Donner Public Utilities District, Water System Master Plan Update (2001)
' California Department of Water Resources, Bulletin 118 (April 2003 draft (excerpts)
Nimbus Engineers, Ground Water Availability in the Mortis Valley Ground Water Basin
t (Nimbus Engineering 2001)
Kennedy /Jenks Consultants, Independent Appraisal of Mortis Valley Groundwater
Availability - Nevada and Placer Counties, California (December 2002)
Interflow Hydrology, Inc., Measurement of Ground Water Discharge to Streams Tributary
' to the Truckee River in Mortis valley, Placer and Nevada Counties, California (April 2003)
Pacific Municipal Consultants, Mortis Valley Community Plan, Final EIR, Master Response
3.4.4 (July 2003)
California Department of Water Resources, Draft Guidebook for Implementation of
Senate Bill 610 and Senate Bill 221 of 2001 (Draft September 25, 2002)
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Town of Truckee iii Gray's Crossing Specific Plan Project
September2003 Final Environmental Impact Report
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1.0 INTRODUCTION
1.1 PURPOSE OF THE EIR PROCESS
This Final Environmental Impact Report (Final EIR) is an information document prepared
for the Town of Truckee to evaluate the impacts Of the Gray's Crossing Specific Plan
Project. The California Environmental Quality Act (CEQA) and the State CEQA
Guidelines set forth the EIR process. Under CEQA, the primary objectives of the EIR
process are to inform decision makers and the public about a project's potential
significant environmental effects, to identify possible ways to minimize the significant
' effects, and to describe reasonable alternatives to the project. This Final EIR has been
prepared by Pacific Municipal Consultants, a consultant for the Town. It has been
' independently reviewed by Town staff for completeness and accuracy, in accordance.
with CEQA Guidelines Section 15084(e).
1.2 DOCUMENT FORMAT
As prescribed by CEQA Guidelines Section 15088, the Lead Agency, which in this case is
' the Town of Truckee, is required to evaluate comments on environmental issues
received from persons who have reviewed the Draft Environmental Impact Report
(Draft EIR), and to prepare written responses to those comments. This document,
' together with the Draft EIR, will constitute the Final Environmental Impact Report for this
project. The Draft EIR is incorporated into this document by reference, in accordance
with CEQA Guidelines Section 15150. Pursuant to the requirements of CEQA, the City
' must certify the Final EIR as complete and adequate prior to final approval of the
project.
This Final EIR contains individual responses to each written comment received during
the public review period for the Draft FIR, from March 6, 2002 to April 22, 2002. The Final
EIR also contains a summary of all changes, corrections, and additions made to the EIR
' text between the draft and final stages. ,Deletions are shown in :trikcthrough, and
additions are indicated by bold italics. This summary, or errata, is an important
reference tool used to identify specific text modifications.
1.3 EIR CERTIFICATION PROCESS AND PROJECT APPROVAL
In accordance with CEQA requirements and the procedures of the Town of Truckee,
the Town must certify the EIR as complete and adequate prior to taking action on the
project. Certification of the EIR for the Gray's Crossing Specific Plan Project will take
place at a hearing of the Town of Truckee Town Council. After the EIR is certified and all
information is considered, the Town may take action on the project using its
independent judgment. It may approve the project, make changes, or select an
alternative to the project. The information in the EIR does not control the ultimate
decision of the Town on the project. However, the Town must respond to each
' significant effect and mitigation measure identified in the EIR by making findings
supporting its decision.
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Town of Truckee Final Environmental Impact Report
111 September 2003 . 1 -1 Gray's Crossing Specific Plan Project
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2.0 RESPONSE TO COMMENTS
' 2.0 RESPONSE TO COMMENTS
2.1 INTRODUCTION
No new significant environmental impacts or issues, beyond those already covered in
the Draft EIR for the Gray's Crossing Specific Plan project, were raised during the
comment period, and the Town of Truckee, acting as lead agency, directed that
responses to the Draft EIR comments be prepared. Responses to comments received
during the comment period do not include any new significant impacts or "significant
new information" that would require recirculation of the Draft EIR pursuant to CEQA
Guidelines Section 15088.5
' The following section contains comments letters and written responses to comments on
the Draft EIR. CEQA requires that this document respond to only those comments that
are specific to the Draft EIR. However, every attempt has been made to respond to
' comments that address the proposed project in general, in an effort to provide the
most complete information possible.
2.2 LIST OF COMMENTORS
Table 2 -1 lists those persons and public agencies that provided written comments on
the Draft EIR. The assigned comment letter number, letter date, letter author, and
affiliation, if presented in the comment letter or if representing a public agency, are also
listed.
`, TABLE 27:1
PUBLIC'AGENCIES AND P.ERSONS,CQMMENTING ON THE,DRAFT EIR
Letter ' l
No. - - Affiliation = ature t::. N Date
California Regional Water Quality Scott C. Ferguson, Chief,
1 Control Board, Lahontan Region' Truckee River Watershed Unit July 31, 2003
California Department of Bruce De Terra, Chief, Office of
2 Transportation Regional and Transit Planning August 5, 2003
California Department of Fish and Larry L. Eng, Ph.D. Deputy
3 Game Regional Manger July 15, 2003
California Department of Forestry Jeff Dowling, Truckee Area
4 and Fire Protection Forester July 29, 2003
Town of Truckee Planning
5 Commission Bob Jensen, Chair July 28, 2003
' 6 Town of Truckee Town Council Ted Owens, Mayor August 8, 2003
Craig F. Woods, General
7 Tahoe - Truckee Sanitation Agency Manager, Chief Engineer June 25, 2003
1 Bradley D. Stapley, P.E.,
8 Truckee Sanitary District Assistant General Manager July 1, 2003
David Gotschall, General
' 9 Truckee Tahoe Airport District Manager August 8, 2003
Town of Truckee Final Environmental Impact Report
September 2 -1 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS '
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No '' . 'Affiliation , a. ignature :, - -- Date,:
10 Terrell Watt Planning Consultants Terrell Watt, AICP August 6, 2003
Mountain Area Preservation
11 Foundation Stefanie Olivieri, President July 9, 2003
President, Mountain Area
12 Preservation Foundation Stefanie Olivieri August 2, 2003
Dennis and Pat Ward; John and
Janet Moore; Ernie Grossman
and Margaret Lewicki; Graeme '
Fraser and Tracy Lum; Tom and
Elisabeth Grossman; Pat Setter;
13 Prosser Woods Estates Lot Owners Augiist 7, 2003 '
14 Area Resident Karen Sessler August 3, 3002
15 Area Residents Robert Yoder and Nancy Davis July 16, 2003
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16 Area Resident Adrian J uncosa August 8, 2003
Northern Sierra Air Quality Gretchen G. Bennitt, Air
17 Management District Pollution Control Officer August 1, 2003
18 East West Partners Rick McConn, Project Manager August 8, 2003 I
19 Area Resident Julie Cooley - Rieders August 6, 2003
20 Area Resident Mike Huber • August 7, 2003
21 Area Resident Dennis A Dickinson August 8, 2003 •
2.3 COMMENTS AND RESPONSES I
2.3.1 REQUIREMENTS FOR RESPONDING TO COMMENTS ON A DRAFT EIR I
CEQA Guidelines. 15088 require that lead agencies evaluate all comments on
environmental issues received on the Draft EIR and . prepare a written response. The
written response must address the significant environmental issue raised and provide a
detailed response, especially when specific comments or suggestions . e.g., additional
mitigation measures) are not accepted. In addition, the written response must be a II
faith and reasoned analysis. However, lead agencies need only respond to
significant environmental issues associated with the proposed project and do not need
to provide all the information requested by commentors, as long as a good faith effort
at full disclosure is made in the EIR (CEQA Guidelines 15204).
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -2 September 2003 '
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2.0 RESPONSE TO COMMENTS
' CEQA Guidelines 15204 recommend that commentors provide detailed comments that
focus on the sufficiency of the Draft EIR in identifying and analyzing the possible impacts
' on the environment and ways in which the significant effects of the project might be
avoided or mitigated. CEQA Guidelines 15204 also note that commentors should
provide an explanation and evidence supporting their comments. Pursuant to CEQA
Guidelines 15064, an effect shall not be considered significant in the absence of
substantial evidence.
' CEQA Guidelines 15088 also recommend that where response to comments results in
revisions to the Draft EIR, that those revisions to the Draft EIR be presented in a separate
section of the Final EIR — Section 3.0 Errata to the Draft EIR.
2.3.2 MASTER RESPONSES
' Several comment letters included common comment themes on issues associated with
the proposed project and the Draft EIR. In order to streamline the Final EIR, master
responses have been prepared for these common comment themes and are
1 addressed under the following issue areas. It should be noted that all comments are
responded to in this Final EIR.
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• Employee /Affordable Housing
• Cumulative Impacts
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' • Water Quality
• Biological Resources: Habitat Values and Wildlife Corridors
• General Plan Consistency
' • Construction Impacts
- Air Quality
- Water Quality
- Noise
• Water Supply
2.3.3 RESPONSES TO COMMENT LETTERS
Written comments on the Draft EIR are reproduced on the following pages, along with
responses to those comments. To assist in referencing comments and responses, the
' following coding system is used:
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• Each letter is numbered (i.e., Letter 1, Letter 2) and each comment within each
' letter is numbered (i.e., comment 1 -1 , comment 1 -2). •
Where changes to the Draft EIR text result from responding to comments, those
changes are included in the response and demarcated with revisions marks (bold italics
for new text, strike out for deleted text).
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Town of Truckee Final Environmental Impact Report
September 2003 2 -3 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS I
2.4 MASTER RESPONSES 1
2.4.1 EMPLOYEE /AFFORDABLE HOUSING ,
Several comment letters expressed concern regarding the adequacy of the
affordable /employee housing setting and impact analysis in the Draft EIR and the
adequacy of the proposed mitigation. Section 4.12 (Population, Housing, and
Socioeconomics) of the EIR provides a detailed description of employment and housing
conditions in the proposed project area as well as for the surrounding region (Draft EIR
pages 4.12 -2 to -6). The proposed project's anticipated direct and cumulative effect
on affordable and employee housing demand in the region is addressed in detail in the
Draft EIR (Draft EIR pages 4.12 -12 to -15). Nonetheless, the existing shortage of
affordable and employee housing in the region, and the proposed project's
contribution to this condition, is a social and economic issue for the Town Council's
consideration and does not result in potentially significant physical effects, either direct
or indirect, on the environment (Draft EIR pages 4.12 -11 to -15). Section 15131 of the
CEQA Guidelines provides that economic and social effects shall not be treated as
significant effects on the environment, and therefore do not require analysis under
CEQA. An EIR may, however, trace the chain of cause and effect between a project's
economic /social effect and any indirect physical change in the environment.
The Town's housing goals are intended to provide housing affordable to all segments of
the community as a whole, however, there are no specific General Plan goals, policies,
or programs that require each and every individual residential project to provide
housing affordable to all segments of the community, or for every job created in
association with a project. The proposed Gray's Crossing project is consistent with the
development density anticipated for the project site in the Town's General Plan for
which an EIR was certified. In other words, the need for affordable housing based on
build -out of the General Plan (which includes the Gray's Crossing, or PC -2, project) has
been addressed, and mitigated for, in the Town's General Plan EIR. In addition, the
Town's General Plan contemplated secondary jobs being created as a consequence
of development on the project site. Affordable housing is being dealt with on a Town -
wide basis through implementation of the Housing Element.
Further, the project as currently proposed is consistent with the General Plan provisions
for the PC -2 area, which calls for the development of a number of affordable housing
units that is equal to 20 percent of the number of market -rate units (PC -2 Policy 8, Land
Use Element). The project proposes the onsite construction of 500 market -rate housing
units and 100 affordable housing units. The 100 affordable units meet the 20 percent
standard as set forth in the General Plan under PC -2 Policy 8.
The number of constructed employee housing units will satisfy the housing needs
generated by the proposed project (as it relates to units, cost, and target market). The
proposed project includes a 92 unit affordable /employee housing complex, comprised
of 64 units of Gray's Crossing employee /affordable housing and 28 units. of Old
Greenwood employee housing. As explained in the Specific Plan (page 30) and
Section 3.0 (Project Description) of the Draft EIR, construction of the affordable and
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -4 September 2003
I 2.O RESPONSE TO COMMENTS
I employee housing units will occur in Phase II, after construction of the cottage units,
and in conjunction with the 18 -hole golf course and Village Center when jobs are
I created and there is a need for such housing as a result of the proposed project. The
Draft EIR also explains that a significant portion of the part-time employees expected to
be employed as golf course starters, course marshals and golf shop and cart staff, are
I anticipated to be retired, high school students, or college students that already live in
the area for other reasons (Draft OR, pages 4.12 -12 to -13). Consequently, although the
affordable housing units would provide housing for less than the maximum number of
I full -time employee equivalents, it would adequately provide for the anticipated full- .
time service sector employees, as well as some additional part-time employees (i.e.,
approximately 144 employees) (Draft EIR, page 4.12 -12). The provision of 64 affordable
I housing units would therefore reduce the increased demand for affordable housing
generated by employees of the proposed project and was determined to result in a
less than significant impact (Draft EIR, page 4.12 -13). Requiring earlier construction of
M . affordable and employee housing units is a policy issue to be considered by the Town
Council. Whether to require additional employee housing beyond what is required by
existing Town policies (including specific PC -2 policies) is also a policy matter for the
I Town Council.
A survey completed in 2002 by the North Lake Tahoe Resort Association supports the
I Draft EIR's findings of less than significant impact (see Appendix S). The Association
completed the survey to determine where current employees live in the North
Tahoe /Truckee area. The results of the survey identified that approximately 89 to 91
=i percent of area employees reside in the North Tahoe /Truckee area rather than travel
outside of the region for housing (North Lake Tahoe Resort Association, 2002). This
information is consistent with the external traffic distribution assumptions in the Draft EIR
I and appendices. The Draft EIR therefore adequately addresses the known project and
cumulative environmental effects associated with the lack of affordable housing in the
region and the related employee traffic in the area.
I Per the applicant, three options are under consideration for managing and maintaining
the employee housing units, including 1) development of a non - profit housing authority
I comprised of Town staff and East West staff, 2) sub - contracting to Nevada County to
oversee the program, or 3) a combination of the first two options. The Town and
applicant continue to discuss the details of this program. The specific number and
I types of units, the number of saleable units (if any), the number of rentable units, the
amount of rent, occupancy rates, and affordability targets (e.g., very low income, low
income, moderate) for the program have yet to be determined. The above issues,
I however, are not germane to physical effects on the environment and do not require
additional analysis under CEQA. Ultimately, who will manage and maintain the
employee housing units is a policy issue to be considered by the Town Council.
1 The general range of salaries for employees of the proposed project and the range of
housing prices are also socioeconomic aspects of the proposed project that do not
I require analysis under CEQA (CEQA Guidelines, § 15131). CEQA, moreover, does not
require the Town to delineate all of the affordable housing available in the area, or
consider the number of units needed to satisfy the unmet need in the area. It would
I also be unconstitutional for the Town to require additional construction of affordable
Town of Truckee Final Environmental Impact Report
September 2003 2 - Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
and employee housing to meet a need for which there is no "nexus" or reasonable '
relationship with that generated by the proposed project.
Finally, the Draft EIR assessed an "Increased Development Option" alternative in the
Alternatives section (6.0), which could result in additional affordable housing units. As
this alternative has been analyzed per CEQA requirements in the Draft EIR, the Council •
may consider options for the provision of additional affordable /employee housing, if
feasible. This would further support the Town's goal of increasing affordable housing
opportunities.
Jobs - Housing Balance
The following is a brief summary of the impact discussion for jobs- housing balance, as
provided in Section 4.12 of the Draft EIR. The Draft EIR determined, as part of a worst -
case scenario jobs /housing balance analysis, that the total maximum number of full
and part-time employees would be 235 (Draft EIR page 4.12 -13). In determining the
need for housing, the Draft EIR utilized the 2000 U.S. Census occupancy rate data for
the Town of 52.8 percent, and determined that The total number of full -time occupied
housing units would be approximately 317. As explained in the Draft EIR, the
jobs /housing ratio for the proposed project would therefore be 0.74 (235 divided by
317), and below the 1.50 ratio for the Town as a whole. The Draft EIR, therefore,
concluded that impacts from the proposed project to the Town's job /housing balance
would be less than significant. Different methods for calculating full time occupancy
were not provided by commentors on the Draft EIR.
2.4.2 CUMULATIVE IMPACTS
Several comment letters expressed concern that the Draft EIR failed to provide an
adequate analysis of the cumulative impacts of the proposed project, taking into
account anticipated development in the region, and that the Draft EIR failed to
adequately describe the cumulative setting conditions. As described in Section 5.0
(Cumulative Impacts Summary) of the Draft EIR, CEQA requires that an Environmental
Impact Report (EIR) contain an assessment of the cumulative impacts that could be
associated with the proposed project.
According to CEQA Guidelines Section 15130(a), "an EIR shall discuss cumulative
impacts of a project when the project's incremental effect is cumulatively
considerable." "Cumulatively considerable" means that the incremental effects of an
individual project are considerable when viewed in connection with the effects of past
projects, the effects of other current projects, and the effects of probable future
• projects (as defined by Section 15130). As defined in CEQA Guidelines Section 15355, a
cumulative impact consists of an impact that is created as a result of the combination
of the project evaluated in the EIR together with other projects causing related
impacts. A cumulative impact occurs from:
. . the change in the environment which results from the incremental
impact of the project when added to other closely related past, present, and
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -6 September2003
2.0 RESPONSE TO COMMENTS
' reasonably foreseeable future projects. Cumulative impacts can result from
individually minor but collectively significant projects taking place over a
1 period of time.
In addition, Section 15130(b) identifies that the following three elements are necessary
for an adequate cumulative analysis:
1) Either:
(A) A list of past, present, and probable future projects producing related or
cumulative impacts, including, if necessary, those projects outside the
control of the agency; or,
(B) A summary of projections contained in an adopted general plan or related •
planning document, or in a prior environmental document which has been
adopted or certified, which described or evaluated regional or area wide
r conditions contributing to the cumulative impact. Any such planning
document shall be referenced and made available to the public at a
location specified by the lead agency.
' 2) A summary of the expected environmental effects to be produced by those
projects with specific reference to additional information stating where that
information is available; and
3) A reasonable analysis of the cumulative impacts of the relevant projects. An EIR
shall examine reasonable, feasible options for mitigating or avoiding the
project's contribution to any significant cumulative effects.
The Gray's Crossing Draft EIR utilizes both the "list" and the "general plan" approach in
the cumulative analysis. The most relevant related planning document for the
proposed project site is the Town of Truckee General Plan, and it was therefore utilized
in consideration of cumulative conditions, impacts, and mitigation measures. The
cumulative impacts analysis was not based solely on the Town's 1996 General Plan and
associated EIR, however. The Draft EIR looks beyond the Town's General Plan
cumulative setting and buildout condition and also analyzes the potential cumulative
impacts of the proposed project in conjunction with proposed or reasonably
foreseeable development for the entire Mortis Valley region. Ultimately, the Draft FIR
analyzes the cumulative impacts of the proposed project with existing, approved, and
proposed projects in the Martis Valley area and with the Town's 1996 General Plan EIR.
The Draft EIR failed to address the cumulative environmental effect of the lack of
' employee housing.
Project and cumulative impacts to affordable /employee housing demand in the region
is addressed in detail in Section 4.12 (Population, Housing, and Socioeconomics) of the
D raft FIR (Draft FIR pages 4.12 -12 through -15). The shortage of affordable /employee
housing in the region and the project's contribution to this condition is a
social /economic issue and is not itself a physical effect on the environment as set forth
in CEQA Guidelines Section 15131. However, an EIR. may trace a chain of cause and
effect from a project's economic or social change to physical changes in the
' environment. The Draft OR evaluates project consistency with the Town of Truckee
Town of Truckee Final Environmental Impact Report
September 2003 2 -7 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS '
General Plan and takes into account environmental effects of a lack of
affordable /employee housing from the project, which would result in employees
traveling outside of the area to find available housing; these employee trips were
included in the project trip generation numbers (Draft EIR page 4.2 -31). The resulting
environmental effect is increased traffic, air pollution and traffic noise impacts, which
were considered in the Draft EIR. Thus, the Draft EIR does take into account the known
project and cumulative environmental effects associated with the regional need for
more affordable /employee housing. See Master Response 2.4.1 Employee /Affordable
• Housing for further discussion of the affordable /employee housing effects of the project.
The Draft EIR failed to provide a large enough geographic area to address cumulative
impacts and should be expanded to include the Cities of Auburn and Reno, Nevada.
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The Draft EIR includes an adequate description of the general cumulative setting
conditions associated with the proposed project (Draft EIR pages 3 -2 to -6). The scope
includes existing development in the Prosser and Town of Truckee areas as well as
proposed development in the Martis Valley. A comprehensive list of existing and
proposed projects, including the Old Greenwood Resort project and projects within the 111 Martis Valley area, is also identified and considered as part of the Draft EIR's analysis
(Draft EIR pages 3 -7 to -13 (Table 3 -1)). For purposes of the cumulative hydrology and
water quality analysis (a resource that moves beyond such static boundaries as those
defined by a General Plan), the Draft EIR considered a 428 square mile area of the
Truckee River watershed located within the Town of Truckee, Placer County and
Nevada County, and including the area that extends from the outflow of Lake Tahoe to
the California /Nevada state line (Draft EIR, pages 4.6 -31, 4.7 -34). In addition, the Air
Quality cumulative analysis, for example, looks beyond the Town's General Plan sphere
to the larger basin and measures the potential impacts of the proposed project against
thresholds based on existing conditions. The scope of the geographical area
considered is therefore adequate under CEQA (CEQA Guidelines, § 15130(b) (1) (B) (3)).
Each technical section of the Draft EIR (Section 4.1 to 4.12) provides a specific 1
description of the cumulative setting conditions for each issue area. In regards to the
extent of the study area for the traffic analysis, and given the distance from the cities of
Auburn and Reno, the proposed project is not expected to result in any significant
traffic impacts to those areas and no evidence has been submitted that illustrates such
a cumulative traffic impact could occur.
The provision of affordable and employee housing included in the proposed project will
• accommodate a significant portion the project's housing needs, thereby eliminating
the need for employees to commute from outside areas. While employees commuting
to and from the proposed project area has been suggested as a reason to consider
traffic impacts in the Lake Tahoe, Auburn and Reno areas, a 2002 survey completed by
the North Lake Tahoe Resort Association, and regarding where current employees in
the North Tahoe /Truckee area reside, identifies that approximately 89 to 91 percent of
area employees reside in the immediate area. This information is consistent with the
Draft EIR's analysis and the external traffic distribution assumptions in the Draft EIR and
appendices.
•
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -8 September 2003
•
1 2.0 RESPONSE TO COMMENTS
' The Draft EIR does address the proposed project's contribution to cumulative traffic
impacts on Interstate 80 and SR 89. As explained, the proposed project is expected to
I add 272 weekday PM peak -hour trips to 1 -80 east of SR 267 and 62 weekday PM peak -
hour trips along 1 -80 west of SR 267. The Draft EIR also notes that 1 -80 is expected to
operate at LOS F by 2017 with no improvements. Because there are currently no
I programmed improvements or funding for improvements to the mainline of Interstate
80 and such improvements are not under control of the Town of Truckee, the Draft EIR
concludes that the proposed project's cumulative impact is significant and
I unavoidable (Draft EIR, page 4.2 -89).
Several commentors suggested that the traffic analysis should include at a minimum
I the areas where trips will terminate or end and a study area that includes Lake Tahoe.
As shown in Figure 4.2 -5 in the Draft EIR the project would generate approximately 57
peak -hour trips into Lake Tahoe upon build out. This would result in a 4 percent increase
I over existing volumes along SR 28. This is not considered a significant impact. To further
validate this conclusion, the existing peak season traffic volumes contained in the
administrative draft Kings Beach Commercial Core Traffic Study were used to calculate ,
I LOS at the SR 267/SR 28 intersection with and without the project - generated traffic. The
LOS calculations may be found in Appendix N. Without the project traffic, the
intersection operates at a LOS B. With the addition of Gray's Crossing project -
generated traffic, the LOS decreases from B to C, but total intersection delay only
increases by 3.3 seconds per vehicle. As TRPA's LOS threshold at this intersection is up to
four hours per day of LOS E, the project can be considered to not have a significant
I impact within the Tahoe Basin.
The Draft EIR fails to quantify the extent of cumulative impacts, including construction
I impacts.
Some comment letters stated that the cumulative impact analysis in the Draft EIR was
I inadequate because it failed to provide quantification of the extent of the impacts
identified. CEQA Guidelines Section 15130 (b) specifically provides that the discussion
of cumulative impacts shall reflect the severity of the impacts and their likelihood of
I occurrence, but that the discussion need not provide as great detail as is provided for
the effects attributable to the proposed project alone.
J Nonetheless, in several of the technical sections of the Draft EIR, quantitative
information regarding the extent of the cumulative effect and /or the proposed
project's contribution is provided. Specifically, quantitative information is considered
I , and provided for traffic (Draft FIR page 4.2 -89 and Appendix B of Draft EIR), noise (Draft
EIR page 4.3 -25 and Appendix C of Draft FIR), air quality (Draft FIR pages 4.4 -18 to -19
and Appendix D of Draft EIR (including air quality impacts from construction)), water
I supply (Draft EIR pages 4.6 -31 to -32), and population, housing and socioeconomics
(Draft EIR pages 4.12 -14 to -15). As suggested by some commentors, cumulative noise
impacts will not result from construction of the Old Greenwood and Gray's Crossing
I projects because Old Greenwood will likely be completed prior to construction of
Gray's Crossing. Any outstanding construction on Old Greenwood would, moreover,
occur on the opposite side of Hwy 80 and would not be heard at the Gray's Crossing
I site, and vice versa due to the existing traffic noise generated by I -80. The Draft EIR
Town of Truckee Final Environmental Impact Report
September 2003 2 - Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS I
provides both quantified and other technical data to adequately address the
cumulative impacts associated with the proposed project pursuant to the requirements
of CEQA. I
Further, the traffic consultant, LSC, conducted subsequent analysis regarding
cumulative traffic impacts from construction, as well as provided more details regarding
the difficulty of quantifying cumulative 1 -80 traffic impacts. Please see Responses to
Comments 10-16 and 2 -9, respectively.
The Draft EIR fails to support the conclusion that cumulative water quality impacts will be
less than significant.
Ample evidence exists in the Draft EIR supporting the conclusion that the proposed '
project will result in less than significant cumulative water quality impacts. With respect
to flooding, the Draft EIR recognizes that the proposed project could result, in •
conjunction with other development in the project area (i.e., Mart's Valley), in
potentially significant impacts to the Truckee River and its sub - watersheds (Draft EIR,
pages 4.6 -32 to -33). Mitigation Measures 4.6.3a (Notice of Intent per the State General
Construction Storm Water Permit), 4.6.3b (SWPPP), and 4.6.7 (Master Drainage Plan)
include, as part of the proposed project's performance standards required by the
RWQCB, "no net increase in turbidity, sediment or other pollutant loads in Prosser Creek
and the Truckee River," "no net positive increase in flow" and "no net increase in peak
off -site flows from design storm event" (see. Draft EIR pages 4.6 -18, -27, -32 to -33 and
Appendices El to E3). Stormwater retention BMPs will be sized to meet the RWQCB's
standards for the 20 -year, I hour storm (Specific Plan page 96). The Draft EIR therefore
does not impermissibly defer water quality mitigation measures under CEQA (CEQA
Guidelines, § 15126.4).
1
Adoption and implementation of a CHAMP and water quality monitoring plan (MM
4.6.4) also support the conclusion that the proposed project will not result in significant
cumulative increases in pollutant or sediment loads. The applicant has incorporated
the requirements of the CHAMP identified in MM 4.6.4 in the Draft EIR into a Natural
Resource Management Plan (NRMP) in order to have a comprehensive single- source
management plan for the Gray's Crossing project (a Draft of the NRMP, as well as the
Ecological Design, is provided as Appendix A to this Final EIR). Although there are no
set standards for CHAMPs in the Lahontan Region, the CHAMP (or NRMP) will adhere to
the water quality objectives for pesticides as specified in the Basin Plan (Draft EIR pages
4.6 -21 to -22) and will be reviewed and commented on by the Lahontan Regional
Board. The water quality objectives for pesticides include objectives for insecticides,
herbicides, rodenticides, and fungicides. Extensive water quality monitoring would be
performed to assure that the project is not degrading surface or ground water quality.
Specific to water quality monitoring, the Draft NRMP has a section entitled
Environmental Monitoring Program found on pages 7 -10 through 7 -27. This section spells
out a detailed and comprehensive water quality program that will require monitoring
and sampling of surface water, wetland sediments, and ground water at several
locations and at multiple times of the year for constituents of concern. The Regional
Board will have an opportunity to provide further input into the acceptability of this
water quality monitoring program when a Final NRMP is provided to them for approval I
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -10 September 2003
•
2.0 RESPONSE TO COMMENTS
as required by MM 4.6.4 Other existing and proposed projects with golf courses in the
Mortis Valley must also adhere to the same or similar standards, supporting the Draft
EIR's conclusion that the proposed project will result in less than significant cumulative
water quality impacts (see Old Greenwood Draft EIR pages 4.6 -15 to -17, -23; see also •
the Mortis Valley Community Plan Update Draft EIR pages 4.7 -43 to -44, and 4.7-66 to -
68).
Section 4.6, Impact 4.6.5, also includes a discussion of the potential impacts to water
quality from construction activities. As discussed in the Draft EIR, implementation of the
comprehensive "construction activity" management plan, including receipt of an
NPDES permit and preparation of a SWPPP, ensures that construction impacts, including
construction of any detention basins and drainage areas, are less than significant (Draft
EIR pages 4.6 -22 to -23).
See also Master Response 2.4.3 regarding the adequacy of the Draft EIR's water quality
analysis.
1 2.4.3 WATER QUALITY
Several comment letters expressed concern that the Draft EIR does not adequately
address surface water quality effects of the proposed project and /or mitigation
measures proposed in the Draft EIR are not adequate or lack adequate detail to ensure
no increases in surface water pollutant conditions. Section 4.6 (Hydrology and Water
Quality) of the Draft EIR provides an extensive analysis of surface water quality and
potential impacts associated with implementation of the proposed project. This section
includes consideration of water quality impacts associated with construction (e.g.,
grading activities, construction of the SR 89 /Alder Drive /Prosser Dam Road roundabout,
sediment, and accidental spills of construction materials such as fuels and paints) (Draft
EIR pages 4.6 -15, 4.6 -22 to 4.6 -23), operational water quality impacts (e.g., use of
fertilizers, herbicides and pesticides, and operation of the golf course) (Draft EIR pages
4.6 -19 to 4.6 -22), increase surface water runoff (Draft EIR pages 4.6 -26 to 4.6 -27), and
groundwater quality impacts (e.g., urban -type run -off that infiltrates and use of
chemicals and fertilizers) (Draft EIR pages 4.6 -16 to 4.6 -22).
The Gray's Crossing Specific Plan requires preparation of an Erosion and Sediment
Control Plan prior to the issuance of a grading permit to ensure adequate erosion
control protection during grading operations: Per the Specific Plan, details of the Erosion
Control Plan are required to be in conformance with the Best Management Practices
' Handbook Standards, Volume II, Tahoe Regional Planning Agency, November 1988, or
as amended (Specific Plan page 150). The Erosion Control Plan will be submitted to the
Lahontan RWQCB for their review and approval as part of the NPDES /SWPPP process.
The Specific Plan requires development and submission of a Master. Drainage Plan with
each development plan as required by MM 4.6.7, and in compliance with Section
18.30.050 of the Town of Truckee Development Code, Truckee Public Improvement and
Engineering Standards as discussed in the Draft EIR (see Draft EIR Impact and MM 4.6.7).
As explained in the Draft EIR, the preparation of specific engineering drainage plans
would be speculative and inefficient at this time because the Town could change the
' Town of Truckee Final Environmental Impact Report
. September 2003 2 -1 1 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
number of units or alter the footprint of development (Draft EIR page 4.6 -27). 1
Nonetheless, a Preliminary Drainage Plan has been prepared for the project site and is
attached as Appendix B. Per MM 4.6.7, the Lahontan Regional Board, Caltrans, and
the Town of Truckee will have the opportunity to review and approve the final drainage
plan (including engineered drainage calculations based on the final project design) to
ensure that it meets their standards.
• Mitigation Measures discussed and required in the Draft EIR include preparation of a
SWPPP and compliance with its NPDES permit to ensure placement of water quality
control measures and BMPs prior to construction (MM 4.6.3b), and a Chemical
Application and Management Plan (CHAMP), or similar program, that includes a water
quality monitoring plan for the proposed golf course (MM 4.6.4), and Master Drainage
Plan (MM 4.6.7). The same mitigation measures and policies have proven to be
effective in the region as demonstrated by the management of the nearby Lahontan
planned community. The CHAMP has been folded into the Audubon International
Natural Resource Management Plan (NRMP) (a draft NRMP for the Gray's Crossing site is
attached as Appendix A) in order to have a comprehensive single- source
management plan for the Gray's Crossing project (see Response to Comment 1 -6).
1
To provide some reference as to the possible effectiveness of mitigation measures and
regulatory requirements in reducing water quality impacts to less than significant levels,
below is a brief summary of comprehensive water quality monitoring at the Lahontan I
development located southwest of Truckee in the Placer County portion of Martis
Valley. Water quality sampling monitoring data for the Lahontan I community have
been routinely submitted to the Lahontan Regional Water Quality Control Board. The
data reflects the short and long term effectiveness of the water quality mitigation
required by the chemical application management plan (CHAMP) for the Lahontan
golf course. Water quality sampling of Martis Creek. associated with the Lahontan
development has been conducted on a quarterly basis for six years. The monitoring
includes sampling of surface water quality upstream of Lahontan, sampling within
Lahontan along Martis Creek and associated tributaries, and sampling downstream of
Lahontan (Huffman & Carpenter, Inc., Cumulative Water Quality Analyses Report for
Lahontan Development 1996 -2002 (March 2003) (see Appendix C for a copy of the
Report without figures and attachments). According to the monitoring results,
development of the Lahontan I community has not resulted in any significant difference
in water quality conditions in the Martis Creek watershed area as a result of the
implementation of effective BMPs.:
The following summary of the Huffman & Carpenter report is provided as it reflects what
can be expected from the Gray's Crossing project due to similar water quality
mitigation measures, BMPs, and regulatory requirements. The Huffman & Carpenter
Report for the Lahontan Development provides a summary and analysis of water
quality monitoring data on Martis Creek collected for the Lahontan Development from
1996 to the second quarter of 2002 for the following constituents:
Total Kjeldahl nitrogen (TKN) I
Nitrite /Nitrate (NO2 -3 -N)
r
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -12 September 2003
2.0 RESPONSE TO COMMENTS
Sulfate (SO4) •
Total Dissolved Solids (TDS)
Chloride (CI)
Iron (Fe)
Total Nitrogen (N)
Total Phosphorus (TP)
Boron (B)
As documented in the report, development and operation of the Lahontan I
development has not resulted in any statistically significant difference in water quality
conditions in Martis Creek based on comparisons with upstream water quality
conditions identified as Station 2 in the report. The study considers the constituents of
concern to the RWQCB (e.g., TDS and phosphorous). As demonstrated in the report,
water quality monitoring and the proper implementation of water quality control
measures such as CHAMPs, infiltration basins, and site designs that allow for drainage
across open space areas, are effective tools in maintaining existing water quality
standards.
• Similar to the Lahontan I project discussed above, the Gray's Crossing project proposes
construction of single - family units in conjunction with a golf course and includes
development and implementation of extensive mitigation measures and an Audubon
International signature program to ensure protection of water quality to the maximum
' extent feasible. MM 4.6.4 specifically requires the implementation of a CHAMP to .
ensure that the golf course design and operation does not result in surface or
groundwater contamination. Although the Lahontan RWQCB does not have set
standards for CHAMPs, the proposed project will, among other things, refrain from using
any chemical listed pursuant to Proposition 65. As discussed earlier in this Master
Response, the CHAMP is being rolled into the Audubon International NRMP (see
Appendix A). As explained in the Draft EIR, organic techniques will be used to support
the growth of turf soil. Consistent with that philosophy, petroleum based chemicals will
not be used as part of the golf course management program. The CHAMP (or NRMP)
will be prepared and submitted to the Town of Truckee, Nevada County and the
RWQCB for additional input and approval (see MM 4.6.4). MM 4.6.4 also requires
surface and groundwater monitoring to ensure that no contamination occurs. The
Draft NRMP already spells out a detailed and comprehensive water quality monitoring
program (see also Response to Comment 1 -6 regarding water quality monitoring).
Implementation of the project's Master Drainage Plan and drainage features, such as
infiltration' basins and overland flow of storm drainage to the open space areas (MM
4.6.7), provides adequate protection via drainage through the filtering effect of
vegetation and materials in the soil. This conclusion is supported by the "Cumulative
Water Quality Analysis Report for Lahontan Development (1996- 2002)" and errata. In
addition, the California Storm Water Best Management Practice Handbook (Municipal)
1 prepared by the Stormwater Quality Task Force identifies that infiltration and retention
systems for storm water disposal (as proposed by the project) are effective in controlling
Town of Truckee Final Environmental Impact Report
September 2003 2 -13 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS I
storm water quality and have been successfully operated in communities for over two '
decades (Stormwater Quality Task Force, 1993).
Implementation of proposed Specific Plan policies and implementation programs r
identified in Section 4.6 (Hydrology and Water Quality) of the Draft EIR and Mitigation
Measures 4.6.3 through 4.6.9 would require construction and operational features of the
proposed project to provide sufficient water quality control measures to ensure "no net
positive increase in flow" and "no net increase in peak off -site flows from design storm
event" consistent with Lahontan RWQCB policy, and no increase in turbidity, sediment
or other pollutant loads in natural waterways as a performance standard. In addition to
these mitigation measures, Specific Plan policies and implementation programs
described above require use of BMPs (e.g., chemical management application plan,
detention/ retention basins, snow storage areas, etc.). The use of performance
standard mitigation is allowed under CEQA Guidelines Section 15126.4(a) and is
supported by case law (see Sacramento Old City Assn v. City Council of Sacramento
(1991) 229 Cal.App.3d 1011, 1028 -1030 (affirming trial court holding that the City's
commitment to develop a Transportation Management Plan was adequate under
CEQA)). i
•
The Specific Plan policies combined with the Draft EIR mitigation measures 4.6.3a -c;
4.6.4; 4.6.7; and 4.6.9a -b, and including the performance standard of no increase in
sediment, turbidity, or other pollutant loads in natural waterways, are sufficient for
ensuring the protection of water quality for the proposed project.
2.4.4 BIOLOGICAL RESOURCES: HABITAT VALUES AND WILDLIFE CORRIDORS 1
Several commentors raised concerns regarding loss of habitat and the project 's effect
on wildlife corridors. The Draft EIR addresses the significance of these impacts in Section
4.7 (Biological Resources). The analysis in Section 4.7 of the Draft EIR was based on
considerable research as well as field level and aerial surveys of the project area. For a
detailed discussion of surveys and research materials please refer to pages 4.7 -1, 4.7 -21
to 22 in the Draft EIR.
The Draft EIR acknowledges that implementation of the proposed project will result in
the removal of common mixed pine and mixed basin sage scrub habitat (Draft EIR
Impacts 4.7.1, 4.7.2). Such habitat, however, is not unique and is, in fact, abundant in
the region. Impacts to common species are considered less than significant unless the
proposed project has the potential to affect a common species throughout a large
portion of its known range (i.e., threatens to eliminate the species), has potential to
cause populations of common species to fall below self- sustaining levels, or the
proposed project has the potential to affect the movement of the common species
from one seasonal range to another. The loss of approximately. 310 acres of locally and
regionally abundant habitat (Great Basin Sage Scrub and Mixed Pine Forest) would not
be considered of sufficiently large magnitude to significantly impact species common
to the Sierra Nevada Mountains. In addition, the project proposes to preserve large
areas of this habitat as open space. The Draft EIR conclusions are consistent with loss of
habitat for common wildlife species, which are not formally regulated by any federal or
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -14 September 2003
2.0 RESPONSE TO COMMENTS
state agency. The loss of common habitat combined with the dedication of open
space is consistent with Town of Truckee policies and consistent with the General Plan.
Therefore, impacts to common species have been adequately considered in the Draft
EIR.
I Several commentors inquired about the creation of a land acquisition /easement
program to offset impacts associated with the loss of on -site common habitat. As
discussed above, the loss of habitat is consistent with the Town of Truckee General Plan
policies and with the impacts analyzed in the EIR prepared for the General Plan.
Regardless, the following information provides additional insight into how the PC -2 site
was proposed for development. The PC -2 property was previously part of a land
transfer. between the U.S. Forest Service (USFS) and the Hopkins Land Trust that took
place in 1983. At that time, the Hopkins Land Trust agreed to exchange two large
parcels totaling 11,007.94 acres (2,248.59 acres in Sierra County and 8,759.35 acres in
Nevada County), and determined to be high quality wildlife habitat surrounded by
existing USFS, for 2,190.38 acres of USFS land (437.5 acres located in Placer County and
1,752.88 acres located in Nevada County, and both located in the vicinity of Truckee),
that was determined to be less biologically valuable and adjacent to urbanizing areas.
The land transfer represented over a 5:1 exchange ratio. According to the
Environmental Assessment (EA) prepared by the USFS for the land exchange, the USFS
' acknowledged that Federal lands to be provided to the Hopkins Land Trust would most
likely be developed for commercial and residential uses, but that it was an appropriate
action in light of the significantly larger tracts of key wildlife habitat and recreational use
areas that the USFS would receive in exchange. Taken from the land exchange EA,
below is a verbatim wildlife comparison of the Federal lands (which are now private
and include the PC -2 site) and the non - Federal lands (previously the Hopkins Land Trust
1 parcels):
Non- Federal - The lands contain a number of key wildlife habitat areas. These
sites are essentially meadow and grasslands located along major water courses,
around springs, and in the flats lying southerly of Russell Valley. These riparian
areas are used by ducks for spring nesting and by deer for fawning.
Three deer migration routes pass through the non - Federal lands. The deer utilize
these routes in the fall returning to their winter habitat east of the Verdi Range.
I Bald eagles (on the Federal endangered species list) have been observed. Also,
golden eagles, peregrine falcons, prairie falcons, osprey, and goshawk (on the
USFS sensitive list) have been observed in the area. No nesting sites have been
found, however.
I Federal - The lands contain no key wildlife habitat areas. Bald and golden
eagles have been observed over the area, but no. nesting sites have been
found.
It is unclear if the observations of bald or golden eagles discussed above took place
over the PC -2 site or on the other approximately 1,400 acres of Federal land that was
part of the exchange.
Town of Truckee Final Environmental Impact Report
September 2003 2 -15 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS I
The provision of this information simply points out that in 1983, large tracts of private I
land, which contain more valuable and diverse wildlife habitat, were exchanged with
the USFS for Federal land (which contained the PC -2 site) with less valuable and diverse
habitat at a 5:1 ratio. A key factor in the USFS decision to participate in the land
exchange was that its land was less valuable from a wildlife habitat perspective. Even
though the land would be developed in the future, the USFS realized it was worth the
exchange to receive a significantly greater amount of land with higher quality wildlife
habitat. In effect, dedication of wildlife habitat at a 5:1 ratio was provided to offset the
habitat that would be lost to development as part of the land exchange.
Further, with respect to the preservation of common habitat, and management of the
project site generally, the project applicant incorporated the goals of the Audubon
International (Al) Sustainable Development Program — Gold Status (attached as
Appendix A is a Draft of the Al Natural Resource Management Plan). The Audubon
program merges wildlife conservation, habitat enhancement, resource conservation,
community education, and environmental improvement with the economic agenda
associated with the development. The Gold Level, which according to MM 4.7.2 the
applicant must fulfill on an annual basis, provides the most comprehensive degree of
support from Al. A team of Al experts will participate in design, construction, and site
management. Al will prepare an Environmental Master Plan, including a Natural
Resource Management Plan (NRMP) and Ecological Design, for all aspects of the
proposed project (a Draft of the NRMP and Ecological Design is attached as Appendix r
A, however, Section 10 dealing with wildlife and habitat enhancement has not been
completed at this time and will be available in the next several months for Town
review). The Final NRMP will include an assessment of and plans for: wildlife conservation
and habitat enhancement; waste reduction and management; energy efficiency;
water conservation; water quality management; and integrated pest management.
Upon completion, the NRMP is submitted to 'Audubon International for review. After
approval and six months after project completion, an on -site environmental review of
the project will be performed to ensure the NRMP has been implemented. If the NRMP
is approved and Audubon International approves its implementation, the project
receives its Audubon status.
In order to retain Audubon status, the project must submit annual reports, appropriate I
documentation regarding environmental issues, host periodic site visits, and maintain
current membership status. The removal of common mixed pine and mixed basin sage
scrub habitat was considered less than significant as the loss of this habitat did not
exceed Town or other regulatory agency thresholds. Regardless, the applicant is .
instituting a comprehensive Natural Resource Management Plan to enhance on -site
habitat values.
Several comments also assert that removal of habitat raises concerns regarding
potential interference with wildlife movement and migration. Local wildlife, like black
bears and coyotes, move within established home ranges and migratory Loyalton deer
pass through Martis Valley annually returning to Nevada each winter after fawning.
Loyalton deer migration routes have been studied in detail and are well documented
(see e.g., 1988 CDFG Study and 1990 Caltrans, Pencovic and Brown Study).
Documented migration routes do not pass through the project site (see e.g., Pencovic
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -16 September 2003
2.0 RESPONSE TO COMMENTS
•
and Brown 1990, p. 26). The Loyalton deer herd primarily utilizes two crossings located
over seven miles east of the project site. Individual Loyalton deer, however, have been
found to also cross 1 -80 just east of the project's eastern boundary at the Fibreboard and
Prosser Village Undercrossings (CDFG, 1988; Pencovic and Brown, 1990). Golf course
improvements are proposed on the project's eastern edge, but are to be located well
over 500 feet from the Fibreboard Undercrossing. In addition to this buffer, planned golf
features are located uphill and existing trees will be retained to provide screening. The
• FIR, therefore, determined that potential impacts to migration corridors are less than
significant. Mitigation Measure 4.7.10 provides further assurance with respect to
potential impacts to migratory wildlife movement. This measure requires the applicant
to preserve contiguous stands of trees, landscape with native Sierra Nevada flora, and
s use security fencing that meets CDFG requirements (Draft EIR, MM 4.7.10).
With respect to movements of local wildlife, the proposed project has been designed
to minimize potential impacts to local migration. In addition to clustering development
and preserving wooded areas and other habitat, the project proposes to leave 100 -
year floodplain areas, adjacent to the two drainage swales that bisect the project site,
undeveloped. As shown in Figure 3 -6 of the Draft EIR, these undeveloped areas would
provide a buffer zone ranging from approximately 30 feet to 300 feet wide along
seasonal tributaries, which would preserve east /west migration routes. This buffer zone is
also largely surrounded by undeveloped areas, such as the rough turf portions of the
project's golf course, which further facilitates migration as there would be no physical
barriers to wildlife movement. Thus, the Draft EIR determined that this potential impact
to movements of local wildlife is less than significant (Draft EIR pages 4.7 -32 to 33).
The proposed project should also be viewed in the context of surrounding land uses
(see Draft EIR Section 3.0 Project Description). The proposed project represents planned
growth directly adjacent to the Town core and has been designated for this type of
development in the Truckee General Plan since 1996. The project site is located
immediately north of 1 -80 and is bisected by SR 89. The surrounding vicinity and land
uses are primarily residential. Surrounding subdivisions include Prosser Lake Heights and
the existing Tahoe - Donner Planned Community to the west; Prosser Lakeview Estates,
Prosser Woods, Prosser Lake Acreage, and Pannonia Ranchos to the north and
northeast; the Old Greenwood and Olympic Heights Subdivision are located southeast
of 1 -80; and the Pine Forest subdivision and Downtown Truckee to the southwest. The
' project area is surrounded by a significant amount of development and common
habitat is highly fragmented (see Draft EIR Figure 4.1 -1).
While existing development and fragmentation of the area lessens the significance of
r project - specific impacts to biological resources, these impacts may become more
cumulatively significant as development increases and habitat resources dwindle. The
Draft FIR acknowledges that the proposed project, in conjunction with other future
developments in the Town and region, would contribute to the ongoing loss of natural,
undisturbed open space in the region resulting in a potential decline of biological
resources and species diversity (Draft EIR, Impact 4.7.11). Notably, the Town in its
General Plan has addressed the regional implications of continued growth and
development in and around Truckee. The Town's General Plan, therefore, contains
goals and policies designed to mitigate the cumulative impacts of planned
Town of Truckee Final Environmental Impact Report
September 2003 2 - Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS I
development. Implementation of the General Plan goals and policies that reduce I
potential impacts to biological resources to a less than significant level include all
policies under Conservation and Open Space Goals 1 and 2, as well as Land Use
Policies 7.1 and 7.2, and PC -2 Policies 1 and 2. These policies include, among other
requirements, clustering development and preserving open space and migration
corridors. Because the proposed project was designed to be consistent with such goals
and policies its contribution to possible cumulative biological resource impacts is not
considerable.
2.4.5 GENERAL PLAN CONSISTENCY
Several commentors question the proposed project's consistency with the Town's
General Plan. Under CEQA, a project is consistent with the general plan if it will further
the objectives and policies of the general plan and not bar their attainment. A project
need not be in perfect conformity with every general plan policy. To be consistent, a
project must be compatible with the objectives, policies, general land uses and
programs specified in the general plan (Napa Citizens for Honest Government v. Napa
County Board of Supervisors (2001) 91 Cal.App.4th 342, 378; Families Unafraid to Uphold
Rural El Dorado County v. Board of Supervisors (1998) 62 Cal. App. 4th 1332, 1336).
The Draft EIR provides an extensive analysis of the project's consistency with the General
Plan's goals and policies. Consistency is evaluated as a component of each impact
area in the relevant EIR environmental analysis Section. Where inconsistencies were
identified, appropriate mitigation measures were formulated, including changes to the
project, to ensure that the project is consistent with the General Plan (see e.g., Draft EIR,
Impacts, 4.1.2, 4.1.3, and 4.1.4). As a courtesy, the EIR consultant provided a General
Plan consistency table for each impact area in the relevant EIR environmental analysis
section. Where policies appear to be omitted in a particular section they are generally
reviewed for consistency under a more applicable impact area. Certain policies, .
however, that were determined not to be applicable to the Project were omitted. For
example, Conservation and Open Space Policy 1.2 requires the Town to "[e]stablish an
Open Space Zone District along both sides of the Truckee River outside of the
Downtown Study Area which prohibits all commercial, residential, and industrial
development within a minimum of 150 feet of either side of the River..." Because the
Truckee River does not pass through the project area, this policy does not apply to the
proposed project. In addition, an additional review of the General Plan's goals and
policies was conducted to confirm that all general plan goals and policies relevant to
the project were evaluated in the Draft EIR.
After further review, a modification of the proposed project has been proposed to
ensure consistency with the General Plan. Residential density has been reduced from 10
units to 5 units for the 52.3 -acre parcel designated Open Space Recreation (OSR) in the
General Plan. This parcel is located at the eastern edge of the project site and is shown
with its land use designation marked in Figure 4.2 -1 of the Draft EIR. The General Plan's
Land Use Element provides that residential uses are allowed in OSR at an average
density of 1 housing unit per 10 acres, and with clustering of units required to preserve
open space (Truckee General Plan, Land Use Element, p. 45). Residential and
'Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -18 September2003
2.O RESPONSE TO COMMENTS
recreational development (campgrounds etc.) are also allowed as part of a project
approval if there is also a requirement to preserve 90 percent of the land as open
space. Allowing 1.0 units and 4 golf holes would, therefore, conflict with these provisions
of the General Plan (Draft FIR page 3 -18). Reducing the number of residential units from
10 to 5 on this 52.3 -acre portion of the project site eliminates any potential conflict with
the OSR land use designation in the General Plan. Subsequent site plan submittals will
reflect this minor change to the project.
Commentors' other specific areas of concern included whether the proposed project
was consistent with the General Plan's provisions regarding clustered development and
open space (for a discussion of open space and wildlife habitat /movements corridors
see the Master Response 2.4.4 Biological Resources). The General Plan's policies require
r clustering of residential development to preserve habitat, natural site features, and
• areas of open space (see e.g., General Plan Goal 7, Policies 7.1, 7.2, PC -2 Policy 8).
The proposed project was specifically designed to comply with these General Plan and
PC -2 specific policies.
The project's objectives include clustering residential development in response to
natural features and resources and devoting large areas to open space (Draft EIR page
3 -20). To implement these objectives, as well as relevant General Plan policies, sensitive
natural features, including wetlands, floodplains, steep slopes, and plant communities
were identified. Protection of these resources was then achieved primarily through their
avoidance, which included clustering residential areas in locations where sensitive
features are largely absent or would be minimally affected. As a result of this clustered
design, approximately 417.6 acres of open space is dispersed throughout the project
site in a manner that preserves sensitive site features and resources. The Draft EIR
determined that the proposed project's clustered design is consistent with the General
Plan's goals and policies regarding clustering. Ultimately, however, whether the project
constitutes clustered development as contemplated by the General Plan is a subjective
' determination left to the Town Council, and is part of its ultimate judgment as to
whether the proposed project is consistent with the General.Plan.
The Specific Plan and FIR recognize different types of Open Space including large open
space parcels, which may be maintained by a property owners association, transferred
to a land trust or public entity, and /or preserved by conservation easement, and
undeveloped areas on privately owned land; on which development is restricted by
the Specific Plan's site development standards. This latter type of open space includes
rear yard setbacks in the open space buffers in the Village Center and Attached
Residential District, and lands within golf parcels not devoted to fairway construction.
For the purposes of calculating open space for compliance with the Town's General
Plan and specifically Table 2.4 for the PC -2 land use designation, the Development
Area Map (see Draft FIR, Figure 3 -14) calculates undeveloped land within the Golf and
Open Space Parcels. Open space within the Residential, Attached Residential, and
Village Center areas are not included in the open space calculations, nor is the turf
area of the golf course. PC -2 land uses as identified in the Town's General Plan requires
retention of 290 acres of wildlife habitat /passive open space /trails (see Table 2.4 in the
Town of Truckee General Plan). Total open space area for the proposed project,
excluding the Village, and Attached Residential areas, is approximately 417.6 acres
Town of Truckee Final Environmental Impact Report
September2003 2 -19 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS I
(see Draft EIR, Figure 3 -14). Again, the project is consistent with, or exceeds, all
applicable Town goals and policies.
. Commentors also suggested that approval of the proposed project should be delayed '
until the revision of the Town's General Plan (currently underway) is complete. This is
ultimately a policy decision for the Town Council and these comments have been
forwarded to the Town Council for their consideration. Currently, the Town has not
established a moratorium on the consideration or approval of development projects in
the Town as part of the General Plan Update process. However, the Draft EIR does
evaluate the project's consistency with the existing land use plans and standards in the
Town's General Plan (1996). The project is consistent with existing and proposed land
use policies and development standards and does not conflict with the implementation
of the proposed Town of Truckee General Plan Update. If the Council feels that
imposing a moratorium on development is necessary in light of revisions to the General
• Plan, they have the authority under the Government Code to pass an urgency
measure suspending project approvals during the General Plan Update process (Gov.
Code, §65858). Otherwise, approval of the proposed project need not be delayed
pending completion of the General Plan Update, even if completion of the General
Plan Update would potentially provide additional insights (San Francisco Ecology
Center v. City and County of San Francisco (1975) 48 Cal.App.3d 584, 594; Towards
Responsibility in Planning v. City Council (1988) 200 Cal. App. 3d 671, 681).
Although a public agency is not required to speculate or rely on proposed or draft
regional plans in evaluation of a project, the progress of the Town's General Plan
• Update process has been closely monitored (Chaparral Greens v. City of Chula Vista
(1996) 50 Cal.App.4th 1134, 1145). A review of the most recent Vision Statement for the
General Plan Update indicates that the proposed project remains consistent with the
principals intended to shape Truckee's future growth and development (see Truckee
2025 General Plan Update; Community Workshop #4, June 18, 2003). The most recent
Vision Statement emphasizes clustering new housing, pedestrian oriented development,
the preservation of open space, and reducing sprawl by locating new development
around existing developed areas. The proposed project, as a clustered development
with a pedestrian friendly Village Center, embodies these principles. Moreover, the
proposed project does not contribute to sprawl in that it represents planned growth in
adjacent to the Town core and is surrounded by existing and approved development.
2.4.6 CONSTRUCTION IMPACTS I
Several commentors raised concerns regarding project construction and construction- I
. related impacts. The Draft EIR provides a lengthy description of construction phasing in
Section 3.0 Project Description (Draft EIR pages 3-43 to 45). As described in Section 3.0,
development would occur in four phases over a six -year period.. The timing of each
phase is described and details regarding what project features will be constructed are
provided. The Draft EIR also provides the Gray's Crossing tentative map illustrating
which project components will be included in each phase and showing their locations I
(Draft EIR, Figures 3 -7 to 11). The Draft EIR acknowledges that project construction
would result in various impacts, including increased dust, noise, and traffic (Draft EIR
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -20 September2003
•
2.0 RESPONSE TO COMMENTS
page 4.1 -25). Each physical impact of construction is discussed in the appropriate
section of the EIR. Additional information regarding construction activities, including
' staging areas and a list of BMPs to be implemented for the control of fugitive dust
emissions, will be submitted with the project's site plans /final maps (Draft EIR, MM
4.1.1a). Below are discussions regarding construction - related impacts to air quality,
water quality, and noise. Also, per a commentor's request, the applicant provided
additional details regarding estimated construction traffic for the Gray's Crossing
project and the transportation consultant, LSC, prepared additional analysis of
potential impacts. Please see Response to Comment 10-16 for the additional
construction - related traffic analysis.
Air Quality
The Draft EIR addresses construction air quality impacts attributable to . the proposed
project in Section 4.4, starting on page 4.4 -9. The Draft EIR explains that the URBEMIS-
2001 program was applied to project land uses to estimate the total of construction
emissions from site grading, equipment exhaust, construction worker vehicle trips and
other construction activities. URBEMIS is a computer program used to estimate
emissions associated with land development projects in California such as residential
neighborhoods, shopping centers, office buildings, and construction projects (see
CARB, URBEMIS 2001 Program, 06/18/01 <http: / /www.arb.ca.gov/
planning /urbemis /urbemis.htm >). The program provides default values designed to
require minimal input from the user. Nearly any of the program's assumptions, however,
can be modified if information is available that is more accurate than the program
defaults. The program uses the Institute of Transportation Engineers' Trip Generation
Manual, Version 6.0, along with the ARB's motor vehicle emissions model, EMFAC2001,
Version 2.08, to calculate motor vehicle emissions. Other components of the program
can be used to estimate construction emissions, air quality benefits of construction -
related mitigation measures, emissions from area sources such as gas appliances, wood
stoves, fireplaces, and landscape maintenance equipment, and air quality benefits of
mitigation measures for area sources. With respect to site grading equipment emissions,
for example, the number of housing units and /or the square footage of building
construction are used to estimate the default amount of equipment used. As a default,
the URBEMIS program assumes that two pieces of mobile equipment (one forklift and
one dump truck) are used 8 hours per day for any amount of construction up to 10 units
or 10,000 square feet. The default amount of mobile source equipment is assumed to
double for each doubling in the size of the land use. It is assumed that the equipment is
diesel- powered and used 8 hours per day (see URBEMIS7G for. Windows, Computer
Program User's Guide, October 2000). For the Draft EIR, default values were assumed
for all URBEMIS program inputs, with adjustments to account for the multi -year build -out
period for the project (Draft EIR page 4.1 -25). The URBEMIS -2001 model output for the
proposed project is included as Appendix D to the Draft EIR.
The Draft EIR acknowledges that construction related air quality impacts are potentially
significant and several mitigation measures are proposed, including Mitigation
Measures 4.1.1b, 4.1.1d, 4.1.1e, 4.4.1a, and 4.4.1b, which among other things require
the applicant to comply with the Implementation Guidelines of the Town of Truckee
Particulate Matter Air Quality Management Plan (documented in a • Fugitive Dust
Town of Truckee Final Environmental Impact Report
September 2003 2 - Gray's Crossing Specific Plan Project
2.O RESPONSE TO COMMENTS I
Prevention and Control Plan) and require the applicant to stage construction
equipment and vehicles on the project site at the end of each workday rather than
removing them from the site (Draft EIR, MM 4.1.1b, 4.1.1 d). '
Dust control mitigation also includes, but are not limited to, the following: excavated,
stockpiled, or graded material shall be watered, treated, or covered; areas with vehicle
traffic shall be watered or have a dust palliative applied; on site vehicle traffic shall be
limited to a speed of 15 mph on unpaved roads; when winds are expected to exceed
20 mph land clearing, grading, earth moving or excavation activities shall be
suspended as necessary to prevent excessive windblown dust; inactive portions of the
construction site shall be covered, seeded, or watered until a suitable cover is
established; paved streets adjacent construction sites shall be swept or washed at the
end of each day, or as required to remove excess accumulations of silt and /or mud
which may have resulted from activities at the construction site; material transported off
site shall be either sufficiently watered or securely covered (Draft EIR, MM 4.4.1a). The
Draft EIR determined that these measures serve to reduce potentially significant
construction related air quality impacts to a less than significant level.
Water Quality I
Water quality impacts attributable to construction of the proposed project were also
considered potentially significant. Water quality impacts from construction activities
are addressed in Section 4.6 Water Quality and Hydrology of the Draft EIR. The Draft EIR
indicates that construction activities associated with implementation of the proposed
project may increase surface runoff and may have an adverse impact on water quality
(Draft EIR, Impacts 4.6.3, 4.6.12). Mitigation of these impacts relies largely on strict
.planning and permitting requirements of agencies including the Lahontan Regional
Water Quality Control Board (RWQCB) (see Draft EIR, MM 4.6.3a, 4.6.3b, and 4.6.3c).
Prior to construction, the Lahontan RWQCB requires the project applicant to file for a
National Pollution Discharge Elimination System (NPDES) General Permit. The General
Permit process requires the project applicant to: (1) notify the State, (2) prepare and
implement a Storm Water Pollution Prevention Plan (SWPPP), and (3) monitor the
effectiveness of that plan (Draft EIR, MM 4.6.3a). As part of the SWPPP, temporary Best
Management Practice (BMP) maintenance requirements are mandated. The RWQCB
Storm Water Quality Task Force has' prepared BMP Handbooks for Construction
Activities, Commercial /Industrial Facilities, and Municipalities, which both list BMPs and
provide an outline for their maintenance requirements (see Draft EIR pages 4.6 -16 to
17). i_
• Implementation of a SWPPP, as required under MM 4.6.3, would ensure that water
quality control measures and BMPs are in place at the time construction activities begin
and that these measures are implemented during construction (Draft EIR page 4.6 -23).
The BMP handbooks discussed herein are included in the Draft EIR as Appendices E1 -E3.
Water quality controls must also be consistent with the Town's Grading Ordinance and
the Lahontan RWQCB's North Lahontan Region Hydrologic Unit Project Guidelines for
Erosion Control (see Response to Comment 1 -4). Pursuant to Mitigation Measure 4.6.3,
water quality controls must ensure no increase in turbidity, sediment or other pollutant I
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -22 September 2003
2.O RESPONSE TO COMMENTS
loads in Prosser Creek and the Truckee River and that storm water discharges are in
compliance with all current requirements of the Lahontan RWQCB. Examples of water
quality controls are listed in the Draft EIR on page 4.6 -18 as part of Mitigation Measure
4.6.3b. See also Response to Comments 1 -9 and 1 -10 for the applicability and the
provision of additional BMPs.
t Mandatory requirements imposed by the Town and responsible agencies such as the
Lahontan RWQCB, in addition to requirements set forth•in Mitigation Measures 4.6.3a,
4.6.3b, and 4.6.3c, mitigate construction water quality impacts. These mandatory
permitting requirements rely on well - established design criteria and performance
standards. It is appropriate to rely on such standards in determining mitigation at this
stage in the planning and as part of the EIR process (CEQA Guidelines, § 15126.4 (a);
see also Sacramento Old City Assn. v. City Council of Sacramento (1991) 229
Cal.App.3d 1011, 1028 -1030; Dry Creek Citizens Coalition v. County of Tulare (5th Dist.
1999) 70 Cal.App.4th 20). CEQA principles provide that environmental impacts should
be assessed as early as possible in the planning process to allow for flexibility in the
design of a project. In the present case, the applicant has already made significant
plan changes during the current environmental review process. It would be infeasible
to require an applicant to acquire in advance all additional entitlements necessary for
a project to proceed and to prepare all supporting documentation, like a SWPPP,
before a project is approved and when the details of a project are still subject to
change. For purposes of CEQA, it is enough to identify the required permitting and
performance standards, with which final plans must comply, together with enough
general information to allow the lead agency to conclude that such standards are
attainable (see e.g., Draft EIR page 4.6 -27 to 28). Nonetheless, the project applicant
has provided a copy of a Preliminary Drainage Plan, which is attached as Appendix B.
Per MM 4.6.7, the Lahontan Regional Board, Caltrans, and the Town of Truckee will have
the opportunity to review and approve the final drainage plan (including engineered
drainage calculations based on the final project design) to ensure that it meets their
M . standards.
Noise
The Draft EIR addresses construction noise impacts in Section 4.3. The Draft EIR states
that noise from construction activities would add to the noise environment in the
immediate project vicinity. Construction activities would generate maximum noise
levels ranging from 85 to 90 dB at a distance of 50 feet (Draft EIR page 4.3 -18).
•
Because project construction could generate noise levels in excess of the Town of
Truckee General Plan noise standards or expose future residents within the project area
to substantial short-term increases in ambient noise levels, construction noise impacts
are considered potentially significant (see Draft EIR page 4.3 -9 (table indicating Truckee
General Plan noise standards)).
Construction noise impacts are addressed in Impact 4.3.4 of the Draft EIR. Due to the
myriad possibilities for combinations of construction equipment types, locations, and
duration of operations, it is not feasible to precisely predict construction noise levels.
Although construction activities will be temporary in nature, and would occur during
daytime hours, a finding of significant noise impact was made for this aspect of the
Town of Truckee Final Environmental Impact Report
September 2003 2 -23 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
project, and mitigation measure 4.3.4 was applied to address this impact. Mitigation
Measure 4.3.4 requires all construction activities adhere to the requirements of the Town
of Truckee with respect to hours of operation, muffling of internal combustion engines,
and other factors to mitigate construction noise generation and its effects on noise -
sensitive land uses (Draft EIR page 4.3-24). Additionally, Mitigation Measure 4.1.1a in the
Land Use section of the Draft EIR requires the project applicant to locate construction
staging areas as far as feasibly possible from existing residential areas. Mitigation
Measure 4.1.1 e, also in the Land Use section, further mandates that fixed construction
equipment, such as compressors and generators, be located as far as feasibly possible
from sensitive receptors and that exhaust ports on power construction equipment must
be muffled and impact tools must be shrouded /shielded to reduce noise (see Draft EIR
page 4.1 -25 to 26). Notably, construction activities and impacts would be localized
and temporary in nature.
In addition, contrary to the suggestion of some commentors, cumulative noise impacts
will not result from construction of the Old Greenwood and Gray's Crossing projects
because Old Greenwood will likely be completed prior to construction of Gray's
Crossing. Any outstanding construction on Old Greenwood would, moreover, occur on
the opposite side of Hwy 80 and would not be heard at the Gray's Crossing site, and
vice versa due to the existing traffic noise generated by 1 -80.
Traffic [.
The traffic consultant; LSC, conducted subsequent analysis regarding cumulative traffic
impacts from construction, which is found in Response to Comment 10-16.
2.4.7 WATER SUPPLY
The Town received a number of comments requesting additional information regarding
water supply for the project. Specifically:
• Comment 6 -1 requested additional information regarding the project's
compliance with Water Code section 10910.
• Comment 6 -16 requested additional information regarding whether existing public
utilities (including water supplies) were adequate to serve the project, and
whether the existing community would be affected by extending service to Gray's
Crossing.
• Comment 10 -11 requested that the EIR contain information regarding the water
supplies relied upon by the project.
Comment 10-20 expressed concern that the EIR could not reach conclusions
about •whether the project would have a significant impact on groundwater
. resources without first determining the "safe yield" for the basin.
• Comment 10 -31 expressed concern that the project could result in cumulatively
significant water supply impacts.
r
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -24. September 2003
2.O RESPONSE TO COMMENTS
Comment 15 -1 expressed concern that groundwater pumping could affect
groundwater levels at homes in the Prosser Ranch and Pannonia neighborhoods,
' both of which rely on wells.
The purpose of this response is to provide the requested information regarding water
. supplies proposed for the project, and to respond to concerns about the adequacy of
those supplies. All documents referenced in this Master Response may be reviewed at
the Town of Truckee Community Development Department under a special technical
appendix prepared entitled "Documents Referenced in Master Response 2.4.7 Water
Supply."
Chapters 4.6 and 4.11.A provide an analysis of the water demand generated by the
project, describe how that demand will be met, and analyze potential impacts
associated with providing water to the project. The water purveyor for the project is the
Truckee Donner Public Utility District (TDPUD). The analysis in Chapters 4.6 and 4.11.A is
based on the TDPUD's Water System Master Plan (1997), on TDPUD's Water System
Master Plan Update (2001), on other information obtained from the TDPUD, and on
'I several studies that have been performed regarding available groundwater supplies in
Mortis Valley.
Some •commentors requested additional information regarding water supply in
accordance with recent legislation, citing SB 221 and SB 610. The Draft EIR includes a
discussion of the requirements of SB 221 and SB 610 (see Draft EIR, pp. 4.11-9 to 4.1 1 -1 1).
The following discussion expands further on the analysis already in the Draft EIR.
SB 610 requires the lead agency to request certain water supply information from the
water purveyor, and to use that information in the lead agency's CEQA analysis. SB 221
does not apply to the CEQA process; rather, SB 221 requires the lead agency to obtain
from the water purveyor a written verification of the adequacy of water supplies prior to
' approving a subdivision or development agreement for the project. Thus, SB 610
applies at the front end of project review, at a time when the lead agency is gathering
information; and SB 221 applies at the back end of project review, at a time when the
agency is considering whether to adopt findings and approve the project. The
information gathered under SB 610 may serve as the evidence necessary to adopt the
verification required under SB 221.
Both SB 610 and SB 221 apply only to projects that exceed certain development
thresholds. SB 610 applies to residential developments containing more than 500
dwelling units, or mixed -use projects that would demand an amount of water
equivalent to, or greater than, the amount of water required by a 500 dwelling -unit
project (Water Code, § 10912). SB 221 applies to residential subdivisions containing
more than 500 . dwelling units (Gov. Code, § 66473.7). Gray's Crossing is a mixed -use
project with more than 500 residential dwelling units. Thus, the Gray's Crossing project
exceeds the thresholds established by SB 610 and SB 221.
•
As part of the CEQA process, on January 15, 2003, the Town requested TDPUD to
provide an analysis of water availability in accordance with SB 610. By letter dated
1 April 4, 2003, the TDPUD responded to this request. TDPUD attached to its response an
Town of Truckee Final Environmental Impact Report
September 2003 2 -25 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS 1
•
"S.B. 610 Compliance Study" for the Gray's Crossing project. A copy of TDPUD's letter I
and compliance study appears as Appendix F of the Draft EIR.
In its letter and compliance study, TDPUD states it has updated its Water Master Plan to '
reflect all anticipated development within its service area, including anticipated
development at the Gray's Crossing site. According to this letter, it] he District has
water supplies available to these areas, which include the currently available source of
supplies that will meet all water demands for the PC2 development including multiple
dry years" (Letter from Ed Taylor, TDPUD Water Utility Manager, to Heidi Scoble,
Associate Planner, Town of Truckee (April 4, 2003)).
According to the SB 610 compliance study, the TDPUD's updated Master Plan
anticipated that demand from Gray's Crossing would total 1,109 acre -feet per year
(Letter from Ed Taylor, TDPUD Water Utility Manager, to Heidi Scoble, Associate Planner,
Town of Truckee (April 4, 2003)). This estimate was based on the level of development
authorized by the Town's General Plan. Actual water demand associated with Gray's
Crossing will be less than the amount assumed by TDPUD when the agency prepared its
updated master plan. As set forth in the Draft EIR, estimated demand for Gray's ,
Crossing is approximately 581 acre - feet /year (see Draft EIR, Table 4.6 -2). For this reason,
TDPUD's SB 610 compliance study is conservative, and over - estimates Gray's Crossing
water demand. . I
Commentors have not submitted information indicating that the project's water
demand will exceed the 581 acre - feet /year estimate as provided in the Draft EIR, Table
4.6 -2. The water demand estimate was prepared based on generally accepted
estimates for water demand generated by the various land uses incorporated into the
project (e.g. residential dwelling units, lodging, etc.). Water demand for the golf course
is based on actual data obtained from the Coyote Moon golf course, extrapolated to
reflect the relative size of the Gray's Crossing course. The Coyote Moon course is also
located in the Town of Truckee; the courses are located in areas with the same climate;
the courses will have similar designs; and the irrigation needs are expected to be similar.
Thus, actual water usage at Coyote Moon represents the best available data on water
demand associated with the proposed golf course. 1
As noted above, one commentor requested additional information regarding the
project's compliance with Water Code section 10910. This section requires the lead
agency (here, the Town of Truckee) to request certain water supply information from
the water purveyor (Wat. Code, § 10910, subds. (b), (c)). The Town complied with this
requirement by submitting such a request to TDPUD.
In response, TDPUD provided the Town with an assessment of available water supplies in
relation to anticipated demand. As required by SB 610, the assessment discussed
projected water demand over a 20 -year period. Total demand for TDPUD's entire
service area at build -out was estimated to be 14,383 acre -feet per year (Note that this
total includes an over - estimate of actual demand for Gray's Crossing, as described
above).
r
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -26 September 2003
1 2.0 RESPONSE TO COMMENTS
As the Draft EIR indicates, water will be supplied to the project from groundwater wells.
Although groundwater supply plans for the project have not been finalized, it appears
likely that the project will be supplied by TDPUD's Glenshire Drive well; this well is
screened in a low aquifer and provides high volumes of high - quality groundwater.
Available data indicates that groundwater wells in the area, including the Glenshire
Drive well, will have adequate capacity to serve the project in normal, single -dry and
multiple -dry years. This analysis indicates TDPUD's total projected water supplies
available during normal, single dry, and multiple dry water years during a 20 -year
projection will meet the projected water demand associated with the proposed
project, in addition to TDPUD's existing and planned future uses, including agricultural
' and manufacturing uses. (See Draft ER, Appendix F; TDPUD Master Plan (1997); TDPUD
Master Plan Update (2001).) The Master Plan and Master Plan Update also contain
TDPUD's capital outlay program to construct the improvements necessary to serve the
project and other anticipated development within the next 20 years.
The California Department of Water Resources has identified Martis Valley as
constituting a distinct groundwater basin (see Department of Water Resources, Bulletin
118 (April 2003 draft)). The basin has not been adjudicated. The Department of Water
Resources has not issued a bulletin identifying the basin as being overdrafted, nor has
the Department issued a bulletin projecting that the basin will become overdrafted.
The Department of Water Resources' Bulletin 118 update indicates that the most
productive geologic formation in the basin is the sedimentary units located in the valley
floor, which are interspersed with relatively impermeable clay layers (Draft Bulletin 118).
Groundwater quality is generally good (Id).
Information on historic groundwater pumping by TDPUD, and projected groundwater
demand in the future, is set forth in the Master Plan and Master Plan Update. This
information is also summarized in Draft EIR Appendix F.
Commentors have not submitted any information contrary to the information set forth in
TDPUD's Master Plan, Master Plan Update, or SB 610 compliance study set forth in
Appendix F to the Draft EIR. Commentors are referred to those documents for further
information pertaining to SB 610.
TDPUD has identified capital improvements necessary to expand its water supply system
. to meet this demand (see SB 610 compliance study, pp. 3 -4). With the implementation
of this improvement program, TDPUD will have adequate capacity to meet the water
needs of its service area, at build -out, at maximum daily demand.
The Gray's Crossing project will have to construct capital improvements necessary to
connect the project to TDPUD's water distribution system. The proposed Specific Plan
and EIR describe these facilities (see Draft EIR, Chapter 3.0, pp. 4.11 -4 — 4.11 -5).
Improvements will include pipelines establishing a loop to improve system reliability for
both Gray's Crossing and for existing development in the area. The project will also be
required to provide approximately 400,000 gallons of storage capacity (see Draft EIR,
MM 4.11.1).
Town of Truckee Final Environmental Impact Report
September 2003 2 -27 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
To ensure adequate supplies at build -out with redundant capacity, TDPUD plans to
develop additional groundwater wells. The project will be required to pay to TDPUD
water hook -up fees. These fees are designed to represent the project's "fair share" for
the development of groundwater supply wells and related infrastructure.
In order to make this requirement explicit, MM 4.1 1.1 found on page 4.1 1 -1 1 of the Draft
EIR is revised as follows: I
Mitigation Measure
MM 4.11.1 Prior to approval of the first phase of development, the project
applicant shall prepare, for review and approval by the Truckee
Donner Public Utilities District (TDPUD), a Water Distribution System
Facilities Report for the proposed project. The report.shall address
the expansion of the water supply facilities and the specific
requirements for all phases of the project. Further, the report shall
incorporate the general guidelines for the water distribution system
identified in the Gray's Crossing Specific Plan, Chapter VII,
Programs, in addition to those identified below. -
• The water distribution system for the Specific Plan area shall be
designed in conformance with the provisions of the TDPUD
Water System Master Plan.
• The water distribution system for the project area will be
designed to be compatible with the future regional distribution
facilities as depicted within the Town's General Plan for the
project area. Each phase of development within the project
area shall size and construct that portion of the system as
determined by the TDPUD. Reimbursement agreements may be
considered subject to TDPUD Standards.
• To supply water service to the Specific Plan area will require
approximately 400,000 gallons of storage capacity. A
combination of on- and /or off -site wells as determined by the
TDPUD will provide the water source. Service to the individual
development components within the project area will be via
water distribution lines in various sizes located within the
roadway right -of -ways.
• Water hook -up fees established by TDPUD for the purpose of
capital improvements shall be paid. These fees shall -be used
for the purpose of making capital improvements (e.g.,
developing groundwater supply wells, increasing storage
capacity) to serve the project and other projected
development within TDPUD's service area. In accordance with
TDPUD requirements, these fees shall be paid as a condition of
issuance of building permits, and shall be based on the
project's fair share for the cost of such improvements,
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -28 September 2003
2.0 RESPONSE TO COMMENTS
Timing /Implementation: Prior to approval of the first phase of
development. Water hook -up fees shall be paid prior to the
issuance of building permits, and shall be assessed on a per -unit
basis in accordance with TDPUD policy regarding such fees.
Enforcement /Monitoring: Truckee Donner Public Utilities District, and
Truckee Fire Protection District (fire flow requirements).
Commentors also requested information regarding the project's compliance with SB
221. This statute does not apply directly to the CEQA process. Rather, SB 221 requires
the local agency approving a qualified subdivision to adopt a written finding verifying
that adequate water supplies exist for the project. The entitlements requested by the
I • applicant include a tentative subdivision map. In addition, the size of the project is
sufficiently large to require a water supply verification under SB 221. For these reasons,
TDPUD will be requested to issue a water supply verification prior to approval of the
tentative subdivision map for the project.
As noted above, commentors expressed the concern that water supply wells
developed for the project could lower groundwater levels at wells that currently serve
the Prosser Ranch and Pannonia neighborhoods. No groundwater wells serving the
project are planned in or near these neighborhoods. Water supply wells serving Gray's
Crossing will be screened in lower water- bearing sedimentary formations. For example,
the Glenshire Drive well, upon which the project may rely, is drilled to a depth of 900
feet below ground surface. The depth of the well, and its distance from the water
supply wells relied upon by the Prosser Ranch and Pannonia neighborhoods, indicate
that increased groundwater pumping from the Glenshire Drive well will not interfere with
pumping at these neighborhood wells.
One commentor stated the EIR should be revised to include additional analysis based
on a calibrated numeric model as proposed by Acton - Mickelson. The Acton - Mickelson
report was submitted to Placer County as a critique of an earlier study prepared by
Nimbus Engineers entitled Ground Water Availability in the Mortis Valley Ground Water
Basin (Nimbus Engineering 2001). The Nimbus study is cited in the Gray's Crossing Draft
EIR, and was relied upon in the preparation of the Draft EIR's analysis of cumulative
groundwater impacts.
The Acton - Mickelson report was prepared in 2001 at the request of Mountain Area
Preservation Foundation, an environmental advocacy organization based in the Town
of Truckee. The report predates the SB 610 compliance report prepared for Gray's
Crossing. The Acton - Mickelson report criticizes the methodology used in the Nimbus
study, and recommends the use of a calibrated numeric model instead of a water
balance approach. Although Acton - Mickelson recommends the use of such a model,
no modeling is included in this report, and to date no calibrated model of the
!. groundwater basin has been constructed.
• Although no calibrated model has been constructed, a number of studies have been
performed to assess the available yield of groundwater in Mortis Valley. These studies
generally use a water balance approach. Such an approach is recognized as a valid
means of assessing available groundwater yield. In this case, the studies using a water -
Town of Truckee Final Environmental Impact Report
September 2003 2 -29 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS • I
balance approach represent the best available evidence on the available yield of I
groundwater from the Mantis Valley groundwater basin.
Briefly, these studies conclude as follows:
• Nimbus 2001 used a water - balance approach, and concluded the available
yield of groundwater supplies in the basin was approximately 24.7K acre -feet per
year. This yield is sufficient to accommodate all anticipated development in
Martis Valley, including Gray's Crossing.
• Kennedy /Jenks conducted an independent assessment of available data, and
concluded the Nimbus study was a conservative estimate of the available yield
of groundwater in the basin. The study concluded approximately 24,000 acre -
feet /year of groundwater was potentially available for use on a sustainable basis
(Kennedy /Jenks Consultants, Independent Appraisal of Martis Valley Ground
Water Availability - Nevada and Placer Counties, California (December 2002).
• Interflow Hydrology conducted an assessment of the potential impact of
tributary flows on the groundwater budget in the valley, an impact that the
Nimbus and Kennedy /Jenks studies had not considered. Interflow collected
stream flow data and quantified groundwater discharge to streams tributary to
the Truckee River in order to refine the groundwater balance assessment F
prepared by Nimbus and confirmed by Kennedy /Jenks. Based on this
assessment, Interflow concluded an additional 10,320 acre - feet /year of water,
over and above the 24,000 acre - feet /year identified by Kennedy /Jenks, is
available for use. The report concluded: "[T]he total amount of ground water
potentially available for use in Martis Valley on a long -term sustainable basis, in
which equilibrium in the Martis Valley water balance is maintained, exceeds
34,000 of /yr." The report further concludes that the availability of this water
would not be affected by drought cycles because the "total saturated
thickness" of the aquifer is "hundreds of feet" (Interflow Hydrology, Inc.,
Measurement of Ground Water Discharge to Streams Tributary to the Truckee
River in Martis Valley, Placer and Nevada Counties, California (April 2003), p. 4).
• The recommendation to use the analytic approach proposed by Acton - Mickelson is
noted. Under CEQA, an EIR need not use a particular analytic approach in assessing
the impacts of the project. Rather, the EIR must rely upon an approach that is based
upon substantial evidence. The water - balance approach is recognized as a valid
method for. assessing the available yield in the groundwater basin. The California
Department of Water Resources cites the Nimbus study in its most recent description of
the Martis Valley Groundwater Basin. (See Department of Water Resources, Bulletin 118
(April 2003 draft)).
The Acton - Mickelson report was also submitted to Placer County in connection with its
proposal to adopt the Marts Valley Community Plan (see MVCP Final EIR, Comment
135). The County's response to that comment, and to groundwater supply issues 1�
generally, is incorporated by reference (see MVCP Final EIR, Master Response 3.4.4
(copy attached)).
I
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -30 September 2003
2.0 RESPONSE TO COMMENTS
Based on available information, the available yield of groundwater appears to be
adequate to serve both the Gray's Crossing project, and all other foreseeable
development in the Martis Valley groundwater basin. TDPUD has confirmed that
groundwater supplies are adequate even during multiple dry years. Although TDPUD
will have to develop additional groundwater wells in the future in order to serve all
development anticipated in its service area over the course of the next 20 years, TDPUD
has adopted a master plan identifying the improvements that need to be constructed,
and has established requirements for the funding • of these improvements. Gray's
Crossing will contribute its fair share towards the cost of these improvements.
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Town of Truckee Final Environmental Impact Report
1 September 2003 2 -31 Gray's Crossing Specific Plan Project
California Regional Water
v g Quality Control Board
Winston H. Hickox Lahontan RQg100 Gray Davis
Secretary for Y
Environmental 2501 Lake Tahoe Boulevard, South Lake Tahoe, California 96150 Governor
Protection Phone (530) 542 -5400 • FAX (530) 544 -2271 E
Internet: http: / /www.swrcb.ca.gov /rwgcb6 C. / i/
ED
• July 31, 2003 4115 0 4 1003 LETTER 1 .
Philip Crimmins
State Clearinghouse
1400 Tenth Street
Sacramento, CA 95812
COMMENTS ON THE GRAY'S CROSSING SPECIFIC PLAN/ TENTATIVE MAP.
I DRAFT ENVIRONMENTAL IMPACT REPORT, TOWN OF TRUCKEE, NEVADA
• COUNTY (SCH# 2002072115)
I : Lahontan Regional Water Quality Control Board (Regional Board) staff has completed our
review of the above - referenced Draft Environmental Impact Report (DEW) prepared by the
Town of Truckee. This letter presents Regional Board staff comments on the DEW and the
scope and content of water quality issues required to be addressed in the EIR. Regional Board
staff provided comments on the Notice of Preparation document for the Gray's Crossing project
(project) in a letter dated September 16, 2002 (enclosed). Thank you for the opportunity to
I comment.
PROJECT DESCRIPTION
I The project is located in the To of Truckee, immediately north of Interstate 80 and on both the 1
east and west sides of State Route 89 (SR 89). The site includes ponderosa pine on steeper
I slopes in the north and northwest and open meadows in the central and southern portion of the 1 -1
site along SR 89 and Prosser Dam Road. Prosser Creek Reservoir, a water storage /flood control
facility is located approximately 0.5 miles north of the project site. A small, unnamed ephemeral
II • creek crosses the property in a southwest to northeast direction and flows into the reservoir. The
proposed project includes the development of a 757 -acre site as a destination recreation
community with golf, recreational amenities, single - family, cottage, and attached housing, and
I . mixed -use development in a village center setting. The proposed project has the following
specific elements: . •
I Residential Land Uses
• 410 single- family residential lots; •
• 57 cottage lots that allow for cottage units;
• 48' attached housing units; and
•
• • a 92 -unit affordable /employee housing complex (64 affordable and 28 employee units); and
• • a set aside of 9.5 acres to provide future worship centers.
•
California Environmental Protection Agency •
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- Philip Crimmins -2-
'
Village Complex
• 38,900 square feet (sf) of office and retail floor space;
• a 120 -room lodge with 5,000 sf of conference facilities and limited food service;
• a 7,200-sf multi-use building; and
• a 1,800 -sf gas station and convenience store.
Golf Course
• an 18 -hole golf course, practice range, maintenance facility, fitness center, and clubhouse. I
Open Space
The project also includes a set aside of 417.6 acres of open space dispersed throughout the '
project and connected by a series of trails.
Pursuant to the California Environmental Quality Act (CEQA, Public Resources Code 21000 et ,
seq.) the Regional Board is a "responsible agency" with regard to water quality: Staffs general
and specific comments and concerns on water quality issues related to the proposed project
components are provided below.
General Comments
A. Regional Board staff find that the impact analysis is somewhat general and are concerned
about the degree of reliance on permits by other agencies to provide mitigation. CEQA case
law (Sundstrom v. County of Mendocino) provides that a lead agency cannot cite another _2
agency implementing its permitting program as mitigation. To satisfy our concern, the EIR
should include specific mitigation measures for each potentially significant impact that will
achieve compliance with other agencies' standards.
B. Appendix E2 describes the area - specific Water Quality Objectives (WQOs) from the Basin
Plan. In addition to complying with the WQOs, the project must also be protective of the
beneficial uses listed for the area (Sections 2 -15 and 2 -47), and comply with the anti- 1.-3
degradation policy (Section 3 -14). The Basin Plan can be viewed online'or downloaded at
http:// www .swrcb.ca.gov /rwgcb6 /BPlanBPlan Index.htm. The final EIR should cite these
Basin Plan components. ..
C. Numerous sections of the DEIR cite the Regional Board's Truckee River Hydrologic Unit
Project Guidelines for Erosion Control. Please be aware that the Truckee River Hydrologic 1-4
Unit Project Guidelines for Erosion Control have been replaced with the North Lahontan
Region Project Guidelines for Erosion Control (attached).
D. Details provided for the sedimentation basin and temporary drains and swales in Appendix
E3 discuss treating and/or retaining storms other than the 20 -year, 1 -hour storm. As stated
on page 4.6 -27 of the DEIR, the North Lahontan Region Project Guidelines for Erosion 1 -5
Control require that permanent BMPs that treat and/or retain storm water runoff originating
from impervious surfaces be designed to accommodate the runoff generated by the 20 -year
1 -hour storm event (0.7 inches of rain). The final EIR should address this discrepancy. \7
California Environmental Protection Agency
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of simple ways you can reduce demand and cut your energy costs, see our Web -site at http: / /www.swreb.ca.gov
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Philip Crimmins -3-
Temporary BMPs may need to accommodate a storm larger than the 20 -year, 1 -hour in order
to comply with other Basin Plan requirements, such as beneficial use protection, prohibitions,
WQOs, and the anti - degradation policy. This is due to the intense runoff associated with
' thunderstorm activity and rain -on -snow events.. The final FIR should address this situation.
E. Several mitigation measures cite regulatory agencies as the sole mechanisms for monitoring
water quality. As previously stated in Comment 8 of the September 16, 2002 letter, Regional
Board staff strongly suggests that a comprehensive surface water and ground water 1-6
monitoring program be developed and implemented for this project. The final FIR should
include such a monitoring plan to ensure that water quality is adequately monitored, data
distributed, and if necessary, additional mitigation implemented.
F. Appendix E3. describes suggested maintenance for the listed potential BMPs; however, it
does not identify the party or parties responsible for BMP implementation and maintenance. 1 -7
Appendix E3 also does not identify who will be responsible for updating/modifying the BMP
plan, if and when necessary. The final EIR should include this information.
G. Regional Board staff is concerned about potentially significant environmental impacts related
to the timber harvest activities associated with this project that were not identified in the
DEW. The final EIR should, at a minimum, refer to the Timber Harvest Plan (THP) to _8
identify potential impacts and necessary mitigation measures associated with timber harvest
activities for this project. The final EIR should discuss the potential impacts of accessing the
site and of harvesting techniques on soil stability, and cite the mitigation measures intended
to address any potential impacts associated with such activities.
Specific Comments (Impacts and Mitigation Measures have been referenced from the DEIR)
1. Impact 4.5.3 - Implementation of the proposed project could cause increased erosion of soil.
Mitigation Measures (MMs) 4.6.3b and 4.6.3c are proposed to reduce this potentially
' significant impact to a less than significant level. MMs 4.6.3b and 4.6:3c cite compliance
with the State General Construction Activity Storm Water Permit (General Construction
Permit), National Pollutant Discharge Elimination System (NPDES) General Permit for
Limited Threat Discharges to Surface Waters (General Limited Threat Permit), and the Basin
Plan. These MMs also cite reliance on the Town of Truckee's Grading Ordinance, the Storm 1-9
Water Pollution Prevention Plan (SWPPP) that is associated with the General Construction
Permit, and the Regional Board's Truckee River Hydrologic Unit Project Guidelines for
Erosion Control. It is staff's opinion that a lead agency cannot cite another agency
implementing its permitting program as mitigation, as discussed in General Comment A
above. The final EIR should include specific mitigation measures that will achieve
compliance with other agencies' standards.
In addition to reliance on the above - mentioned permits and regulatory guidance, MMs 4.6.3b
and 4.6.3c also cite some water quality controls and refer to Appendix E3 -Best Management
Practices (BMPs) from Lahontan RWQCB Basin Plan, which cite numerous temporary and
I
Calif ornia Environmental Protection Agency
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Philip Crimmins -4-
permanent BMPs in detail. Please be aware that the BMPs provided do not originate from
the Basin Plan. The final EIR should cite the correct origin of the BMPs provided in
Appendix E3. With regard to the BMPs provided in Appendix E3, please refer to the first
and third items in the Comments on Appendix E3 section below. •
Revegetation efforts are described in MM 4.6.3b as applying to all disturbed areas and as ,
being maintained. Regional Board staff suggests that more detail is provided for the
revegetation plan. In general, we require vegetation success criteria that includes interim and
final percent ground coverage, species distribution, and a monitoring plan that extends a
• minimum of five years past the initial revegetation efforts. Regional Board staff is willing to
provide assistance to the Discharger regarding this issue.
2. Impact 4.6.3 - Development and operation of the proposed project may increase surface
runoff from the project, which may contain contaminants that could enter surface waters and
possibly ground water.
This impact is proposed as less than significant before mitigation. Regional Board staff does
not agree with this determination and believe that this impact should be listed as potentially
significant prior to mitigation. Without mitigation, a potential for increased peak flows
1-10
exists. Increased peak flows can result in increased erosion and sediment transport to the
Truckee River. The Truckee River has been placed on the Clean Water Act Section 303(d)
List, which identifies water quality impaired surface waters. The Truckee River has been
identified as being water - quality impaired due to excessive sedimentation. Any increase in
sediment loading to the Truckee River and its tributaries is a significant impact. Therefore,
Regional Board staff recommends that the final EIR note this impact as potentially
significant prior to mitigation. I
MM 4.6.3 (MMs 4.6.3a -c) is proposed for this impact.. MM 4.6.3a relies on Regional Board
regulation (see General Comment A above). See Specific Comment 1 above for discussion 1
of MMs 4.6.3b and 4.6.3c.
3. Impact 4.6.4 - Development of the proposed golf course may adversely affect the existing '
quality of surface waters and ground water in the project area.
MM 4.6.4 is proposed to reduce this potentially significant impact to a less than significant I
level. Although MM 4.6.4.describes the utilization of a computer - controlled irrigation
system to ensure proper application of irrigation water and a comprehensive water quality'
monitoring plan, it does not discuss distribution uniformity, which is discussed in the 1- 1 1
Regional Board's Chemical Application and Management Plan (CHAMP) guidance
(provided as an enclosure to the September 16, 2002 letter). Distribution uniformity is a
. critical element associated with an irrigation system. Increasing the distribution uniformity
and/or maintaining high distribution uniformity can prevent over - irrigation. Excessive
irrigation can push fertilizers and other golf course chemicals down into the ground water or
result in surface runoff. Both conditions increase pollutant loading to water resources. The
final DR should discuss how distribution uniformity will be monitored and what goals will
be set for distribution uniformity.
California Environmental Protection Agency
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of simple ways you can reduce demand and cut your energy costs, see our Web -site at http: / /www.swrcb.ca.gov
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Philip Crimmins -5-
' The DEIR indicates that a CHAMP will be developed in the future. However, in order to
better assess if water quality will be adequately protected, the final EIR should include the
CHAMP referred to in MM 4.6.4.
'- 4. Impact 4.6.5 - Construction activities associated with implementation of the proposed project
may have an adverse impact on water quality due to sedimentation and the potential •
introduction of hazardous materials. 1 -12
MM 4.6.3 (MMs 4.6.3a -c) is proposed to reduce this potentially significant impact to a less
• . than significant level. Please refer to Specific Comment 1.and General Comment A above
for 'a discussion of MMs 4.6.3 a -c.
5. Impact 4.6.6 - The proposed project would rely primarily upon ground watei as a source of
water supply, potentially impacting the quantity of ground water resources in the basin.
' The DEW identifies this impact as less than significant prior to mitigation based upon
conclusions reached in a 2001 ground water availability report prepared by Nimbus
Engineers entitled Ground Water Availability in the Martis Valley Ground Water Basin,
• Nevada and Placer Counties, CA. The report notes the presence of a "clay member" that
separates the upper aquifer from the middle /lower aquifer and restricts transfer of ground
• water and interaction between the aquifers. Page 4.6 -25 of the DEW states that "Nimbus
' studied the Basin's hydrogeology.on a regional scale to allow simplification of subsurface 1 -13
characteristics, which would allow evaluations that could be based upon assumptions the •
aquifer is isotropic and homogeneous." Have field studies been conducted to confirm the
. presence of the clay member at the project site? Regional Board staff is concerned that such
studies may not have been conducted. The Nimbus study encompasses a broad area and the
site conditions preventing aquifer interaction may not exist at the Gray's Crossing site or
location where ground water will be extracted. If an interaction between the upper and
middle /lower aquifer exists in the local area, surface water impacts could exist and could be
significant. The final EIR should provide information indicating that the Nimbus study
conditions mentioned above exist at the project site or where ground water will be extracted
to demonstrate that surface water resources will not be affected.
I . Does the Truckee River rely on water from the middle /lower aquifer? The final EIR should
provide additional information on this issue.
•
6. Impact 4.6.9 - During winter, sand and substances used to de -ice roadways may enter stream
. channels and surface waters and potentially affect water quality.
MM 4.6.9b is proposed to reduce this potentially significant impact to a less than significant 1 -14
level. MM 4.6.9b describes the acceptable snow melt treatment facilities as retention basins,
retention galleries and mechanical facilities (each designed using Best Available Technology
or Best Control Technology) to be used prior to release to overland or concentrated flow.
These treatment techniques will probably effectively remove suspended and settleable solids
from snow storage areas; however, the above - referenced treatment methods do not typically \
California Environmental Protection Agency
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of simple ways you can reduce demand and cut your energy costs, see our Web -site at http: / /www.swrcb.ca.gov
Op Op Recycled Paper
Philip Crimmins -6
reduce dissolved solids concentrations, and increases in dissolved solids loading can '
adversely impact downstream beneficial uses such as "rare, threatened, and endangered
species." Regional Board staff is concerned about potential increases in dissolved solids
concentrations in the Truckee River and its tributaries that may result from using the
proposed de- icers. The final EIR should either provide a discussion on alternative de -icers
that may have a reduced environmental impact on beneficial uses or further assess the
anticipated increase in total dissolved solids loading to surface waters and the potential
impact associated with the increased loading.
7. Impact 4.6.10 - Development of the Gray's Crossing project, in combination with other.
development within the region would result in increased demand for water supply, which
may result in increased ground water and surface water usage. 1 -15
This impact is proposed as less than significant before mitigation. Please "refer to comments '
provided in Specific Comment 5 above:
8. Impact 4.6.11 - Development of the proposed project in combination with other development '
within the region would result in increased peak flows in Prosser Creek and the Truckee
River, which would alter flood conditions.
1 -16 '
MMs 4.6.3a, 4.6.3b, and 4.6.7 are proposed to reduce this potentially significant impact to a
less than significant level. Please refer to Specific Comment 1 above for discussion of MMs
4.6.3a and 4.6.3b. In order to better assess if water quality will be adequately protected, the '
final EIR should include the Master Drainage Plan referred to in MM 4.6.7.
9. Impact 4.6.12 - Construction and operational activities associated with the Gray's Crossing. '
project would contribute to cumulative surface water quality impacts to urea waterways.
MMs 4.6.3a, 4.6.3b, 4.6.4, 4.6.7, 4.6.9a, and 4.6.9b are proposed to reduce this potentially I
significant impact to a less than significant level. Please refer to Specific Comment 1 above 1 -17
. for discussion of MMs 4.6.3a and 4.6.3b and Specific Comment 5 above. Specific Comment '
6 above provides a discussion on considering alternative de -icers or providing analysis on the
anticipated total dissolved solids loading on surface waters. As stated in Specific Comment 8
above, the final EIR should include the Master Drainage Plan in order to determine the I
adequacy of MM 4.6.7.
Comments on Appendix E3 (potential BMPs)
•
• Regional Board staff is concerned about the potential for the internal and external slopes of
the sedimentation basin (listed on page 5 -90) to erode and become a source of sediment. The 1 -18 ,
sedimentation basin detail does not describe how the slopes of the sedimentation basin will
be stabilized (e.g. coconut matting, vegetation, etc.). The final EIR should.address this '
concern. '
California Environmental Protection Agency I
The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list '
of simple ways you can reduce demand and cut your energy costs, see our Web -site at http: / /www.swrcb.ca.gov
V' 1 Recycled Paper
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Philip Crimmins -7-
1
• Page 4 -81 describes the Storm Channel /Creek Maintenance BMP and includes a statement
I about modifying channel characteristics to enhance pollutant removal and/or hydraulic
capacity. Prohibition 4(c) on Page 4.1 =5 of the Basin Plan (as cited in Appendix El) will
apply to channels /drainages determined to be waters of the state. The Basin Plan also 1-1 9
contains exemption criteria to the 100 -year flood plain prohibition. A summary of
I . prohibitions and exemption criteria for the Truckee River Hydrologic Unit is enclosed. The
final EIR should include information demonstrating how implementation of this BMP will
. satisfy the exemption criteria. This also applies to other aspects of the project (roads,
utilities, trails, etc.) that impact/discharge wastes to the 100 -year flood plain of any surface
• water at the project site.
' • Appendix E3 does not include some potential BMPs that may be necessary to control
sediment erosion and transport on the site (e.g. gravel bag check dams, coconut matting,
I stockpile covering, fiber rolls, etc.). Although some may be identified in other areas of the 1-20 •
DEIR, a comprehensive list of BMPs should,be made available. The final ER should
include a list of all BMPs discussed in the EIR and provide ata minimum, the same level of
' detail that is currently provided in Appendix E3.
We appreciate the opportunity to comment on water quality issues related to the proposed
project. If you have any questions or would like to discuss any of these comments in more •
detail, please contact Robin Mahoney, Water Resource Control Engineer, at (530) 542 -5417, or
me at (530) 542 -5432.
I Sincerely,
•
' e
Scott C. Ferguson, hief
' Truckee River Watershed Unit
' Enclosure: September 16; 2002 comment letter
North Lahontan Region Project Guidelines for Erosion Control
Waste Discharge Prohibitions and Exemption Criteria for Projects within the
' Truckee River Hydrologic Unit
cc: Nevada County Department of Environmental Health, Janet Mann
Town of Truckee, Heidi Scoble (w/ enclosures)
Department of Fish and Game, Region 2
U.S. Army Corps of Engineers, Matt Kelly
I Pacific Municipal Consultants (w/ enclosures) . •
East West Partners (w/ enclosures)
RFM /cgT: Gray's Crossing DEIR -
[Pending/NV County /Gray's Crossing] •
California Environmental Protection Agency •
' The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list
of simple ways you can reduce demand and cut your energy costs, see our Web -site at http: / /www.swrcb.ca.gov
IV, Recycled Paper
,F/4
•
California Regional Water Quality Control Board ` .:2'
L Region
Vi .S e v rciron ry r al for fick overnor Gray Davis
E n -
Enmen(a! . 2501 Lake Tahoe Boulevard, South Lake Tahoe, Tah, California 96150 -
Protection Phone (530) 542 -5400 • FAX (530) 544 -2271
Internet: httpi /www.swrcb.ca.gov /rwgcb6
Septeiflber 16, 2002 •
Tony Lashbrook, Director.
• Community Development Department
• Town of Truckee '
10183 Truckee Airport Road
Truckee, CA 96161
• CALIFORNIA ENVIRONMENTAL QUALITY ACT REVIEW ON THE NOTICE OF
PREPARATION FOR GRAY'S CROSSING — SPECIFIC PLAN AND TENTATIVE MAP
DRAFT ENVIRONMENTAL IMPACT REPORT, TOWN OF TRUCKEE, TRUCKEE,
NEVADA COUNTY (SCH# 2002072115)
The staff of the California Regional Water Quality Control Board, Lahontan Region (Regional
Board) has received the Notice of Preparation for the Gray's Crossing Draft Environmental
Impact Report (NOP) prepared pursuant to the California Environmental Quality Act (CEQA).
Thank you for the opportunity to comment upon the early consultation document for the
proposed Gray's Crossing Project. Staff apologizes for submitting these comments past the due
date set by the State Clearinghouse.. Regional Board staff understands that the proposed project
is a modification of a previously proposed project, Planned Community2 (Boca Sierra Estates or
PC2), that was not constructed.
Gray's Crossing — PC2 Comparison '
The Gray's Crossing Project is proposed to be constructed in the same location as the previously
proposed PC2 Project, along both sides of Highway 89 immediately north of Interstate 80. In
comparison to the PC2 project, the Gray's Crossing Project consists of:
• 32 fewer acres total land area (752 acres total), •
. • . 17 fewer single family homes (410 total),
• 100. fewer attached residential structures (73 total),
• 30 more employee housing units (630 total),
• 0.5 more acres for a residential church site (8. acres total), •
• • four acres for a clubhouse (not previously proposed), ,
•
• . five fewer acres of golf course (120 acres total),
• nine acres for a golf driving range (not previously proposed),
• 30 fewer recreation lodgings (120 total),
• 117,000 fewer square feet for office/retail (48,000 square feet total),
California Environmental Protection Agency ,
The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list .
- - of simple ways you can reduce demand and cut your energy costs, see our Web-site at http: / /www.swrc0.n.gov
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Tony Lashbrook - 2 -
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• two fewer Village Center Lofts (23 total),
• 0.5 fewer acres for a Village Center church site (1 acre total),
• total removal of 13.5 acres for a Commercial Triangle,
• total removal of 25 acres for a public highway right -of way,
' • total removal of 37.7 acres for a public school and recreation site,
• 22 more acres for zoned open space (347 acres total), and
• • the same 50% lot coverage in residential zone.
Since the project involves similar components of a similar magnitude in the same location,
' Regional Board staff finds that the potential water quality impacts from the two projects would
be similar. Regional Board staff provided comments on the Notice of Preparation for the Boca
Sierra Estates Draft Environmental Impact Report and the Draft Programmatic Environmental
Impact Report in letters dated February 3, 1999 and June 15, 2000,. respectively (enclosed).
1. Regional Board staff comments in the enclosed letters still need to be addressed in the draft
environmental impact report (DEW). In addition to the comments provided in the February 3,
' 1999 and June 15, 2000 letters, Regional Board staff has the following additional continents.
Specific Comments
1. The requirement to acquire a National Pollution Discharge Elimination System (NPDES)
Construction Storm Water permit for projects involving five acres or more of land
' disturbance will change to one acre or more of land disturbance, beginning in March 2003.
2. The project will need to include appropriate best management practices (BMPs) that at a
' minimum prevent storm water runoff from impervious surfaces generated by the 20 -year 1-
hour storm event (0.7 inches of rain) from discharging to surface waters. The use of such
BMPs is intended to avoid adverse impacts to surface water hydrology (increasing peak
' flows, increasing flow velocities, etc.), which generally lead to adverse water quality impacts
(increased channel instability, bank erosion, increasing pollutant concentrations, etc.). Such
BMPs may include, but not be limited to, infiltration trenches, infiltration galleries,
' infiltration basins or other methods to retain the storm water runoff. Information regarding
the potential volume of storm water runoff from impervious surfaces generated by the 20-
year, 1 -hour storm should be included in the DEIR. At a minimum, the DEIR should include
' a commitment to disposing of storm water runoff from impervious surfaces in a manner that
does not adversely impact surface water hydrology. The DEW should also identify probable
methods for achieving this objective.
' In addition to managing the storm water runoff volume generated by the above - referenced
I storm, it is equally important to ensure that the storm water is adequately treated prior to
disposal:. Storm water runoff contains sediment, petroleum products, other vehicular fluids,
metals, nutrients from fertilizers and other sources, pesticides, and potentially deicing
products. The DEW should identify probable source- control measures and treatment
' measures that will be implemented to prevent, storm water pollution from adversely
impacting both ground and surface water quality.
California Environmental Protection Agency
The energy challenge facing California is real. Every Californian needs to lake immediate action to reduce energy consumption. For a list
of simple ways you can reduce demand and cut your energy costs, see our Web-site at http: / /www.swrcb.ca.gov
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Tony Lashbrook - 3 -
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It is imperative that the BMPs to be implemented are adequately maintained for the life of the
project. This includes the construction and post - construction periods: The DEIR should
include a temporary and permanent BMP maintenance plan and identify who will be
responsible for ensuring its implementation, and when necessary updating/modifying the
plan.
3. The information provided does not indicate potential locations of snow storage. Snow
removed from areas associated with industrial developments often contains sediments, oils;
greases, petroleum products, and other constituents that would normally be collected and •
treated through various best management practices. The land area located downgradient '
from the project will be the site of an extensive wetland mitigation project that must be •
provided protection from adverse water quality impacts equal to all surface waters within the
Truckee River Hydrologic Unit. The DEW should discuss probably methods that will be
employed to protect both surface and ground water quality from pollutants associated with
snow removal and disposal activities. The DEW should also discuss proposed deicing
methods for road and parking areas, deicing material storage and handling areas, and '
associated BMPs.
4. The Truckee River has been placed on the Clean Water Act Section 303(d) List, which '
identifies water quality impaired surface waters. The Truckee River has been identified as
• being water - quality impaired due to excessive sedimentation. Any increase in sediment
loading to the Truckee River and its tributaries is a significant impact. This includes
wetlands and ephemeral drainages located within the watershed. Efforts must be made to
adequately identify and protect all perennial and ephemeral/intermittent surface waters and
other surface waters (rivers, streams, drainage swales, wetlands, springs, etc.) within and
immediately adjacent to the project site. A wetland delineation study should be conducted to
identify any wetland areas on the property, and a program to protect wetlands and other
surface waters from disturbance during and after construction should be developed as part of
the DEW. The applicant may wish to construct fences at locations where there is easy access
to the wetlands and other surface waters and erect signs to educate the community on the
importance of protecting natural resources.
•
5. The project proponent should contact the U.S. Army Corps of Engineers (Army Corps)
regarding any proposal to disturb surface waters, including any wetlands and floodplain
areas. It may be necessary to obtain a Clean Water Act Section 404 permit from the Army
Corps, which may then require the project proponent to obtain Clean Water Act Section401
Water Quality Certification from the Regional Board.
6. The tentative map in the NOP shows residential parcels and fairways that encroach on
wetlands and surface water drainages. The Regional Board's Basin Plan contains
prohibitions regarding the discharge of waste to surface waters of the Truckee River
Hydrologic Unit, and the discharge and threatened discharge of wastes to 100 -year flood
plains of the Truckee River and its tributaries. The Basin Plan also contains exemption
criteria as discussed in staff's June 15, 2000 letter; however, new home s ite construction and
California Environmental Protection Agency
The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list
of simple ways you can reduce demand and cut your energy costs, see our Web -site at http://www.swrcb.ca.gov
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Tony Lashbrook - 4 - • •
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golf course development (fairways, greens, tees, parking areas, etc.) do not satisfy the
exemption criteria. F more details regarding the Regional Board's Basin Plan prohibitions,
• p lease refer to sta or f s F ebruary 3, 1999 an d June 1 5, 2000 letters.
•
. It is important that the DEW identifies all of the prohibition areas related to surface waters
and 100 -year flood plain areas as discussed in staff's June 15, 2000 letter. It is equally .
important the DEIR demonstrate compliance with the prohibitions or demonstrate how a_y
proposed disturbance within the prohibition areas satisfies the exemption criteria specified
' in the Basin Plan. This applies to, but is.not limited to, proposed disturbance associated with
transportation, utility, residential, commercial, industrial, and recreation - related development
activities. .
•
' 7. Staffs June 15, 2000 letter includes a discussion of potential golf course impacts. In
addition to the requests made in that letter regarding golf course impacts, the DEW should
also identify what criteria the Town of Truckee and Nevada County intend to use in assessing
' the Chemical Application Management Plan (CHAMP). It is also imperative that the DEIR
discuss how the golf course design and landscaping in conjunction with the CHAMP and
Irrigation Management Plan will maintain compliance with water quality standards specified
I in the Basin Plan and consider alternatives that limit landscaped areas and preserve natural
vegetation. Guidelines for Development of the Chemical and Irrigation Management Plan
are enclosed. •
•
8. Given the potential for adverse water quality impacts, the sensitive nature of the Truckee
River and its tributaries, and anticipated reliance upon BMPs for pollutant source - control and
t treatment, Regional Board staff strongly suggests that a comprehensive surface water and .
ground water monitoring program be developed and implemented for this project. The
i monitoring program should include pre - development monitoring.
' 9. Since greater areas of disturbance generally result in greater sediment loading to nearby
surface waters, Regional Board staff encourage you to consider reduced coverage rates (i.e.
30% coverage as a maximum for all residential development instead of 50 %) or other
alternatives that limit total coverage (cluster development, building envelopes closer to roads,
etc.). .
I . Summary
' Regional Board staff find that additional environmental documentation is required for the Gray's
Crossing Project due to the number and significance of the issues identified above and in staffs
February 3, 1999 and June 15, 2000 letters. The Gray's Crossing DEW should address the
issues identified above and in the above - referenced letters.
1 .
t • California Environmental Protection Agency
The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list
of simple ways you can reduce demand and cut your energy costs, see our Web -site at http: / /www.swrcb.ca.gov
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Tony Lashbrook 5 -
Regional Board staff looks forward to working with you and your staff on this project. If you ,
have any questions or comments regarding issues related to this matter, please contact Robin
Mahoney at (530) 542 -5417 or me at (530) 542 -5432.
Sincerely,
Scott r son Chief
Northern Watersheds Unit
Enclosures: Regional Board staff letter dated February 3, 1999.
Regional Board staff letter dated June 15, 2000
Truckee River Hydrologic Unit Project Guidelines for Erosion Control
Guidelines for Development of the Chemical and Irrigation Management Plan
cc: Regional Board Members I
Nevada County Environmental Health Department/Janet Mann
Nevada County Planning Department
Placer County. Environmental Health Department/Brad Banner
Placer County Planning Department/Fred Yeager
California Department of Fish and Game/Ron Perrault
California Department of Fish and Game/Region 2 I
Tahoe Truckee Sanitation Agency /Craig Woods
Truckee Sanitary District/Ossian Butterfield '
U.S. Army Corps of Engineers, Sacramento District/Matt Kelly
California Department of Transportation, District 3 /Jeff Pizzi
REM/cgT: Gray's Crossing NOP -DEIR
California Environmental Protection Agency ,
The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list
of simple ways you can reduce demand and cut your energy costs, see onr Web-site at http7 /wwwswrcb.a.gov
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• CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
LAHONTAN REGION
WASTE DISCHARGE PROHIBITIONS
i • • AND' •
• EXCEPTION CRITERIA •
I FOR PROJECTS WITHIN THE TRUCKEE RIVER HYDROLOGIC UNIT •
: The Water Quality Control Plan for the Lahontan Region (Basin Plan) prohibits the discharge or
1 threatened discharge, attributable to human activities, of solid or liquid waste' materials
. (including, but not limited to, soil, silt, clay, sand and other organic and earthen materials). to
. lands within the 100 -year floodplain of.the•Truckee River or within the 100 -year floodplain of
I any tributary 2 to the Truckee River. The Regional Board may grant exceptions to the prohibition
for repair or replacement of existing structures provided that a loss of additional floodplain area
or volume does not occur, and Best Management Practices and mitigation measures are used to
I minimize any potential soil erosion and/or surface runoff problems.
The Regional Board may also grant exceptions to the prohibition for the following types of new
1 . • ' projects: .
•
' (1) Projects solely intended to reduce or mitigate existing sources of erosion or water
pollution, or to restore the functional value to previously disturbed floodplain areas.
•
1 (2) Bridge abutments, approaches, or other essential transportation facilities identified in an
approved county general plan.
I (3) Projects necessary to protect public health or safety, or to provide essential public
. services. •
r (4) Projects necessary for public recreation.
•
(5) Projects that will provide outdoor public recreation within portions of the 100 -year flood
plain that have been substantially altered by grading and/or filling activities which
1 •
•occurred prior to June 26, 1975.
•
• . Waste includes earthen material placed in a water body or carried to waters by erosive forces. Construction
. . activity involving ground disturbance within 100 -year floodplain areas is generally considered to constitute a
:threat of discharge: .
•
' z • Tributaries include: perennial surface waters (rivers. streams, lakes, wetlands) and ephemeral (seasonal)
• ' watercourses exhibiting evidence of the occurrence of flowing water, and having the potential to transport water
and/or sediment to another water body, including, but not limited to, named and unnamed streams, wetlands, and •
•
• lakes.
1 •
1 • . •
Discharge Prohibitions -2- Exemption Criteria • I
The Basin Plan allows an exception to the prohibitions for new projects only when the Regional
Board makes all of the following findings:
• The project is included in one or more of the five categories listed above.
• There is rio reasonable alternative to locating the project or portions of the project within '
. the 100 -year flood plain.
• • The project, by its very nature, must be located within the 100 -year flood plain. (The •
I
determination of whether a project, b very nature, must be located in a 100 -year flood
plain shall not apply to projects in category (5), above, and shall be based on type of I
project proposed, not the particular site proposed.) .
• The project incorporates measures which will ensure that any erosion and surface runoff •
I problems caused by the project are mitigated to levels of insignificance.
• • The project will not individually or cumulatively with other projects, directly or '
indirectly, degrade water quality or impair beneficial uses of water.
The project will not reduce the flood flow attenuation capacity, the surface flow treatment ,
capacity, or the ground water flow treatment capacity from existing conditions. All
• 100 -year flood plain areas and volumes lost as a result of the project must be completely
mitigated by restoration of previously- disturbed floodplain within or as close as practical ,
to the project site. The restored, new, or enlarged floodplain shall be of sufficient area
and volume to more than compensate for the flood flow attenuation capacity, surface flow
treatment capacity and ground water flow treatment capacity which are lost as a result of • '
the project. .
•
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3 This finding will not be required for new projects necessary to protect public health and safety. For new projects . .
necessary to provide essential public services, this finding will not be required when the Regional Board finds .
mitigation measures to be infeasible because the financial resources of the project proponent are severely limited.
T:forms Prohib.doc (AEM 1 /I 1/d0) '
•
' NORTH LAIIONTAN REGION
PROJECT GUIDELINES FOR EROSION CONTROL
I In the interest of protecting surface water quality from unnatural or accelerated erosion caused by
land development, the following guidelines shall be followed:
I Temporary Construction BMPs
1. Surplus or waste materials shall not be placed in drainage ways or within the 100 -year flood
I plain of surface waters.
I 2. All loose piles of soil, silt, clay, sand, debris, or earthen materials shall be protected in a
reasonable manner to prevent discharge of pollutants to waters of the State. Material stockpiles
should be placed on the upgradient side of excavation whenever possible. Stockpiles may also be
I. protected by covering to prevent contact with precipitation and by placing sediment barriers around
the stockpiles. .
3. Dewatering shall be done in a manner so as to prevent the discharge of pollutants, including
earthen materials, from the site. The first option is to discharge dewatering waste to land. A
separate permit may be required if due to site constraints, dewatering waste must be discharged to
surface waters. Contact the Regional Board for information on discharging to surface waters.
4. All disturbed areas shall be stabilized by appropriate erosion and/or sediment control measures
' by October 15 of each year.
5. All work performed between October 15th and May 1st of each year shall be conducted in such
' a manner that the project can ' be winterized within 48 hours. Winterized means implementing
erosion and/or sediment controls that will prevent the discharge of earthen materials from the site
and the controls will remain effective throughout the rainy /snow season without requiring
' maintenance. In general, . this requires stabilizing bare disturbed soils with mulch, erosion
protection blankets, or other suitable materials, and installing perimeter sediment controls such as
' fiber logs or other similar materials that will remain effective during significant rain and snow
events.
I 6. After completion of a construction project, all surplus or waste earthen material shall be
removed from the site and deposited at a legal point of disposal.
I 7. All non - construction, areas (areas outside of the construction zone that will remain undisturbed)
shall be protected by fencing or other means to prevent unnecessary encroachment outside the
active construction zone. .
8. During construction, temporary erosion control facilities (e.g., impermeable dikes, filter fences,
hay bales, etc.) shall be used as necessary to prevent discharge of earthen materials from the site
I during periods of precipitation or runoff.
9. Control of run-on water from offsite areas shall be managed (protected, diverted, treated, etc.)
' to prevent such water from degrading before it discharges from the site.
10. Where construction activities involve the crossing and/or alteration of a stream channel, such
1 activities require a prior written agreement with the California Department of Fish and Game and
shall be timed whenever possible to occur during the period in which streamflow is expected to be
lowest for the year. Other control measures may be used as necessary to prevent adverse effects
from work in surface waters.
2.0 RESPONSE TO COMMENTS
LETTER 1 SCOTT C. FERGUSON, CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD,
' LAHONTAN REGION
' Response to Comment 1 -1
The commentor summarizes the project description and notes that the California
Regional Water Quality Control Board is a "responsible" agency with regard to water
quality, per CEQA, Public Resources Code 2100 et seq. Since the comment does not
address the adequacy of the Draft EIR, no further response is required. The comment is
' noted and presented here for the consideration of the Town Council.
Response to Comment 1 -2
The commentor expresses concern with the impacts analysis and the degree of
reliance on permits by other agencies to provide mitigation. The commentor requests
' specific mitigation measures for each potentially significant impact that will achieve
compliance with other agencies' standards.
The commentor is referred to Section 4.6 (Hydrology and Water Quality) of the Draft EIR
for a discussion of the Regulatory Framework governing the project and providing
specific mitigation measures for those impacts deemed potentially significant.
' . Specifically, Section 4.6 identifies that the proposed project must comply with the water
quality standards of the Town of Truckee, Lahontan RWQCB and other applicable State
and Federal laws such as the Clean Water Act. In addition, the applicant has provided
a series of BMPs to be utilized during both construction and operation of the project,
which will be provided to the Lahontan RWQCB for its • consideration as part of the
SWPPP process.
Further, the commentor is referred to the Master Response 2.4.3 Water Quality,
regarding the Town's ability to rely on performance standards and subsequent agency
• approvals to find that potentially significant impacts will be reduced to less than
significant levels. Implementation of proposed Specific Plan policies and
implementation programs identified in Section 4.6 (Hydrology and Water Quality) of the
Draft EIR and Mitigation Measures 4.6.3 through 4.6.9 would require construction and
operational features of the proposed project to provide sufficient water quality control
measures to ensure "no net positive increase in flow" and "no net increase in peak off-
site flows from design storm event" consistent with Lahontan RWQCB policy, and no
increase in turbidity, sediment or other pollutant loads in natural waterways as a
performance standard. In addition to these mitigation measures, Specific Plan policies
' and implementation programs described above require use of BMPs (e.g., chemical
management application plan, detention/ retention basins, snow storage areas, etc.).
The use of performance standard mitigation is allowed under CEQA Guidelines Section
15126.4(a) and is supported by case law.
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -32 September 2003
2.0 RESPONSE TO COMMENTS '
Response to Comment 1 -3
The commentor wants to ensure that the proposed project is protective of beneficial
uses listed for the area and that it complies with the Regional Board's anti - degradation
policy. Table 2 -1 (see Appendix D) from the Lahontan Basin Plan lists the Beneficial Uses
of Surface Waters of the Lahontan Region. The Hydrological Unit (HU) number is 635.20.
The drainage feature, which traverses the project site, is a tributary to Prosser Reservoir.
The beneficial uses listed for Prosser Reservoir are Municipal and Domestic Supply
(MUN), Agricultural Supply (AGR), Ground Water Recharge (GWR), Navigation (NAV),
Water Contact Recreation (REC -1), Non - contact Water Recreation (REC -2),
Commercial and Sport Fishing (COMM), Cold Fresh Water Habitat (COLD), Wild Life
Habitat (WILD), Rare, Threatened, or Endangered Species (RARE), and Spawning,
Reproduction, and Development (SPWN). As the on -site tributary is seasonal some of
the beneficial uses for Prosser Reservoir do not directly apply.
•
Table 2 -2 (also in Appendix D) from the Lahontan Basin Plan lists the beneficial uses for '
ground waters of the Lahontan Region. Plate A2 (referred to in Table 2 -2) indicates that
the proposed project falls within DWR Basin Number 6 -67 and that the ground water
basin name is Mortis Valley. A small portion of the northeast corner of the project area
falls into this basin. The beneficial uses listed are Municipal and Domestic Supply (MUN),
Agricultural Supply (AGR), and Freshwater Replenishment (FRSH).
The project applicant proposes to protect applicable beneficial uses during the
construction and long -term operation of the proposed project. Methods proposed for
protecting beneficial uses include, but are not limited to, the following:
a) Surface runoff shall not be diverted to another basin. All runoff shall follow the
natural grade of the existing ground to the extent possible. Roadway drainage
and culverts shall be directed toward the tributaries where the natural drainage
flowed.
b) Surface runoff entering the tributary shall be protected from silt and surface
contaminates. The surface runoff shall be directed to the natural drainage
channel, but must first be retained and filtered. The retained volume is based on
the 20 -year, 1 -hour storm event. This equates to 0.7 inches of surface runoff of all
the impervious areas. The most critical time to retain the runoff is during the initial
storm event. This is the time when the road oils, sands and silts tend to be the
greatest. The theory is to design the Best Management Practices (BMPs) to
accept this initial runoff and not overflow into the natural drainage courses. The 111 time between storms allows silts and oils to settle out through filtration and
evaporation. Maintenance of these BMPs should occur shortly after the initial
storm event where significant runoff has occurred. Several methods are
acceptable to the Regional Board such as retention basins, retention galleries
and building drip -line infiltrators. Other methods may be developed and
submitted to the Lahontan Regional Staff for approval at the time the Storm
Water Pollution Prevention Plan (SWPPP) is reviewed and approved.
1
Town of Truckee Final Environmental Impact Report
September 2003 2 -33 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
c) BMPs shall have a means of discharging the surface runoff back into the ground.
Such methods include but are not limited to natural bottoms in retention basins,
' weep holes in culverts used for retention galleries, and rock, pervious filter fabric,
or natural lined channels.
' New methods of protecting surface waters are continuously being developed. It is not
the intent of the Draft EIR, or the above listed BMPs, to limit the possible methods used
for protecting the beneficial uses listed above. It is the intent of the project applicant to
follow the anti - degradation objective policy listed in Chapter 3 (Water Quality Control
Plan) of the Lahontan Basin Plan.
' Response to Comment 1 -4
The commentor explains that the Regional Board Truckee River Hydrologic Unit Project
Guidelines for Erosion Control have been replaced with the North Lahontan Region
Project Guidelines for Erosion Control. The following portion of the Draft EIR has been
amended and the North Lahontan Region Project Guidelines for Erosion Control have
been attached as Appendix E, and are intended by reference to replace the Truckee
River Hydrologic Unit Project Guidelines for Erosion Control found in Appendix E3 of the
Draft EIR.
' Pages 4.6 -18 through 4.6 -19 of the Draft EIR are amended to read:
' MM 4.6.3b In compliance with the requirements of the State General
Construction Activity Storm Water Permit as well as the Water
Quality Control Plan for the Lahontan Region (Basin Plan), the
applicant shall prepare a Stormwater Pollution Prevention Plan
(SWPPP) which describes the site, erosion and sediment controls,
means of waste disposal, implementation of approved local plans,
' control of post- construction sediment and erosion control measures
and maintenance responsibilities, and non -storm water
management controls. This plan shall cover the entire Gray's
' Crossing Specific Plan site. The SWPPP shall also be submitted to
Town of Truckee Department of Public Works and the Lahontan
Regional Water Quality Control Board for review and approval.
' The applicant shall require all construction contractors to retain a
copy of the approved SWPPP on each construction site. Water
quality controls shall be consistent with the Town's Grading
Ordinance and the Lahontan Regional Water Quality Control
Board's Truckcc Rivcr Hydrologic Unit North Lahontan Region
Project Guidelines for Erosion Control and will demonstrate that the
' water quality controls will ensure no increase in turbidity, sediment
or other pollutant loads in Prosser Creek and the Truckee River and
that storm water discharges are in compliance with all current
requirements of the Lahontan Regional Water Quality Control
Board. Water quality controls may include, but are not limited to,
the following:
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -34 September 2003
2.0 RESPONSE TO COMMENTS
• Prohibit placement of surplus or waste materials within the 100- 1
year floodplain of onsite intermittent drainages.
• Stabilize all disturbed areas by October 15th of each year. I
• Install temporary gravel dikes, earthen dikes or sand bag dikes
to prevent the discharge of pollutants.
• Install infiltration trenches or other protection facilities.
• Revegetate disturbed areas and maintain vegetation.
• Compliance with Lahontan Regional Water Quality Control
Board NPDES No. CAG996001 (National Pollutant Discharge
Elimination System General Permit for Limited Threat Discharges
to Surface Waters) for construction dewatering activities.
Timing /Implementation: Prior to Improvement Plan approval.
Enforcement /Monitoring: Town of Truckee Public Works, Lahontan
Regional Water Quality Control Board.
MM 4.6.3c During the long -term operational phase of the project, a '
permanent erosion and water quality control plan consisting of
BMPs (attached as Appendix E3 in the technical appendices) shall
be built into the infrastructure of the project's improvements and
operational activities. It shall conform to requirements of the
Lahontan RWQCB and the Truckee Development Code.
Timing /Implementation: Prior to issuance of a grading permit.
Enforcement /Monitoring: Lahontan Regional Water Quality Control
Board, Town of Truckee Community Development
Department /Planning Division.
Implementation of the above mitigation measures will ensure that water quality controls ,
shall be consistent with Lahontan RWQCB's North Lahontan Region guidelines for erosion
control and will demonstrate that the water quality controls will ensure no increase in
turbidity, sediment or other pollutant loads in Prosser Creek and the Truckee River and
that storm water discharges are in compliance with all current requirements of the
Lahontan RWQCB. Impacts after implementation of this mitigation will be less than
significant. .
Response to Comment 1 -5
The commentor points out a discrepancy in the retention levels discussed for the storm
water BMPs listed in Appendix E3 and the requirements of the North Lahontan Region
Project Guidelines for Erosion Control. The BMPs listed in Appendix E3 in the Draft EIR
state that they should be sized to various storm events, or other appropriate design
storms specified by the local agency.. In this case, the appropriate design storm for a
retention basin is the 20 -year, 1 -hour storm. It is prudent to design other facilities with
greater capacities to help ensure protection of beneficial uses. The overflow spillway of
a retention pond or detention pond should be designed to handle a much greater
Town of Truckee Final Environmental Impact Report
September 2003 2 -35 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
volume of water. Typically, a spillway would be designed to handle, at a minimum, a
100 -year, 24 -hour storm and sometimes up to a 1000 -year, 24 -hour storm event. Swales
and other applicable BMPs shall be designed to handle the 10 -year, 24 -hour storm
event. Current Town of Truckee Code requires drainage facilities to be designed to the
10 -year, 24 -hour storm event with no overtopping. The size of the BMP is critical if it is
' intended to function through the winter season. The design storm used to size erosion
control facilities ultimately should be left up to the project engineer's judgment but in
no case shall be less than the 10 -year, 24 -hour storm event. BMP designs and
I capacities shall be listed in the Final Drainage Report. The Drainage Report shall be
included in. the SWPPP for verification by the Regional Board for compliance to sizing.
Attached as Appendix B is a copy of a Preliminary Drainage Plan. Per MM 4.6.7, the
' Lahontan Regional Board, Caltrans, and the Town of Truckee will have the opportunity
to review and approve the final drainage plan (including engineered drainage
calculations based on the final project design) to ensure that it meets their standards.
r As required by MM 4.6.7 detention basins shall be sized to a 20 -year, 1 -hour storm event
prior to the implementation of construction, and consistent with the standards and
' guidelines established by the RWQCB (Draft EIR page 4.6 -28). The engineer's
preliminary drainage plan shows the location and details of the retention facilities. The
plans will be reviewed by the appropriate agencies for conformance to their standards
' and requirements. If the RWQCB deems that temporary BMPs are required to
accommodate a storm larger than the 20 -year, 1 -hour event, then those BMPs shall be
made part of the Master Drainage Plan approval. The RWQCB may require additional
' temporary BMPs as part of its review and approval of the plan per MM 4.6.7.
Response.to Comment 1 -6
' The commentor requests that a comprehensive surface and ground water quality
monitoring program be developed as part of the proposed project. Attached as
' Appendix A, is a copy of the Audubon International Institute's Draft Natural Resource
Management Plan (NRMP) for the Gray's Crossing project - a mitigation requirement of
the Draft EIR. A Final NRMP will be developed and available for review and input by the
' Regional Board. The Regional Board will receive a copy of the NRMP for its review and
input as the applicant has chosen to incorporate the requirements of the CHAMP
required by MM 4.6.4 in the Draft EIR into the NRMP in order to have a comprehensive
' single- source management plan for the Gray's Crossing project. , Per MM 4.6.4, a
project specific CHAMP, or similar management plan, is required to be reviewed and
approved by the Lahontan Regional Water Quality Control Board, Nevada County,
and Town of Truckee. Further, per the mitigation measure, if the CHAMP, or similar
program, does not meet the Town's, County's, or Regional Board's requirements, those
agencies may require changes and re- submittal of the CHAMP - or as is the case now,
the NRMP. Specific to water quality monitoring, the commentor is asked to review in
particular pages 7 -10 through 7 -27 of the Draft NRMP. This section, entitled
Environmental Monitoring Program, spells out a detailed and comprehensive water
' quality program that will require monitoring and sampling of surface water, wetland
sediments, and ground water at several locations and at multiple times of the year for
constituents of concern. The Regional Board will have an opportunity to provide further
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -36 September 2003
• 2.O RESPONSE TO COMMENTS
input into the acceptability of this water quality monitoring program when a Final NRMP '
is provided to them as required by MM 4.6.4 (discussed above).
Additional water quality monitoring proposed by the project applicant is related to ,
determining the success of the project's proposed construction and permanent BMPs.
The applicant has provided the following information (indented and in italics below)
related to monitoring BMPs to address concerns raised by the commentor. By the
applicant's provision of this information and by providing this within this Final DR, the
applicant is responsible for the implementation of the following BMP monitoring
protocols:
A water quality monitoring program and reporting system shall be
implemented to assure Regional Board Water Quality Objectives are met.
Monitoring of the Gray's Crossing project will consist of two (2) separate
areas of concern. The first is the monitoring of all activities related to onsite
construction as approved in the improvement plans. The second monitoring
is related to the long -term effectiveness of the permanent BMPs. Each will
require a monitoring program and reporting system. The monitoring and
inspection shall be done by a person who has been trained and is
knowledgeable in the application of BMPs. At a minimum, the individual
shall have met the training requirements as listed in the training section of the
Gray's Crossing SWPPP.
Monitoring Programs and Reports for Construction Activities ,
Monitoring shall be done 24 hours prior to anticipated storm runoff and
immediately on 24 -hour intervals during a storm and within 24 hours following
storm events, including snowfall which has the potential to melt and
generate runoff. The applicant, or its designated representative, will inspect
all soil stabilization measures, temporary sediment barriers, storm water
conveyance facilities, detention ponds, and infiltration trenches. Using visual
observation, the inspector will evaluate whether these measures are
adequate and properly implemented. A logbook will be kept at the site in •
the main construction trailer and subsequently in the maintenance
headquarters of the project. Inspection reports will be recorded in the
logbook and will include dates, time, weather conditions, name of inspector,
and the observations made. If deficiencies in the BMPs are identified, the
applicant and contractor shall be notified so that corrective measures can
be taken. The inspection reports along with a written record of any
improvements /repairs made after each rainstorm must be kept at the
construction site for Regional Board staff review. The report shall be similar to
Exhibit 1 BMP /SWPPP Inspection Checklist (see Appendix F).
Water quality monitoring is required during storm events. Water quality •
monitoring shall include collection of water samples to determine if
sediments and nutrients are leaving the site.
Town of Truckee Final Environmental Impact Report
September 2003 2 -37 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
Sample Collection
One sample shall be collected downstream and one sample collected
upstream of the project site prior to a storm event. Additional samples shall
be taken during the intervals indicated above. Samples shall be collected in
a clean quart jar. Each consecutive sample shall be collected in the same
' location to ensure consistency between test samples.
Each sample shall be sealed at the sampling site. Each jar shall be
permanently marked with the date, location and time the sample was
collected. The sample shall be inspected by the person collecting the
sample. The upstream sample shall be compared visually to the downstream
' sample for color and clarity. Indication of any chemicals shall also be noted
on the report form. A summary of differences between the two samples shall
be noted in a summary column.
' After visual inspection, the samples shall be sent to a water quality lab
• certified by the State of California for water quality testing. The samples shall
be tested for sedimentation content and nutrients. The lab reports shall be
kept onsite. Monitoring of construction activities and BMPs shall be
continuous until the date that the Notice of Termination (NOT) is approved
by the Lahontan RWQCB.
Monitoring Programs /Reports for Long Term Water Quality Assurance
Mitigation
The long term monitoring program shall be similar to the Construction Activity
Monitoring Program with the exception that the long term program will
monitor the permanent BMPs effectiveness for a period of five years after the
Notice of Termination (NOT) of the National Pollutant Discharge Elimination
System (NPDES) permit for construction has been issued by RWQCB.
' Any floodplain or wetland monitoring shall be carried out by a field biologist
competent in identifying the wetland and upland plant species of the
' project vicinity and familiar with basic principles of channel fluvial
morphology. A suitable (but not exclusive) source of names of qualified firms
and individuals is the Nevada County list of pre - qualified biological
consultants.
Timing and Reporting
' A monitoring report will be submitted to the Regional Board by September 1
of each monitoring year (thus allowing time for possible completion of
remedial actions if needed). An addendum to the report will be provided in
' the case that any remedial follow -up occurs after September 1 (for example,
seeding or other revegetation which is most useful if delayed until October or
November).
Each annual monitoring report shall include the following elements:
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -38 September 2003
2.0 RESPONSE TO COMMENTS
• Statement of success criteria and methods used including dates of '
observation and contact information for the monitor;
• Summary of data collected; I
• Photographs;
• Evaluation of attainment of criteria and recommended remedial
actions, if any;
• Recommendations for modification of methods or criteria, if applicable.
Response to Comment 1 -7
The commentor requests additional information related to which parties will be
responsible for implementation and maintenance of the BMP program. As discussed in
Impact 4.6.3 in the Draft EIR on pages 4.6 -16 through 4.6 -19, the Lahontan RWQCB's
General Permit process requires the project applicant to prepare and implement a
Storm Water Pollution Prevention Plan (SWPPP) and to monitor the effectiveness of the
plan. As part of the SWPPP, temporary BMP maintenance requirements are required of
the project applicant. The applicant is responsible for verifying that proper methods are
being implemented according to the approved SWPPP. Each BMP listed in the SWPPP
must address proper maintenance of that BMP (i.e., a stabilized construction entrance
shall be inspected monthly and after each rainfall and gravel shall be placed where
voids are visible). Maintenance of permanent BMPs under the applicant's ownership
shall be in accordance with the NPDES permit or the Waste Discharge Requirement
(WDR) permit for that system. In general, inspections shall occur prior to and
immediately after each significant storm event. Cleaning and maintenance shall be as
needed to ensure proper operation of each BMP. Once yearly, prior to the wet season,
each facility shall be inspected and a report generated outlining the condition of the
BMP. The BMP shall be maintained to a maximum level of effectiveness. The report
shall be forwarded to the Regional Board requesting the report. This information is
contained in the Draft EIR in Impact 4.6.3.
Further, BMPs shall be monitored as described in Response to Comment 1 -6 and
maintained by a licensed contractor who has had at least one year of BMP 111 maintenance experience. According to the general language found in an NPDES
permit, the applicant for a project has ultimate responsibility for implementing the
requirements of an approved SWPPP. The owner is responsible for maintaining,
updating, and /or modifying any BMPs. The applicant may designate a responsible
. party for maintaining the BMP plan. Such designee shall have experience in preparing
an approved SWPPP. Because some BMPs may require engineering to adequately size
the BMP, it is recommended that a licensed civil engineer, experienced in hydrology
analysis and open channel flow, be selected for maintaining the BMP plan.
See also the Master Response 2.4.3 Water Quality. I
Response to Comment 1 -8
1
A Timber Harvest Plan has been submitted to the California Department of Forestry and
Fire Protection (CDF) for the proposed project by the project applicant (see Appendix
Town of Truckee Final Environmental Impact Report
September 2003 2 -39 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
G). The THP has been received by CDF and given a permit number — No. 2-03-117-NEV.
The THP references significant portions of the Draft EIR as mitigation measures for the
THP.
Generally, CDF oversees enforcement of California's forest practice regulations. Under
the Forest Practice Act, THPs are submitted to CDF for commercial timber harvesting on
all non - federal timberlands. The plans are reviewed for compliance with the Forest
Practice Act and rules adopted by the State Board of Forestry and Fire Protection as
well as other state and federal laws that protect watersheds and wildlife. CDF has
jurisdiction over all timber and forest lands, regardless of whether the land is zoned as a
Timberland Production Zone (TPZ). The project area is not zoned TPZ nor is it designated
i as a forestland use in the Town of Truckee General Plan. Therefore, impacts associated
with the conversion from timberland to urban development were considered less than
significant (see Draft EIR pages 4.1 -32 to 33). Below is general overview of the THP
Review Process.
When a THP is submitted to CDF the following occurs within 10 days:
• It is assigned a number.
• Copies are distributed to all state and federal reviewing agencies.
' • A Notice of Intent is sent to landowners within 300 feet of the THP, the office of
the county clerk within the THP county, and the local CDF unit headquarters.
' • A Notice of Submission is sent to anyone who has requested in writing,
notification when a THP is submitted to CDF.
• A first review of the THP is done by a multi- agency team that includes CDF, the
California Department of Fish and Game, the California Regional Water Quality
Control Board, the California Division of Mines and Geology, and other agencies
as needed. This first review is meant to assess whether the THP conforms to the
' State Board of Forestry and Fire Protection rules. Any incomplete applications are
returned to the Registered Professional Forester (RPF) who prepared the THP. The
RPF must answer any questions or concerns raised by the review team before the
THP is processed any further.
• Once all review team concerns are clarified and the THP is deemed complete, it
' is officially "filed ". A Notice of Filing is sent to the person who submitted the THP,
the office of the County Clerk, and to anyone who has requested in writing,
notification of filed THPs.
r Additionally, the public may submit to CDF written comments concerning a filed THP.
These written submissions will be accepted by CDF up until the designated final date for
' public comment. CDF responds in writing to each written public comment received.
Within 10 days of the Notice of Filing the review team conducts a Pre - Harvest Inspection
(PHI) to examine the proposed logging site.
Within 20 days of the PHI, a second meeting is held by the review team to discuss the
Pre- Harvest Inspection reports and to finalize any recommendations or changes
' needed for the THP.
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -40 September2003
2.0 RESPONSE TO COMMENTS ,
30 days after the PHI, the public comment period ends. Frequently, however, the public
comment period is extended for such reasons as allowing time for all agencies involved
in the THP process to complete their reviews, and the need for additional study on a
specific THP issue.
•
Following the Review Team's final recommendation, the final recommendations are
sent to the Registered Professional Forester for response. After the RPF's response is
received and the public comment period closes, the THP goes to the CDF Director, or
her representative, who has 15 days to approve or deny the THP. The Director considers
all Board of Forestry and Fire Protection rules, the review team's recommendations, and
any public comment that was submitted concerning the proposed timber operation
before making a decision to approve or deny the THP. CDF prepares and mails a
written response to each person or group who submits public comment on a THP.
•
Once a THP is approved, CDF will periodically inspect the logging operation to ensure
compliance with the approved THP and all laws and regulations. When a THP
operation has been completed, the timber owner has the responsibility for submitting a
completion report to CDF. CDF then inspects the area to certify that all rules were
followed.
Response to Comment 1 -9 ,
As discussed in a previous comment, the commentor is concerned about relying on the
permitting process of other agencies as mitigation. Please see Response to Comment
1 -2 and Master Response 2.4.3 Water Quality. The mitigation measures contained in the
Draft EIR, and including Mitigation Measures 4.6.3b and 4.6.3c, are adequate under
CEQA. In addition to requiring no increase in turbidity, sediment or other pollutant loads
in Prosser Creek and the Truckee River, Mitigation Measures 4.5.3, 4.6.3 and 4.6.7 require
that water quality controls and storm water discharges be in compliance with all
current requirements of the RWQCB. The Draft and Final EIR propose a number of BMPs
and water quality control features that may potentially satisfy RWQCB requirements.
Still, ultimate determination of the project's consistency with RWQCB guidelines and
regulations reside with the RWQCB acting as a responsible agency, rather than the Final
EIR.
•
With regard to the origin of the BMPs cited in Appendix E3 of the Draft EIR, these BMPs
originated from the California Storm Water Best Management Practice Handbooks
prepared for the Storm Water Quality Task Force of California. These handbooks have
been in wide use since 1993. Per the commentor's cross - reference to comments found
later in the comment letter, please see Response to Comments 1 -18 and 1 -20.
•
Further, MMs 4.6.3b and 4.6.3c in the Draft EIR do mention specific methods for water 111 quality control. Appendix E3 in the Draft EIR Technical Appendices shows examples of
the BMPs to be implemented during and after construction. In addition to the water
quality controls listed in the Draft DR and Technical Appendices, the following
information has been provided by the project applicant (indented and in italics below)
to address concerns raised by the commentor. By the applicant's provision of this
1.
Town of Truckee Final Environmental Impact Report
September 2003 2 -41 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
information and by providing this within this Final EIR, the applicant is responsible for the
implementation of the following protocols:
Retention basins designed to retain the surface runoff from impervious areas
for the 20 -year, 1 -hour storm shall be constructed at various strategic
locations. A 20 -year, 1 -hour storm multiplied over an area equates to a
volume of water and not a peak flow. The purpose of utilizing the 20- year,, l-
hour precipitation depth (0.7 ") assures the retention basin is of adequate size
' to retain the initial storms that hit the Sierra in the early fall when oils and
sands are washed off roads and other impervious surfaces. The runoff is
retained and has the opportunity to be filtered, evaporated and /or settled
' out in the basin. The runoff from subsequent storms is considered to be
cleaner.
The retention basin locations typically will be near the lower end
(hydraulically speaking) of the development. This may include several
locations adjacent to the tributaries. It is the intent of the retention basins to
settle and filter out the initial storm contaminates such as silts and road oils.
These basins, if designed to accept much larger flows associated with major
drainage improvements, shall be designed so that the spillway will handle
the 100 -year, 24 -hour storm event with a freeboard of one (1) foot. If the
basin is designed to return the flow to sheet flow, the basin shall be designed
so that the spillway and banks are all in cut. The entire length of the spillway
' shall be protected from erosion by filter fabric and or rock slope protection.
Other retention facilities should be used when retention basins cannot be
utilized. Drip line retention trenches are a means of retaining the runoff from
the roofs of buildings. The attached Roof Drip Line Trench Calculation
(attached as Appendix H), was developed by SCO Planning and
Engineering, Inc. and illustrates the width and depth of a retention trench
needed in relation to the roof area.
Re- Vegetation Plan for the Proposed Project
Upon completion of the site grading and earthwork, the following
permanent erosion control measure will be implemented by the project
applicant. ESC10 (Seeding and Planting), ESC II (Mulching), and ESC40
(Outlet Protection), ESC42 (Slope Roughening /Terracing), ESC54 (Storm Drain
Inlet Protection) and ESC56 (Sediment Basins) shall be listed in the interim
1 measures in the SWPPP but will also become permanent BMP measures (see
Appendix I for details regarding these BMPs).
' Along with the above measures and prior to October 15, seed, fertilizer and
mulch shall be applied to all disturbed soils and all exposed cut and fill
• slopes' not protected by rock. Application shall be in the following rates
(unless specified otherwise by the Nevada County Resource Conservation
District):
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -42 September 2003
2.0 RESPONSE TO COMMENTS
Seed Mix: Berber Orchard Grass (Dactylis glomerata) 15 lbs/AC •
Zorro Fescue (Vulpia myorus) 3 lbs/AC
Rose Clover (Trifolium hirtum) 9 lbs/AC
Crimson Clover (Trifolium incarnatum) 4 lbs/AC
Fertilizer: Ammonium Phosphate (16 -20 -0) 300 lbs/AC '
•
Mulch: Straw (Hand or machine placed) 2 tons /AC ( slopes> l0 %)
1 ton /AC (slopes < =10 %) •
Slopes with glazed or smooth surfaces shall be scarified to a depth of 2 -4 inches to provide
an adequate seed bed.
2 All legumes need to be inoculated with the appropriate inoculate prior to seeding.
3 Seed and fertilizer shall be applied using broadcast or hydroseed method. If hydroseeded,
seed rates shall be increased by 25 %.
Germination of all species within the seed mix is necessary. The Resource I
Conservation District or a field biologist who is able to identify the different
species of plants and grasses shall provide a field review in November of the
first year to identify proper sprouting. The second field review shall be in mid -
spring to identify the success rate of germination of all the species. Areas
that do not germinate or are sparsely germinated shall be re- seeded and
mulched the following season. These areas shall be monitored each spring
for five (5) years or until the Lahontan RWQCB is satisfied that the soil has
been successfully stabilized. It will be necessary to keep temporary
sedimentation control facilities in place in areas that have not been
successfully germinated until such a time that all species have germinated
and soil is suitably stabilized.
The Town and the project applicant welcome any comments Lahontan Regional
Board staff might have on the proposed re- vegetation plan. I
Response to Comment 1 -10
• The commentor believes that Impact 4.6.3 found on page 4.6 -16 of the Draft EIR should '
have a conclusion of "potentially significant prior to mitigation." We agree with the
commentor and changes to the Draft EIR text have been made below. See also
Response to Comment 1 -2 regarding reliance on the Regional Board's regulations for
. mitigation.
Pages 4.6 -16 through 4.6 -17 of the Draft EIR are amended to read: i
Surface Runoff and Ground Water Contaminants from Urban Uses
Impact 4.6.3 Development and operation of the proposed project may
increase surface runoff from the project, which may contain
contaminants that could enter surface waters and possibly ground
water. [kSPSMj
•
Town of Truckee Final Environmental Impact Report
September 2003 2 -43 Gray's Crossing Specific Plan Project
1 2.0 RESPONSE TO COMMENTS
I Contaminants in runoff from residential and commercial areas are likely to
consist primarily of motor vehicle fluids such as fuels, oil and radiator coolant.
Also typically found in urban runoff are trace metals such as copper, lead, zinc,
cadmium, chromium, arsenic and nickel. Landscaping may contribute fertilizers,
pesticides and herbicides and other potential contaminants, which may include
I nutrients, organic compounds and sediments. The potential for pollution is
typically highest during late summer and fall when pollutants are bound to
particulates in the sediments and then released during the first large rainfall
I event of the season. Since pollutants are typically concentrated in the
environment after the long dry season, increased levels of contaminants is most
likely during the first flush event because the dilution factor is relatively low.
Increased levels of contaminants in surface runoff has the potential to exceed
I
water quality standards and can detrimentally affect aquatic and wildlife
resources.
I The Gray's Crossing project is within the North Lahontan Basin, specifically the
Truckee River Hydrological Unit (TRHU). The TRHU has several prohibitions for
- -I discharge. Chapter 4.1 (Waste Discharge Prohibition) of the Basin Plan describes
the many prohibitions for all the different basins (attached as Appendix El ). The
prohibitions that apply to the TRHU are listed in Figure 4.1 -1 and pertain to areas
S as indicated in Figures 4.1 -7 and 4.1 -8 in the Water Quality Control Plan for the
Lahontan Region (these figures are also attached as part of Appendix El ).
I The Gray's Crossing project would be subject to the Water Quality Standards
described in Chapter 3 (Water Quality Objectives) of the Basin Plan for the TRHU.
Figure 3 -5 from this section of the Basin Plan is entitled Water Quality Objectives
I for Certain Water Bodies and the specific water quality objectives are listed in
Table 3 -11 (attached together as Appendix E2). In particular, Objectives 3
applies to the proposed Gray's Crossing project. Minimal surface waters from
I the project site may reach the Truckee River between Objective Locations 4 and
3, but the majority of site runoff flows to a tributary that feeds Prosser Creek,
which flows into the Truckee River at Objective Location 3. Chapter 2 (Present
I and Potential Beneficial Uses) of the Basin Plan describes several beneficial uses
of the Truckee River, including agricultural supply, aquaculture, preservation of
. biological habitats of special significance, cold freshwater habitat, ground water
I recharge, in addition to others.
. Prior to construction of a project greater than one acre, the Regional Water
I Quality Control Board (RWQCB) currently requires the owner to file for a National
Pollution Discharge Elimination System (NPDES) General Permit. The Lahontan
RWQCB's General Permit process requires the project applicant to 1) notify the
I State, 2) prepare and implement a Storm Water Pollution Prevention Plan
( SWPPP), and 3) to monitor the effectiveness of the plan.
•
I The RWQCB Storm Water Quality Task Force has prepared Best Management
Practice (BMP) Handbooks for Construction Activities, Commercial /Industrial
Facilities, and Municipalities. Each BMP listed in the handbooks has an outline for •
I maintenance requirements of the BMP. As part of the SWPPP, temporary BMP
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -44 September2003
2.0 RESPONSE TO COMMENTS I
maintenance requirements are required of the project applicant. The applicant '
is responsible for verifying that proper methods are being implemented
according to the approved SWPPP. Each BMP listed in the SWPPP must address 111 proper maintenance of that BMP (i.e., a stabilized construction entrance shall be
inspected monthly and after each rainfall and gravel shall be placed where
voids are visible). I
When a BMP evolves from a temporary to a permanent BMP, such as sediment
basins, they are initially to be maintained by the applicant until such a time that
the Town accepts the roads and drainage facilities into their system. At that time
the maintenance of certain sediment basins may become the responsibility of
the Town. In this instance, a signed agreement shall be provided to the RWQCB
notifying them of the responsible party for that structure.
Maintenance of BMPs under the jurisdiction of the Town shall be maintained
according to the Town's approved NPDES permit. Maintenance of permanent
BMPs under the applicant's ownership shall be in accordance with the NPDES
permit or the Waste Discharge Requirement (WDR) permit for that system. In
general, inspections shall occur prior to and immediately after each significant
storm event. Cleaning and maintenance shall be as needed to ensure proper
operation of each BMP. Once yearly, prior to the wet season, each facility shall
be inspected and a report generated outlining the condition of the BMP. The
BMP shall be maintained to a maximum level of effectiveness. The report shall
be forwarded to the Regional Board requesting the report.
A recent study provides evidence that well - planned development within the
Martis Valley, along with implementing the Lahontan RWQCB's BMPs, can
effectively protect water quality. The study completed by Huffman & Carpenter
Inc. (2003), entitled Cumulative Water Quality Analyses Report for Lahontan
Development 1996 - 2002, assessed the effectiveness of the Lahontan I •
development project design, including the use of RWQCB BMPs and discharge
restrictions, on meeting Lahontan RWQCB Basin Plan water quality objectives.
Water quality data collected between 1996 and 2002 were analyzed to assess •
whether there were project - related impacts to Mortis Creek. Through a six -year
monitoring . program, Huffman & Carpenter concluded that water quality
objectives set by the Lahontan RWQCB for Mortis Creek at its confluence with
the Truckee River (downstream of the proposed project) were being met, and
that based on the analysis, the golf course and project does not appear to
adversely impact water quality in Martis Creek.
Regardless of the above discussion, Ppotential impacts to water quality as a
result of the proposed project are considered potentially significant and subject
to mitigation. would be mitigatod to a loss than significant loyal through The
project will be subject to the BMP design elements of the
NPDES permit process, which is required as part of standard Town of Truckee
conditions of approval. Reger-dless. To ensure contaminated surface runoff from
the proposed project does not enter surface and ground waters and to ensure
applicant adherence to the NPDES regulatory framework and to onsurc
Town of Truckee Final Environmental Impact Report
September 2003 2 -45 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
adherence —to Lahontan RWQCB water quality standards, the following
mitigation measures are recommended.
' Response to Comment 1 -11
The commentor requests additional information on MM 4.6.4 and how the proposed
CHAMP will monitor distribution uniformity of the irrigation system, and what goals will be
set. Attached as Appendix A, is a copy of the Audubon International Institute's Draft
Natural Resource Management Plan (NRMP) for the Gray's Crossing project - a
mitigation requirement of the Draft EIR. A Final NRMP will be developed,and available
for review and input by the Regional Board. The Regional Board will receive a copy of
the NRMP for its review and input as the applicant has chosen to incorporate the
requirements of the CHAMP required by MM 4.6.4 in the Draft EIR into the NRMP in order
to have a comprehensive single- source management plan for the Gray's Crossing
project. Per MM 4.6.4, a project specific CHAMP, or similar management plan, is
required to be reviewed and approved by the Lahontan Regional Water Quality
Control Board, Nevada County, and Town of Truckee. Further, per the mitigation
measure, if the CHAMP, or similar program, does not meet the Town's, County's, or
Regional Board's requirements, those agencies may require changes and re- submittal
of the. CHAMP - or as is the case now, the NRMP. Specific to the question of how the
project will monitor distribution uniformity of the irrigation system, the commentor is
referred to Sections 4.0 (Best Management Practices), 6.0 (Water Conservation
Management), and 7.0 Water Quality Management of the Draft NRMP. The Regional
Board will have an opportunity to provide further input into the acceptability of the
NRMP, in particular as it relates to meeting the goals of a CHAMP and monitoring
distribution uniformity of the golf course irrigation system when a Final NRMP is provided
•
to them as required by MM 4.6.4 (discussed above).
Water quality will be adequately protected through implementation of the NRMP and
as documented by other similarly situated projects, including the Lahontan community
development project discussed in Impact 4.6.4 of the Draft EIR and Master Response
2.4.3 Water Quality. See also Response to Comment 5 -3.
Response to Comment 1 -12
Regarding the commentor's opinion that MM 4.6.3a through 4.6.3c are insufficient to
reduce Impact 4.6.5 (potential for construction activities to effect water quality) to a
less than significant level, see Master Response 2.4.3 Water Quality and 2.4.6
Construction Impacts and Responses to Comments 1 -2 and 1 -9.
Response to Comment 1 -13
The commentor requests additional information pertaining to surface and groundwater
supplies and specifically whether or not field studies have been prepared to verify the
presence of a clay member separating the upper and lower aquifers. Please see
I • Master Response 2.4.7 Water Supply.
I
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -46 September 2003
•
2.O RESPONSE TO COMMENTS I
Response to Comment 1 -14
The commentor expresses concern that use of the proposed deicers (MM 4.6.9b) could
result in an increase in dissolved solids concentrations in the Truckee River and its
tributaries, and requests additional discussion regarding alternative de- icers. MM 4.6.3a
through 4.6.3c (requiring a permanent erosion and water quality control plan), and
4.6.7 (Master Drainage Plan) ensure that these impacts will remain less than significant
(Draft EIR page 4.6 -31). As required by MM 4.6.9b, Best Available Technology (BTC) or
Best Control Technology (BCT) will be used in determining acceptable retention basins,
galleries or other facilities to stockpile snow. The Town of Truckee Department of Public
Works will enforce this mitigation measure and ensure that the facilities are regularly
maintained to ensure their effectiveness in containing sediments (Draft EIR pages 4.6 -30
to -31).
The project, after construction of the roads, will initially be maintained by the owner.
Chemical de -icing will not be allowed. Once the Town takes over the roads and starts
to provide maintenance, depending on their maintenance procedures, chemical de-
icing may be used. It should be required that only certain de -icers be used. I
As additional information, the following is a synopsis of de -icers and other alternatives
prepared by Susan H. Barrott, Horticulture Technician at the University of Minnesota. I
Chemical de -icers will help remove ice, but can also cause damage to the surrounding
environment. Over application of chemical de -icers can shorten the life span of
concrete surfaces, corrode metal railings, pollute streams and lakes through run -off
water, damage soils and stunt or kill plants adjacent to de -iced areas. Manual snow -
removal followed by the application of an abrasive such as damp sand to create
traction can keep sidewalks safe without the problems associated with de- icers. Using
de -icers wisely, or replacing them with manual removal and abrasives, can minimize
the potential for damage while keeping steps and sidewalks safe. I
Most de -icing chemicals are technically "salts" that work by lowering the freezing point
of water below 32° F. Salts can damage plants in two ways: I
First, by direct contact with snowmelt containing de -icers or in salt spray from roadways.
Repeated shoveling or blowing snow that contains de -icers onto nearby landscape
plants will increase the likelihood of contact injury. Direct contact can cause bud
death and twig dieback resulting in the growth of twig clusters known as "witches'
brooms ". Evergreens exposed to salts can show symptoms as early as February or
March, including needle flecking, yellowing or browning, and twig dieback.
Second, by repeated yearly applications the resulting build - in adjacent soil may
damage plant roots so they are unable . to take up water. Plants symptoms include
wilting even when soils are moist, an abnormal blue -green cast in the foliage, marginal
leaf burn or.needle tip -burn, and general stunting or lack of vigor. Over time, some clay
soils may have their structure changed by extremely high salt levels and become
unable to support plant life. Well- drained soils can be watered heavily to leach some
1
Town of Truckee Final Environmental Impact Report
September2003 2 -47 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
of the excess salts out, but this will not work with fine - textured clay soils or soils with
inadequate drainage.
De -icing chemicals vary in their effectiveness as de -icers and their potential for
damage.
' De -icer Information
Common chemicals Lowest effective Damage to Soil Water Damage to ,
for de -icing temperature plants damage pollutant concrete /metals
I Common salt +15 °F I High High Yes Yes
Calcium chloride -20 °F Medium Medium Yes Yes •
Calcium. magnesium +15 °F Low, Low . No . No
acetate ... .
j Urea +15°F Medium - Low Yes Yes
i
Calcium chloride is the chemical most effective at extreme low temperatures. It is also
less likely to cause corrosion or plant damage when applied correctly. Avoid using rock
salt whenever possible. Urea, (lawn fertilizer), can burn plants and lawns if too much is
applied. Urea is also likely to cause pollution in run -off waters during the spring melt.
De -icers should not be used simply to melt snow or ice. They should be used as an aid
to mechanical removal. All de -icers need to be used after shoveling and sweeping has
removed as much snow and ice as possible and after the threat of additional snowfall
has ended. The de -icer will melt down to the surface and allow manual removal of the
final layer of snow or ice. De -icers should be mixed with an abrasive such as sand or
1 kitty litter so that the amount of chemical used can be reduced and the abrasive can
provide traction. Spread the mix evenly and clean up any clumps or spills. Avoid
shoveling snow that contains de -icers directly onto plants. Whenever possible, remove
snow and ice manually and then spread an abrasive.
Advance landscape planning can minimize plant damage from de- icers. Landscape
' plants differ in their tolerance to salt exposure; some are highly sensitive while others are
more tolerant. When planning new landscapes, or redesigning existing ones, use
relatively salt tolerant plant species in areas adjacent to de -icing locations.
-' s , • "Sensitive,, ;1 More Tolerant ,
Finus` strobus ` Eastern White Pine ,_ , Gleditsia>thacanth Honeylocust ''- ry
Taxus spp Yew Juniperus chinensis
Thou occidentals" Amencan Arborvitae ; •
}, PfitzerJuniper
Berbens- thunbergii Japanese Barbeny, Ribes alpinum • Alpine Currant'
Cornus spp° Dogwood ' Philadelphus spp. Mock Orange:' a ;?
Spirea spp . Splrea Potentilla fruticosa : Bush Cinquefoil
I Rhododendron spp Rhododendron7Azalea Symphoricarpos ;;` Common Snowberry
Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -48 September 2003
2.0 RESPONSE TO COMMENTS
Make sure areas receiving snow and de -icer have good drainage so a thorough r
watering in the spring can help flush the excess salts. Plant tolerance is increased if the
soil is rich in organic matter. Soils can be amended with organic matter such as
compost or peat moss. Incorporating Gypsum into the soil may also help offset some of
the negative effects of de -icing salts. Incorporate 10 to 20 pounds of gypsum per
hundred square feet prior to planting in salt exposure areas:
Well- maintained landscape plants that are properly pruned, fertilized and watered will
be better equipped to withstand the stresses associated with exposure to de -icing
chemicals, but your goal should be to minimize or eliminate the use of these chemicals.
Currently the Town of Truckee does not use chemical de -icers including salts. However,
if and when the decision is made to use de- icers, the Town may choose to use a de -icer
similar to calcium magnesium acetate. This de -icer has the least potential for water
pollution and plant damage compared to other de -icers on the market today. I
Response to Comment 1 -15
The commentor believes that the Draft EIR should not have concluded that cumulative r
development in the Martis Valley region will have a less than significant impact on
surface water and ground water resources. Please see Master Response 2.4.7 Water
Supply.
Response to Comment 1 -16
The commentor questions the Draft EIR's finding that MMs 4.6.3a through 4.6.3b and MM
4.6.7 will reduce the potentially significant cumulative impacts resulting from the
increase in peak flows to Prosser Creek and the Truckee River to less than significant
levels. The commentor is referred to Master Response 2.4.2 Cumulative Impacts and
Response to Comment 1 -2.
In addition, in the Truckee area, golf course developments attenuate the post -
development peak flow to the pre - development peak flow levels because of the 111 nature of the golf course. This is achieved because the natural ground cover has a
larger runoff coefficient than the grass used on the course. This lower runoff coefficient
of the grass means the water travels slower and more is absorbed as it passes through
the course. In some cases the increase in runoff from impervious areas are more than
offset by the lower coefficient of the grass. In these instances, the project shall design
detention basins to attenuate the difference in peak flow. By attenuating the post-
development flows, upsizing of existing drainage facilities are not required and water
quality is maintained.
A preliminary drainage plan indicating the proposed locations and approximate sizes
of retention and detention facilities has been developed and is included in this
document. Please see Appendix B for a copy of a Preliminary Drainage Plan. Per MM
4.6.7, the Lahontan Regional Board, Caltrans, and the Town of Truckee will have the
opportunity to review and approve the final drainage plan (including engineered
Town of Truckee Final Environmental Impact Report
September 2003 2 -49 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
drainage calculations based on the final project design) to ensure that it meets their
standards.
! Response to Comment 1 -17
' The commentor raises the same concerns raised in earlier comments. See Responses to
Comments 1 -2, 1 -6, 1 -9, and 1 -16.
Response to Comment 1 -18
The commentor is concerned about the potential for the internal and external slopes of
the sediment basins (described on page 5 -90 of Appendix E3) to erode and become a
source of sediment. Slopes of all permanent water quality retention and detention
basins shall be protected from erosion by the details and methods described in the final
N improvement plans. These methods shall include items such as seeding, mulching, rock
slope protection, and slope stabilization fabrics. It is the intent of the basins to collect
sediment and attenuate flows.
In the case of a retention basin or sediment control basin the velocity of the runoff is
slowed enough to settle out silt and sand particles. These basins require maintenance
' on an annual or semiannual basis. Therefore, the bottom and the interior slopes will be
cleaned of all sediment buildup. It is an exercise in futility to try and establish plant
growth in these areas. The exterior of the basins shall be protected by means as listed
above.
In the case of a detention basin, maintenance is typically on a five (5).year plan. Plant
growth can be established during the non - maintained years and through selective
cleaning; establishment of addition aquatic plants can be achieved during the
maintenance year.
Temporary sedimentation basins shall be design to collect sediment from the project
site during construction. These basins are considered short term and shall be removed
once permanent erosion control facilities have been established and /or when their
usefulness is no longer effective. The interior and exterior slopes of the temporary basins
shall be stabilized by compaction methods and then the loose overburden removed.
Any erosion from the exterior slopes shall be prevented by mulching, silt fences, and /or
fiber rolls.
Response to Comment 1 -19
The commentor requests additional information as to how implementation of the storm
channel /creek maintenance BMP will . satisfy the Basin Plan's exemption criteria
pertaining to the 100 -year flood plain prohibition (Prohibition 4(c) on page 4.1 -5 of the
Basin Plan), including other aspects of the project (e.g., roads, utilities, trails etc.) that
impact /discharge wastes to the 100 -year flood plain of any surface water at the
project site.
M .
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -50 September 2003
2.0 RESPONSE TO COMMENTS
•
The storm channel /creek maintenance BMP shall only be used in tributaries that are not
considered "waters of the State." In field review with a qualified biologist, a civil
engineer, and Regional Board staff, the applicant determined the locations that are
considered "waters of the State" and their 100 -year floodplain. Those areas are
delineated in the Specific Plan and site plan maps found in the Project Description of
the Draft EIR and are shown as no- disturbance areas with details provided for crossing
of these areas by roadways and golf cart paths (for more detail regarding this
important issue, please review Impact 4.7.8 regarding avoidance of sensitive habitats
found in the Biological Resources section of the Draft FIR). '
Response to Comment 1 -20
The commentor requests that the Final EIR provide a comprehensive list of all BMPs i
applicable to the project. Please see Appendix I. This list does not limit the possibility
that additional BMPs will be added during the permitting process with the Regional
Board.
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Town of Truckee Final Environmental Impact Report
September 2003 2 -51 Gray's Crossing Specific Plan Project
D HUG -05 -2003 1 21 CALTRANS D3 PLANNING 53 741 5346 P.02/05
EPARTMENT 1 OF TRANSPORTATION :; itti;
ISTRICT 3 " ;,,
03 B STREET 1
.0.BOX911
Flex your power!
MARYSVILLE, CA 95901 -0911 Bed
ONE (530) 7414025
AX (530) 741 -5346 LETTER 2
PPY (630) 741-4509
I
II August 5, 2003
03NEV0023
I 03 -NEV -089, PM 2.560
Gray's Crossing Planned Community
DEIR, SCH #: 2002072115
I Ms. Heidi Scoble, Associate Planner
Town of Truckee
I Community Development Department
10183 Truckee Airport Road
Truckee, CA 96161
I Dear Ms. Scoble:
1 Thank you for the opportunity to review and comment on the above referenced draft
environmental impact report (DEIR) for the proposed mixed -use development on 757
I acres. The project is located on the northeast corner of State Route (SR) 89/267 and
Interstate 80 (I -80). Our comments are as follows:
Section 3.6. Project Site Characteristics:
I • Under the discussion of Roadway Access beginning on page 3 -37, the statement is
made that "The applicant proposes that roundabouts be utilized at the Prosser Dam 2 -
Road/Alder Road/SR 89 and Donner Pass Road/SR 267 intersection to accommodate
i
traffic generated from current and projected traffic." This statement is inconsistent
with Mitigation Measure 4.2.1 on page 4.2 -48.
III Section 4.2. Transportation and Circulation:
• On page 4.2 -48, Mitigation Measure 4.2.1 states that either a roundabout or a 2 -
I traffic signal will be installed at the Prosser Dam Road/Alder Road/SR 89 and
Donner Pass Road/SR 267 intersections, subject to approval by Caltrans. This
measure is stated acceptably.
1 • The decision to install a traffic signal or a roundabout at each of these intersections
' will have to be made based on counts and observations in the future. The Truckee 2 - 3
Bypass construction is not yet completed, and the first new developments in this /
V
i "Coltrane improves mobility across California'
IG -05 -2003 11 21 CALTRRNS.D3 PLANNING 530 741 5346 P.03/05
Ms. Heidi Scoble
August 5, 2003
Page 2 I
area will be a good indicator of the future traffic patterns and volumes that can be
expected.
• The connection of Thayer Drive to Pioneer Trail will also affect the traffic volumes
in this area. It should be assumed that left turn lanes would be required on SR 89 2 -4
at the Prosser Dam Road intersection before a decision is made as to whether a
traffic signal or roundabout will be approved for that intersection.
• Within Sub - section 4.2.2, Regulatory Framework, under Local Regulations on page
4,2 -12, a Level of Service Criteria Study was discussed. In referencing the study,
the statement was made that "...the maximum peak hour capacity per lane for a
two -lane highway operating at Level of Service (LOS) D or better is 1,584...." It was
further stated on this page that "...the capacity of the SR 267 Bypass (at the Town's
LOS standard of D) is 1,891 vehicles per hour per lane ", and that "1,891 vehicles
per hour per lane could be accommodated along the roadway links of the SR 267 2 -5
Bypass, which would contain wider lanes and shoulders than are currently provided
through the `Mouseholem. Both of these vehicles per hour per lane values are
unreasonably high for any significant length of two -lane highway. Speed differences
create gaps in traffic that reduce the capacity of two -lane highway. While a capacity
of 1,500 is acceptable in flat to rolling terrain with access control or very few
turning movements, we recommend that a lower value be used for developed areas
and long grades. I
• In Table 4.2 -5 on page 4.2 -24 and in other similar peak -hour traffic volumes tables, 2 -6
the eastbound and westbound columns appear to be switched. In addition, our I l M
records indicate that the westbound through volumes at the Donner Pass and
Prosser Dam intersections in Table 4.2 -5 are high.
• Within Sub - section 4.2.4, Cumulative Impacts and Mitigation Measures, and '
beginning on page 4.2 -56, it is unclear for the Year 2023 analyses whether the 2 -7
Thayer Drive connection to Pioneer Trail or the Soaring Way extension to Joerger
Drive have been assumed. It seems likely that both of the road connections will be
complete by that time.
• The discussion of Impact 4.2.9 on pages 4.2 -86 and -87 pertaining to the potential
increased demand for transit services was limited to the SR 89 corridor. MM 4.2.9
recommends that the applicant prepare a transit plan for the SR 89 corridor. We
recommend that the cumulative transit needs along the SR 267 corridor also be 2 -8
identified in the transit plan. This recommendation is supported by the text on page
4.2 -2, which states that SR 267 is a "route of local and regional significance,
providing access to residential, industrial, commercial, and recreational land uses".
"Caltrane improves mobility across Califorma'
RUG -05 -2003 11 21 CRLTRRNS D3 PLRNNING 530 741 5345 P.04/05
• Ms. Heidi Scoble
August 5, 2003
Page 3
• Impact 4.2.8 on pages 4.2 -77 and 78 identified cumulative circulation impacts, and
MM 4.2.8 on pages 4.2 -79 through 4.2 -86 identified mitigation measures (fair share
costs) that will reduce the impacts to a less than significant level. However, on page
4.2 -89, Interstate 80 (I -80) is identified as being deficient (LOS F) in 2023, and the
additional traffic volume impacts, 9 percent eastbound and 2 percent westbound,
are considered to be "significant and unavoidable ", yet there are not mitigation 2 -
measures identified. We disagree that the cumulative circulation impacts on I -80
generated from the project are significant and unavoidable. The 2001 I -80
Transportation Concept Report lists the 20 -year Improved Concept LOS for
segment 9 as E. As such, we request that a mitigation measure be developed which
applies fair share costs to the 1 -80 impacts attributable to the proposed Gray's
Crossing development.
• The General Plan Circulation Goal 8 "Analysis" box on page 4.2 -18 states "...the
project access is provided directly onto I -80 at a location with a high level of
available capacity, which limits the project's contribution to congestion on local
roadways within the area ". This direct access may help congestion on the local 2 -
roadways, but adversely affect mobility on I -80. We suggest the internal circulation
' for Gray's Crossing be re- evaluated, so that drivers are not forced to utilize I -SO for
local trips. We believe that the re- evaluation is especially important in light of
Impact 4.2.12 on page 4.2 -89. This impact states that the year 2023 traffic volumes
t with the project will result in "...Interstate 80 is expected to be deficient ".
Section 4.6, Water Quality and Surface Hydrology:
• Comments submitted in our February 3, 2003 letter (attached) that pertain to ( 2 -
potential hydrological and water quality impacts still apply to the DEIR.
• We concur with the proposed mitigation measure (MM) 4.6.7, which requires
preparation of a Master Drainage Plan for the project, and that the "cumulative 2
effects" of development on runoff, drainage, and water quality will be mitigated by
means of the use of detention basins
• We recommend that the language of MM 4.6.7 be modified and require the Master
Drainage Plan to include area -by -area site mitigation for drainage modifications.
There may be cases where runoff from one area of the project site might have an 2 -
impact on the State's highway right -of -way and highway drainage facility up
gradient of a proposed Best Management Practice (BMP) detention basin.
• If runoff is increased in an area that is up gradient of a highway drainage facility, a
water quantity /quality mitigation BMP should be constructed within that area prior 2 -
to discharge to the State's highway right -of -way.
'Coltrane improves mobility acroes California"
1G -05 -2003 11 21 CALTRANS D3 PLANNING 530 741 5346 P.05/05
Ms. Heidi Scoble
August 5, 2003
Page 4
• Please request copies of any documents pertaining to site runoff, drainage, and t
water quality when available, and send them to Mr. Mike DeWall, District 3 2
Hydraulics Branch in Marysville for review prior to final project approval. Mr.
DeWall can be reached at (530) 741 -4056.
An Encroachment Permit will be required for any work conducted in the State's right
of way, including for signs in the right of way, traffic control, light installation, culvert 2 -
maintenance, changes in drainage patterns, sidewalk installation or construction of
any new or rehabilitated access. To secure an application, please contact Mr. Bruce
Capaul, Caltrans District 3, Office of Permits, at 530 - 741 -4408.
Please send us a copy of the final environmental impact report when available. If you
2 1
have any questions regarding these comments, please contact Rick Heiman, Local I
Development/Intergovernmental Review Coordinator, at (530) 634 -7612.
Sincerely,
K
Z RUCE 1 � TERRA, Chief
Office of Regional and Transit Planning
Cc: Philip Crimmins, State Clearinghouse
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°Caltrans improues mobility across California' I.
HUU — d — G19t'JS 10 LH H
LIKNS US HLHNNING 538 441 5346 F.02iO4
DEPARTMENT' OF TRAJORTATION
L _r y �rmnt
DISTRICT 3 th
2389 Gateway Oaks. Blvd., Suite 100 �'
Sacramento, CA 95833 `'�'�J
PHONE (916) 274-0641
FAX (916) 274 -0648 lie, yanrpnxrer!
Be energy efficient!
•
February 3, 2003
Heide Scoble
Town of Truckee
10183 Truckee Airport Road
Tnickee, CA 96161 -4947
03NEV001
03- NEV -89 -PM 0.57
Gray's Crossing
Dear Ms. Scoble
. Thank you for the opportunity to review and comment on the above referenced
document.
' The proposed project is planned for construction in multiple areas adjacent to SR 89
• (Nev -89, PM 0.57 (I 80 separation) to PM 2.12 (Rainbow Dr. intersection)). Phase I of'
this project is located on the west side of SR 89 (Nev -89, PM 1.15), north of Alder Drive.
The natural terrain in this area slopes from the northwest to the southeast at 5% to
10% slope. In the natural, pre - construction condition, surface water (storm water)
runoff from this site flows toward SR 89 and either pass beneath the highway through
a number of existing cross drain culverts or to the far southeast end of the site where it
enters an existing intermittent stream that flows to the northeast and passes beneath
the highway (Nev -89, PM 1.26) through a steel arch pipe on its way to Prosser Creek
Reservoir.
•
Phase 2 of the project will be built along the east side of SR 89, just north of I 80 and
. south of Prosser Dam Road. Runoff from this area is divided with a portion following
the terrain that slopes gently to the northwest toward SR 89 and the intermittent
stream and a portion that flows to the southeast toward I 80. The southern segment of
the portion that flows to the northwest must pass beneath SR 89 prior to entering the
intermittent stream. The northern segment of the portion that flows to the northwest
crosses beneath Prosser Dam Road and enters the intermittent stream, down gradient
of SR 89.
Phase 3 of the project is located north of Prosser Dam Road and flows directly to the
intermittent stream, down gradient of SR 89. •
"Caimans improves mobility across California"
•
i •
nUu c✓u 'cuuJ AtrieJ Lnurna ui rLnrinlinu ',DJ r41 D34b r.0.7/04
Addressee: Heide 3 oble
Date: February 3, 2003 1
1
Phase 4 of the project is located north of Prosser Dam Road. The western edge of this 1
phase is immediately adjacent to SR 89. Depending on site grading of the development
of this phase, the westerly most portion may be graded to drain to the west toward SR
89.
1
The Any cumulative impacts to Caltrans drainage facilities, bridges, or other State
facilities arising from effects of development on surface water runoff discharge from the
peak (100 -year) storm event should be minimized through project drainage mitigation
measures. I
• Increases in peak runoff discharge for the 100 -year return storm event to the State's
highway right of way and to Caltrans' highway drainage facilities must be reduced to
at or below the pre - construction levels. All runoff from the project area that will enter
the State's highway right of way and Caltrans' highway drainage facilities must meet
all RWQCB water quality standards. The cumulative effects on drainage due to
development within the region should be considered in the overall development plan of
this area.
• No net increase to 100 -year storm event peak discharge may be realized within the
State's highway right of way and/or Caltrans drainage facilities as a result of the
project. Further, the developer must maintain, or improve existing drainage patterns
and/or facilities affected by the proposed project to the satisfaction of the State and
Caltrans. This may be accomplished through the implementation of stormwater
management Best Management Practices (BMPs) (i.e., detention/retention ponds or
basins, sub - surface galleries, on -site storage and/or infiltration ditches, etc.) as
applicable. Once installed, the property owner must properly maintain these systems. I
The proponent/developer may be held liable for future damages due to impacts for
which adequate mitigation was not undertaken or sustained.
• Runoff from the proposed project that will enter the State's highway right of way
and/or Caltrans drainage facilities must meet all Lahontan Regional Water Quality
Control Board water quality standards prior to entering the State's highway right of
way or Caltrans drainage facilities. Appropriate stormwater quality BMPs (i.e.,
oil/water separators, clarifiers, infiltration systems, etc.) may be applied to ensure that
runoff from the site meets these standards (i.e., is free of oils, greases, metals, sands,
sediment, etc.). Once installed, the property owner must properly maintain these
systems. I
• No detailed drainage plans, drawings or calculations, hydrologic/hydraulic study or
report, or plans showing the "pre- construction" and "post- construction" coverage ,
"Caimans improves nmbiliry arrnss C.'aliJnrnia"
i
nuu <r� cesei.n Ln•ler i.nurcnivo Lu rLnrvrvinu JJVJ 'Cµ1 JJµb Y. b4 /(�µ
Addressee: Heide Scoble
Date: February 3, 2003
•
quantities for buildings, streets, parking, etc. were received with the application
' package. In order to adequately evaluate project impacts upon the State's right of way
and Caltrans drainage facilities, we recommend that you request these documents from
the project proponent and send them to Caltrans District 3 Hydraulics Branch at the
' above address for review prior to final project approval.
Our traffic engineer will make his comments on this project when the Draft
Environmental Impact Report is circulated for review.
We are requesting a copy of conditions of approval for this project issued by your
department. If you have any questions, please contact me at (916) 274 -0641.
•
Sincerely,
•
' D
•
ruiinal Sire() b
Ann Marie Robinson
Office of Regional and Transit Planning
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" Cal rrnar improves mabiliry across Califaryria"
TOTAL P.04
•
2.0 RESPONSE TO COMMENTS
I
LETTER 2 BRUCE DE TERRA, CALIFORNIA DEPARTMENT OF TRANSPORTATION
Response to Comment 2 -1
' The commentor indicates that the project description proposes roundabouts at the SR
89 /Alder Road /Prosser Dam Road and Donner Pass Road /SR 89 intersections but then
MM 4.2.1 inconsistently requires that a roundabout or traffic signal be constructed
(emphasis added). As the construction of a roundabout at either the SR 89 /Alder
Road /Prosser Dam Road or Donner Pass Road /SR 89 intersections is subject to Caltrans
' approval, the EIR analyzed the construction of a traffic signal or roundabout at these
intersections so that the proposed project is not jeopardized in the case that Caltrans
will not approve a roundabout.
Response to Comment 2 -2
The commentor notes that MM 4.2.1 is stated acceptably. The comment is noted and
included here for the consideration of the Town Council.
' Response to Comment 2 -3
The commentor indicates that the decision to install a signal or roundabout at the SR
89 /Alder Road /Prosser Dam Road and Donner Pass Road /SR 89 intersections will have
to be made based upon counts and observations in the future as they may not be
warranted in the absence of growth assumed to occur in the 2005 analysis. For this
reason, MM 4.2.1 requires the project applicant to prepare a signal warrant analysis at
' the SR 89 /Alder Drive /Prosser Dam Road intersection prior to constructing a signal or
roundabout.
' As the same should be required at the SR 89 /Donner Pass Road intersection, MM 4.2.1
on page 4.2 -48 has been changed accordingly as follows:
' MM 4.2.1 Prior to the issuance of the first building permit for the project or the
recordation of final subdivision maps (whichever comes first), the
project applicant shall pay its fair share cost of improvements at the
' SR 267 /Northstar Drive and Donner Pass Road /Bridge Street
intersections as described in Table 4.2 -15. Prior to issuance of the
first Certificate of Occupancy or recordation of the Phase I Final
Subdivision Map (whichever comes first), the project applicant shall
conduct a signal warrant analysis .at the SR 89 / Donner Pass Road
intersection. If found by Caltrans to warrant improvement, the
project applicant shall construct a signal or roundabout at this
location as described in Table 4.2 -15. If a signal warrant is not met
prior to Phase 1 construction, at the Town's discretion, the project
applicant shall be responsible for preparing a roundabout or signal
design acceptable to Caltrans, posting a bond with the Town of
Truckee equal to 125 percent of the construction cost of the
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -52 September 2003
2.0 RESPONSE TO COMMENTS
improvement, conducting a signal warrant analysis on an annual I
basis, as well as for construction of a signal or roundabout when
warrants are determined by Caltrans to be met. These signal
warrant analyses will need to consider construction traffic impacts.
Finally, if a signal or roundabout is not warranted prior to Phase 2
construction, the applicant will be required to provide traffic
management at the intersection during those construction traffic
periods at which average delay exceeds 50 seconds per vehicle, or
provide a construction traffic management plan that avoids this
level of delay.
In addition, prior to issuance of the first Certificate of Occupancy or
recordation of the Phase 1 Final Subdivision Map for Grays Crossing
Phase 1, the applicant shall construct a northbound left -turn lane at
the SR 89 /Alder Drive /Prosser Dam Road intersection. The applicant
can alternatively construct a signal or roundabout at this location
prior to recordation of subdivision maps or building permits for Phase
I, if identified as appropriate by Caltrans based upon a signal
warrant analysis. If approval of a signal or roundabout is not
granted by Caltrans, the project applicant shall be responsible for
preparing a roundabout or signal design acceptable to Caltrans, '
posting a bond with the Town of Truckee equal to 125 percent of the
construction cost of the improvement, conducting a signal warrant
analysis on an annual basis, as well as for construction of a signal or
roundabout when warrants are determined by Caltrans to be met.
The applicant would have the opportunity to recover a portion of
costs from fees collected in the future from projects also contributing
to future traffic growth at this intersection, as required by the Town of
Truckee. Finally, all construction traffic shall be prohibited from
entering SR 89 from Prosser Dam Road when exiting the Phase II
construction areas (exiting via the Donner Pass Road access point),
unless a signal or roundabout is in place.
also construct the improvements to tho SR 89 North / Donnor Pass
Prosser Dam Road intersection (if not constructed by othors).
signal warrant analysis at the SR 89 / Alder Drive / Prosser Dam Road
intersection. If found by Caltrans to meet warrants, the project
applicant shall construct a signal or roundabout at this location as
described in Table 4.2 15, prior to issuanco of the first Certificate of
Final Subdivision Map {whichover comps first). If not found by i
Town of Truckee Final Environmental Impact Report
September 2003 2 -53 Gray's Crossing Specific Plan Project
111
2.0 RESPONSE TO COMMENTS
bond with the Town of Truckee equal to 125 percent of tho
I projects also contributing to futuro traffic growth at this intersection,
as required by the Town of Truckee.
Please note that the SR 89 North /Prosser Dam Road intersection and
SR 89 / Alder Drive / Prosser Dam Road intersection were analyzed
as both signalized intersections and as roundabouts, as shown in the
site plan. In 2005 with a roundabout, both intersections are
expected to operate at a LOS B or better for both the weekend and
weekday plus project conditions.
For the purposes of determining the project's fair share cost, the
percentage the Gray's Crossing project contributes to the total
' future growth in PM peak -hour total intersection volume at each
intersection requiring mitigation is presented in Table 4.2 -16. None
of the improvements identified above are included in the existing
•
' Placer County or Town of Truckee Traffic Fee Programs. The fair
share cost to improvements within the Town of Truckee shall be paid
to the Town of Truckee. Similarly, the fair share cost to improvements
within Placer County shall be paid to Placer County.
•
However, please note that the Town of Truckee and Placer County
' are currently conducting a joint study of a potential joint regional
traffic impact mitigation program, which could mitigate the impact
of planned growth on these regional facilities. The timing of this
' project may provide an opportunity to mitigate identified impacts to
regional transportation facilities through a larger coordinated
program. Therefore, if a regional traffic impact fee program is
implemented by the Town of Truckee and Placer County and all the
intersections identified as requiring mitigation in this EIR are
contained in this fee program, the project applicant shall pay the
' appropriate amount into this fee program prior to the issuance of the
first building permit for the project or the recordation of final
subdivision maps. The project applicant's fee will be determined by
the methodologies adopted as a part of the regional fee program.
If some of the roadways or intersections identified above are not
• contained in the fee program, the project applicant shall pay its fair
share to the additional improvements.
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -54 September 2003
2.0 RESPONSE TO COMMENTS I
Timing /Implementation: Prior to recordation of subdivision maps or the I
issuance of initial building permit or the recordation of the final subdivision
map, except that construction of the SR 89 / Alder Drive roundabout or '
signal shall be required prior to issuance of the first Phase II building permit
or the recordation of Phase 2 final subdivision maps, as this improvement is
not required to accommodate Phase I traffic. II
Town of Truckee, Placer County Department of
Public Works, Ca /trans .
Response to Comment 2 -4 '
The commentor indicates that a northbound left -turn lane should be constructed at the
. SR 89 /Alder Drive intersection prior to the construction of a roundabout or traffic signal.
In the case that a signal or roundabout is not constructed, a northbound left -turn lane
should be constructed at the SR 89 /Alder Drive /Prosser Dam Road intersection. MM
4.2.1 has been revised to clearly state this as shown under Response to Comment 2 -3
above.
Response to Comment 2 -5 '
The commentor states that the threshold of 1,891 vehicles per hour per lane to maintain
a LOS D is not appropriate. This threshold is based upon an adopted policy for Nevada
I
County (Nevada County LOS Criteria Study, Prism Engineering, December, 2000) and
has been identified by the Town of Truckee staff as appropriate for the corridor,
although it has been adjusted to reflect factors contained in the 2000 Highway
I
Capacity Manual. In addition, it should be noted that the segment of roadway to
which this threshold is applicable is SR 267 from 1 -80 to Brockway Road, which is a flat ,
access - controlled section of roadway.
Regardless, for comparison, an analysis of roadway LOS has been provided in Table 2 -2
below, which applies the Town of Truckee roadway LOS thresholds, the Placer County I
roadway LOS thresholds, and the Highway Capacity Manual LOS methodologies. As
the table indicates, the results of the LOS analysis remain the same regardless of the
threshold applied: SR 267 would need to be widened from 1 -80 to Waddle Ranch upon I
build out of the existing Mortis Valley Community Plan and Town of Truckee General
Plan, with or without the construction of the Third Tahoe Donner Connector.
TABLE 2 -2 1
COMPARISON OF ROADWAY LOS METHODOLOGIES ASSUMING A TWO -LANE SR 267
.7 n d E; Peak H W O LOS °Pe a ..1
if 4: a
Two-Way , Peak LOS per , A djusted
f
` , r ` e
Peak-Hour ct
Direion Pl v "" `I
t i`� i �� rt :Traffic Traffic ' '' Courit`y,� , County :u�OSper,HCMt
R %Segment =i =:67. . .i.Volume Volurne.� r ADTw _ := Thresholds -T hreshoolds� - Methodologies',
Without Third Tahoe
Donner Connector '
R 267 -1-80 to Brockway
Road 3,574 2,127 35,671 F F F I
R 267 - Brockway Road 5,525 3,333 45,769 F F F ,
Town of Truckee Final Environmental Impact Report
September 2003 2 -55 Gray's Crossing Specific Plan Project '
I .
RESPONSE TO COMMENTS
II TABLE 2 -2
COMPARISON OF ROADWAY LOS METHODOLOGIES ASSUMING A Two-LANE SR 267
>a ,w='3 ,�• y a , A?F Peak-Hour ��, c y :, LOS per 9d
4' r i Two Way ; Peak =, b { LOS pert : Adjusted; '
` = = N d
- evaa t '
3 cai r x r ' f '� Peak Hour = Direction Placer
. c . ra at a , § 's
I di-« rY h Traffic ATraff tx ' try County r Count' S �pei HCM
Roadway Seg ment :te ? Volume, . :i :Volum r , . ADT :.Thresholds ::Thresholds' `.'M
to Schaffer Mill Road
I R 267 - Schaffer Mill
Road to Waddle Ranch
Access 3,621 1,821 27,892 F • D F
With Third Tahoe Donner
I Connector
SR 267 -1-80 to Brockway
Road 3,539 2,122 35,287 F F F
I SR 267 - Brockway Road
to Schaffer Mill Road 5,545 3,343 45,859 F F F
SR 267 - Schaffer Mill
I Road to Waddle Ranch
Access 3,626 1,826 27,867 F D F
Note l: Nevada County thresholds not applicable to this segment due to steep grades.
I Note 2: Bold indicates methodology used in EIR for specific segment.
Response to Comment 2 -6
I The commentor states that the eastbound and westbound traffic volumes appear to
be switched in Table 4.2 -5 of the Draft EIR. The commentor is correct and the table
I headings have been corrected as follows (this mislabeling did not impact any other
elements of the analysis). Page 4.2 -24 of the Draft EIR is amended to read:
TABLE 4.2-5
I 2005 WEEKEND No PROJECT PEAK-HOUR TRAFFIC VOLUMES
pr, P , s _ ;, r =1 , Northbound • Seothbouncl WeEastbound !';EaWestbound:'
:T
I Intersection �T',± . '. 7 :: LT , . Ta Y RT ih LTA T�.,.:- - C ._. LT „,_ - T. R T a LTx ; . T ` _ - RT. '
SR 89 / Rainbow Dr 0 199 90 16 364 0 0 0 0 53 0 14
SR 89 / Prosser Dam Rd / Alder Dr59 262 55 11 390 16 5 136 60 7 11 11
I SR 89 North / Donner Pass Rd 189 229 0 0 265 321 147 129 0 0 0 0
SR 267 /1-80 WB 421 165 0 0 248 146 0 0 0 263 0 253
SR 267 /1-80 EB 0 511 76 392 183 0 75 0 382 0 0 0
I Donner Pass Rd / Pioneer Trail 191 179 0 0 358 106 103 0 200 0 0 0
Donner Pass Rd /1-80 WB 160 364 0 0 305 253 0 0 0 0 0 0
' Donner Pass Rd /1 EB 0 450 0 0 305 0 74 0 280 0 0 0
Page 4.2 -39 of the Draft EIR is amended to read:
'
' Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -56 September 2003
'
2.0 RESPONSE TO COMMENTS '
TABLE 4.2 -10 - I
2005 SUMMER WEEKEND PEAK -HOUR PROJECT - GENERATED TRIPS
M t , A , Northbound South bound WeEa t
sboun d € Westboun
"-d
Intersection x Y "` " & . : ' . : Lire. Tj , . R T 2 LT T: - R11 LT . T RT ,.: LT. f ` T* RTt
SR89 /Rainbow Dr 0 12 11 0 13 0 0 0 0 1.3 0 0 ,
SR 89 / Prosser Dam Rd / Alder Dr 78 3 175 18 3 5 3 17 52 171 18 17
SR 89 North / Donner Pass Rd 0 145 120 12 162 52 94 41 0 119 27 3
SR 267 /1-80 WB 0 228 0 0 119 171 0 0 0 0 0 37 '
SR 267 /1-80 EB 0 90 0 35 84 0 138 0 0 0 0 0
Donner Pass Rd / Pioneer Trail 0 117 0 0 63 17 18 0 0 0 0 0
Donner Pass Rd / 1 -80 WB 0 117 0 0 54 9 0 0 0 0 0 0 '
Donner Pass Rd /1-80 EB 0 107 0 0 54 0 10 0 0 0 0 0
TABLE 4.2 -11 '
2005 SUMMER WEEKEND PLUS PROJECT PEAK - HOUR VOLUMES
., °s Northboutith Southbound:-*. WeEastbound , EaWestbound
I I
ntersection .. .r:., . _ ., LT . IT. n .'�RT .. . LT.. ,IT ,.-IRT It ti: = �T ' �RT. . . LT'S, . T _ RT. °1''-
SR 89 / Rainbow Dr 0 211 101 16 377 0 0 0 0 66 0 14
SR 89 / Prosser Dam Rd / Alder Dr 137 265 230 29 393 21 19 22 188 231 25 28 1
SR 89 North / Donner Pass Rd 189 374 120 12 427 373 241 41 129 128 27 17
SR 267 /1-80 WB 421 393 0 0 367 317 0 0 0 263 0 290
SR 267 /1-80 EB 0 601 76 427 267 0 213 0 .382 0 0 0 '
Donner Pass Rd / Pioneer Trail 191 296 0 0 421 123 121 0 200 0 0 0
Donner Pass Rd /1-80 WB 160 481 0 0 359 262 0 0 0 0 0 0
Donner Pass Rd /1-80 EB 0 557 0 0 359 0 84 0 280 0 0 0 '
Page 4.2 -57 of the Draft EIR is amended to read:
TABLE 4.2 -21 '
2023 NO THIRD TAHOE DONNER CONNECTOR SUMMER WEEKEND NO PROJECT PEAK - HOUR VOLUMES
R T - -4 , , Northbound Southbound WeEastbound EeWestb ound
Int edti ' = LT'.. -T .„... Lt.: T. _. RT.: > LT ._T,.
Intersectionxi = >,,., u.', r
SR 89 / Rainbow Dr 0 320 . 195 20 405 0 0 0 0 130 0 15
SR 89 / Prosser Dam Rd / Alder Dr 120 480 105 10 510 10 25 10 150 80 10 10 II SR 89 North / Donner Pass Rd 325 430 0 0 275 465 275 0 180 0 0 • 0
SR 267 / 1-80 WB 820 375 0 0 445 15 0 0 0 755 0 380
SR 267 /1-80 EB 0 1 170 500 435 765 0 25 0 810 0 0 0 '
Donner Pass Rd / Pioneer Trail 350 315 0 0 545 125 120 0 270 0 0 0
Donner Pass Rd /1-80 WB 200 665 0 0• 450 365 0 0 0 0 0 0
Donner Pass Rd /1-80 EB 0 640 0 0 450 0 _225 0 _365 0 0 0 ,
I
Town of Truckee Final Environmental Impact Report
September 2003 2 -57 Gray's Crossing Specific Plan Project '
' 2.0 RESPONSE TO COMMENTS
' TABLE 4.2 -22
2023 WITH THIRD TAHOE DONNER CONNECTOR SUMMER WEEKEND NO PROJECT PEAK -HOUR VOLUMES
' w x w • Northbound Southbound WeEastbound EaWestbound ;
IrltersectIon `;1'x .. . . . t. ,.. ,.-A: .: LT il - RT. ":? LT T.: -' RT - LT-` =` T: RT . . LT ` i T.::',* __RT, L
SR 89 / Rainbow Dr 0 290 195 20 415 0 0 0 0 130 0 15
' SR 89 / Prosser Dam Rd / Alder Dr 120 445 110 10 520 10 25 10 155 80 10 10
SR 89 NORTH / Donner Pass Rd 365 415 0 0 285 475 260 0 210 0 0 0
' SR 267 /1-80 WB 815 375 0 0 485 15 0 0 0 755 0 405
SR 267 /1-80 EB 0 1165 500 475 765 0 25 0 775 0 0 0
Donner Pass Rd / Pioneer Trail 345 305 0 0 545 160 145 0 265 0 0 0
' Donner Pass Rd /1-80 WB
Donner Pass Rd /1-80 EB 185 655 0 0 455 355 0 0 0 0 0 0
0 620 0 0 455 0 220 0 350 0 0 0
Pages 4.2 - 60 and 4.2 - 61 of the Draft EIR are amended to read: •
' TABLE 4.2 -23
2023 SUMMER WEEKEND PEAK -HOUR PROJECT - GENERATED TRIPS
NO THIRD TAHOE CONNECTION
'
, Northbound Southbound WeEastbound €aWestbound
Intersechon &zP. ik -, ; . ° Lt :4.t T; - . RT: <:i LT T ':H RT . Cr .x , T RT+ LT JF T, , RT €;'
' SR89 /Rainbow Dr 0 12 11 0 13 0 0 0 0 13 0 0
SR 89 / Prosser Dam Rd / Alder Dr 78 3 175 18 3 5 . 3 17 52 171 18 17
SR 89 North / Donner Pass Rd 0 135 120 12 162 52 94 41 0 128 27 17
I SR 267 /1-80 WB 0 228 0 0 119 171 0 0 0 0 0 37
SR 267 /1-80 EB 0 90 0 35 84 0 138 0 0 0 0 0
Donner Pass Rd / Pioneer Trail 0 1 17 0 0 63 17 18 0 0 0 0 0
'
Donner Pass Rd /1-80 WB 0 117 0 0 54 9 0 0 0 0 0 0
Donner Pass Rd /1-80 EB 0 107 0 0 54 0 10 0 0 13 0 0
' TABLE 4.2 -24 .
2023 SUMMER WEEKEND PEAK -HOUR PROJECT - GENERATED TRIPS
WITH THIRD TAHOE-DONNER CONNECTION
"' `' ' 'r , North bou n d Southbound WeEastbburld= EaWestboun d
I n. -. - - - . - . -
tersection:<
.r....,_ ..�, a _-` LT. ' J, RT ;: LT T' . LT :T... RT' LT , .T RT
' SR 89 / Rainbow Dr 0 12 11 0 13 0 0 0 0 13 0 0
SR 89 / Prosser Dam Rd / Alder Dr 78 3 177 18 3 5 3 17 52 173 18 17
SR 89 North / Donner Pass Rd 0 133 104 12 153 62 108 55 0 104 40 17
'
SR 267 /1-80 WB 0 200 0 0 119 148 0 0 0 0 0 37
SR 267 /1-80 EB 0 90 0 35 84 0 110 0 0 0 0 0
' Donner Pass Rd / Pioneer Trail
Donner Pass Rd /1-80 WB 0 117 0 0 62 40 45 0 0 0 0 0
0 117 0 0 54 8 0 0 0 0 0 0
Donner Pass Rd /1-80 EB 0 107 0 0 54 0 10 0 0 0 0 0
Final Environmental Impact Report • Town of Truckee
Gray's Crossing Specific Plan Project 2 -58 September 2003
2.0 RESPONSE TO COMMENTS
TABLE 4.2 -25 •
2023 SUMMER WEEKEND PLUS PROJECT PEAK -HOUR TRAFFIC VOLUMES
No THIRD TAHOE- DONNER CONNECTION
k Northbound Southbound . WeEastbound EaWestbound ".
i Intersection ;;4; .. RT. SI':
SR 89 / Rainbow Dr 0 332 206 20 418 0 0 0 0 143 0 15
SR 89 / Prosser Dam Rd / Alder Dr . 198 483 280 28 513 15 28 27 202 251 28 27
SR 89 North / Donner Pass Rd 325 575 120 12 437 517 369 41 180 128 27 17
SR 267 /1-80 WB 820 603 0 0 564 186 0 0 0 755 0 417
SR 267 /1-80 EB 0 1260 500 470 849 0 163 0 810 0 0 0
Donner Pass Rd Pioneer Trail 350 432 0 0 608 142 138 0 270 0 0 0
Donner Pass Rd /1-80 WB 200 782 0 0 504 374 18 0 0 0 0 0
Donner Pass Rd /1-80 EB 0 747 0 0 504 0 235 0 365 0 0 0
TABLE 4.2 -26
2023 SUMMER WEEKEND PLUS PROJECT PEAK -HOUR TRAFFIC VOLUMES
WITH THIRD TAHOE - DONNER CONNECTION
Northbound Southbound WeEastbound EaWestbourid'.
Irtersection . LT T RT LT ; T RT LT . T :HRT :1 if T . RT. '
SR 89 / Rainbow Dr 0 302 206 20 248 0 0 0 0 143 0 15
SR 89 / Prosser Dam Rd / Alder Dr 198 448 287 28 523 15 28 27 207 253 28 27 111 SR 89 North / Donner Pass Rd 365 548 104 12 438. 537 368 55 210 113 40 17
SR 267 /1-80 WB 815 575 0 0 604 163 0 0 0 755 0 442
SR 267./1-80 EB 00 1,255 500 510 849 0 135 0 775 0 0 0
Donner Pass Rd / Pioneer Trail 345 422 0 0 607 200 190 0 265 0 0 0
Donner Pass Rd /1-80 WB 185 772 0 0 509 363 0 0 0 0 0 0
Donner Pass Rd /1-80 EB 0 727 0 0 509 0 230 0 350 0 0 0 1
The commentor also states that the westbound traffic volumes at the SR 89 /Donner Pass '
Road and SR 89 /Prosser Dam Road intersections seem high. These volumes are
significantly higher than existing volumes, as they represent 2005 conditions. The 2005
volumes assume the following additional development along Pioneer Trail and SR 89
north of 1 -80:
• 30 units built in the Pineforest at Truckee subdivision
• Build out of the Pioneer Commerce Center •
• Build out of the Truckee Industrial Park
• 900 students at the Town of Truckee Middle School
In addition, when reviewing the chapter, corrections were made to the calculations in
Table 4.2 -14. These corrections do not affect the results of the traffic analysis in any way.
1
Town of Truckee Final Environmental Impact Report
September 2003 2 -59 Gray's Crossing Specific Plan Project
•
•
2.0 RESPONSE TO COMMENTS
' Table 4.2 -14 on pages 4.2 -46 and 4.2 -47 of the Draft EIR is amended to read:
TABLE 4.2 -14
2005 No PROJECT AND PLUS PROJECT WEEKDAY ADT AND PEAK -HOUR PEAK - DIRECTION VOLUMES
. #w - t Pia r
s„ .l 4 177
., r Gounty/TOwn
r , Q Project )
- ' of Truckee
.*
NOProject. %Generated`` _Plus. Project. '
� h
z Pea Peak t Peak Peak
Ye i t s, -
r r Hourx Hours Hour Hour.
r r i ry .� ,{ �, a r' Peak 4 Peak: r Peak Peak'.
` p s ,- -
'• Direction Direction Direction > Directio
,ADT. Volumed rADT Volume ADT • Volume ADT. Volume
SR 89 North I -80 to Donner Pass Road 6,754 644 320 5,403 236 12,157 882 556 NA 1,891
SR 89 - Donner Pass Road to Alder Drive 9,265 1,025 590 4,504 228 13,769 -1;253 818 NA 1,891
SR 89 - Alder Drive to Rainbow Drive 5,947 42 405 493 22 6,440 64 427 NA 1,891
SR 89 - Rainbow Drive to Alder Creek Road 4,628 32 290 245 12 4,873 44 302 NA 1,891
t SR 267 1-80 to Brockway Road 12,585 305 775 1,644 82 14,229 387 857 NA 1,891
SR 267 - Brockway Road to Airport Road /Schaffer Mill Road 13,776 251 1 025 1,161 58 14,937 309 1 083 25,000 NA
SR 267 - Airport Road /Schaffer Mill Road to Northstar Drive 12,538 196 765 840 41 13,378 237 806 25,000 NA
SR 267 - Northstar Drive to Brockway Summit 8,976 152 680 647 31 9,623 383 711 16,200 NA
Bridge Street - Donner Pass Road to West River Street 10,413 76 605 399 21 10,812 97 626_ NA 1,891
Brockway Road Immediately South of West River Street 8,749 54 515 278 15 9,027 69 530 NA 1,891
Brockway Road Immediately West of SR 267 8,234 54 482 24 8,716 78 504 NA 1,891
Donner Pass Road Immediately South of 1 -80 12,041 -194 585 1,609 96 13,650 290 681 NA 1,891
' Donner Pass Road - Bridge Street to Glenshire Drive 12,000 -183 685 899 72 12,899 255 757 NA 1,891
Prosser Dam Road Immediately East of SR 89 1,333 -0 80 1,351 199 2,684 299 279 NA 1,891
Alder Drive Immediately East of SR 89 3,283 1,078 1854,206 77 7,489 1,155 262 NA 1,891
Pioneer Trail Immediately West of Donner Pass Road 8,656 54 515 322. 16 8,978 70 531 NA 1,891
Glenshire Drive Immediately South of Donner Pass Road 9,310 49 515 651 26 9,961 36 541 NA 1,891
' Airport Road Immediately East of SR 267 3,208 32 275 201 10 3,409 42 285 16,200 NA
Schaffer Mill Road Immediately West of SR 267 1,596 22 220 120 6 1,716 28 226 16,200 NA -
Northstar Drive Immediately West of SR 267 7,308 44 325 193 10 7,501 54 335 16,200 NA
Response to Comment 2 -7
I - • The commentor states that it is unclear whether the Thayer Drive Connection to Pioneer
Trail or the Soaring Way extension to Joerger Drive was assumed in the cumulative
' analysis. The Thayer Drive extension is assumed to be constructed by 2005 in the traffic
analysis as it is currently under construction.
Page 4.2 -3 of the Draft EIR has been amended to read:
-
Final Environmental Impact Report Town of Truckee
111 Gray's Crossing Specific Plan Project 2 -60 September 2003
•
•
2.0 RESPONSE TO COMMENTS •
Pioneer Trail ,
This roadway begins at Donner Pass Road on the east and continues in a
westerly direction. It serves a mixture of residential, industrial and commercial
uses. At its intersection with Donner Pass Road, Pioneer Trail is controlled by a
Stop sign. This roadway is planned to be a part of the Third Tahoe - Donner
Connection if built and would provide the first segment of the connection of the
roadway to SR 89. The exact alignment of this connection has not been
determined. '
Comstock Drive (Formerly Thayer Drive)
This roadway is currently under construction as a part of the Pineforest ,
Subdivision construction. It will connect Alder Drive to the north to Pioneer Trail to
the south west of SR 89. When completed, it will be controlled by a stop sign at
both its intersection with Alder Drive and Pioneer Trail.
The Joerger Drive /Soaring Way connection was not assumed to be in place under any '
analysis scenario. As the Soaring Way extension is not currently planned or funded, it
was not assumed in the 2023 analysis. However, according to the Martis Valley
Community Plan Final EIR (PMC, 2003), the provision of this connection would require an
additional northbound through lane and westbound left /through shared lane at the SR
267 /Brockway Road /Soaring Way intersection and the SR 267 /Airport Road intersection
would require one less southbound through lane on SR 267 to maintain an adequate
LOS. Regardless, improvements to both intersections would be necessary under 2023
conditions.
Response to Comment 2 -8
The commentor states that the project applicant should be required to prepare a ,
transit plan for the SR 267 corridor: Although the proposed project would result in a
contribution to transit demand along SR 267, the project applicant should only be
responsible for providing transit access from the project site to the Town's transit transfer
point (at the Train Station) where connections could be made to SR 267 transit
routesand other routes, as the project's impact on transit needs along SR 267 can be _
expected to be minimal. It should also be noted that a mitigation measure identified in
the Mortis Valley Community Plan FEIR requires Placer County to complete a focused
transit service plan for the Mortis Valley area, including the SR 267 corridor. The plan
would identify a reasonable public transit plan for the region through coordination with
the Town of Truckee and other stakeholders. Preliminary stages of the development of
this plan have already begun as a part of the Tahoe Area Regional Transit Short Range
Transit Plan study.
However, in order to clarify, MM 4.2.9 on page 4.2 -87 of the Draft EIR is amended to
read: '
•
1
Town of Truckee Final Environmental Impact Report
September 2003 2 -61 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
Mitigation Measures
MM 4.2.9 Prior to the first building permit or recordation of Final Subdivision Map
under Phase II, the project applicant shall prepare a transit plan
identifying methods and equipment necessary to provide transit
' services for project residents, guests and employees. The plan shall
also identify onsite improvements required to facilitate efficient transit
operations. Transit services shall provide transportation to downtown
' Truckee and provide connections to private and public transit
providers. The transit plan shall be reviewed and approved by the
Town of Truckee Public Works Director, and may consider programs
that serve other existing and planned developments in the northeast
portion of Truckee. In addition, the plan shall accomplish the
following:
' a) Identify the future transit demand that will result along the SR 89
North corridor upon build out of the area and determine
whether transit service is warranted based upon the level of
' demand.
b) Identify the level of service (frequency, days and hours of
service) needed to meet the warranted demand.
' c) Identify the project's fair share cost of providing the required
transit service. This shall include both capital and 'operating
costs of the service.
d) Identify the period (number of years) that the project will be
required to partially fund the transit service operation, which
' shall be used to calculate the present value.
The project will be required to pay 57 percent of tho present value of
' s hall be used to calculate the present value. In addition, the project
owners shall become members of the Truckee —North Tahoe .
Transportation Management Association.
' Timing /Implementation: Prior to issuance of building permits or the
• recordation of final subdivision maps.
' Enforcement /Monitoring: Town of Truckee
Implementation of MM 4.2.9 will reduce the project's impacts to transit to a less
than significant level.
Response to Comment 2 -9
The commenter states that the 2001 1 -80 Transportation Concept Report identifies a
Concept LOS E for 1 -80 in Truckee and that the project's fair -share cost to the
improvements required to attain this LOS E (which is assumed to include widening 1 -80 to
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -62 September 2003
•
2.0 RESPONSE TO COMMENTS
six lanes, probably between the Nevada state line and the end of the existing 6 -lane A
cross - section near Auburn) should be identified in the EIR. However, this level of analysis
has never been required for other EIRs in the region, primarily because Caltrans has not
developed any detailed plans for these improvements or identified any funding
mechanism for the improvements. In addition, a significant amount of additional data
not readily available from Caltrans would be required to perform such analysis, such as: '
a. The cost of the 1 -80 improvements would need to be identified. As Caltrans
has never developed a cost estimate to widen the facility, the applicant
would be required to estimate this cost or to obtain the cost estimate from
Caltrans. Either way, estimating the cost of such a project would be an
expensive study in itself and could not fairly be required of the project
applicant.
b. There may be other viable means of addressing future development's
impacts on 1 -80 traffic volumes, such as expansion of passenger rail service
from Auburn to Truckee. This option may be substantially less costly than
freeway widening, and the Placer County Transportation Planning Agency is
currently conducting a study into the costs and benefits of such a service.
However, this option would still need to be included in the development of
the impact fee program and how this is done would need to be determined.
c. Caltrans would be required to set up a special fund to hold the money
collected for the improvements to. I -80 or establish an entity that would be
the legal recipient of the funds. Caltrans would also need to determine what
mechanisms would be put in place to ensure that funds are spent in a timely
fashion, and that the other legal requirements of AB 1600 are met.
d. Caltrans would need to be prepared to be consistent by requiring all
development from Auburn to the Nevada state line that may add traffic to
this roadway segment to pay its fair share cost to the improvements. This
payment would then become a new requirement of other development EIRs
in the region, such as all of Martis Valley.
e. In order to estimate the project's fair share cost to this improvement, a list of
all future projects in the area that may contribute to traffic growth along the
1 -80 segment would need to be developed. It is assumed that Caltrans would
prepare and provide such a list.
•
In conclusion, as Caltrans has no specific adopted projects by which to attain the
concept LOS, as no other projects in the area have been required to pay their fair share
cost to this improvement, as there is not an established fee program and the work
needed to determine the fair -share cost (in absence of a fee program) would be very 1
substantial, it is not reasonable to request this fair -share payment.
1
1
Town of Truckee Final Environmental Impact Report
September 2003 2 - Gray's Crossing Specific Plan Project
1 2.0 RESPONSE TO COMMENTS
Response to Comment 2 -10
The commentor states that the project's direct access to 1 -80 adversely affects mobility
on 1 -80 as drivers may be forced to use 1 -80 for local trips. The commentor suggests that
the project be re- evaluated so that drivers are not forced to use 1 -80 for local trips. The
' proposed project is provided with direct access onto SR 89 and SR 267, which in turn
provides convenient access to 1 -80, although it is not direct. Therefore, local trips are
not forced to use 1 -80, although some local trips accessing the Gateway area and
Donner Pass Road between SR 89 South and the McIver roundabout might use 1 -80.
Regardless, the project's impacts to traffic volumes on I -80 just east and west of the SR
89 /SR 267 interchange have been evaluated in the Draft EIR. Reducing the project's
use of 1 -80 would require things such as ramp closures and prohibition of turn -
movements at freeway ramp intersections, which would impact all traffic (rather than
only project generated traffic. These types of modifications would impact connections
between elements of the state highway system, and would result in more negative
significant impacts to the region's traffic circulation than the proposed project alone.
Response to Comment 2 -11
The commentor notes that previous comments provided related to the proposed
' project still apply. This comment is noted and provided here for the consideration of
the Town Council.
' Response to Comment 2 -12
The commentor concurs that the use of detention basins will reduce impacts. The
' California Department of Transportation (Caltrans) requires a no net positive increase in
peak storm runoff from pre - development flows to post - development flows. The Caltrans
requirement protects the down stream structures from being damaged, assuming the
' down stream structures were previously sized to handle pre - development peak flows,
• and also maintains the pre - development peak flood levels. As required by MM 4.6.7
detailed on page 4.6 -28 of the Draft FIR, upon tentative approval and in the final
' design of the project, a Final Drainage Report will be prepared by the applicant
containing all details to be incorporated in the design. CalTrans will have • an
opportunity at that time to review the final design and make a determination of the
' effectiveness of the .storm water management devices. If the facilities do not meet
CalTrans' requirements, they may require changes and re- submittal of the drainage
documentation. Appendix B is a copy of a Preliminary Drainage Plan.
Response to Comment 2 -13
The commentor recommends that MM 4.6.7 be modified to require the Final Master •
Drainage Plan to include area -by -area site mitigation for drainage modifications as
runoff from one area of the project site might have an impact of the State's highway
right -of -way up gradient of a proposed BMP detention basin. MM 4.6.7 in the Hydrology
and Water Quality section (4.6) states that the Drainage "plan shall be consistent with
standards and guidelines established by the Lahontan Regional Water Quality Control
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -64 September 2003
2.0 RESPONSE TO COMMENTS
Board (RWQCB) and Caltrans. Both the Lahontan RWQCB and Caltrans shall be given '
an opportunity to review the final design and make a determination of the
effectiveness of the proposed drainage facilities. If the facilities do not meet Lahontan
RWQCB or Caltrans requirements, they may require changes and re- submittal of the
drainage documentation." The requirements of MM 4.6.7 provide Caltrans the authority
to require the Final Master Drainage Plan to include area -by -area site mitigation for
drainage modifications if Caltrans determines that the initially submitted drainage plan ,
does not meet its requirements. MM 4.6.7 does not need to be modified for Caltrans to
receive this consideration. Attached as Appendix B is a copy of a Preliminary Drainage
Plan. Per MM 4.6.7, Caltrans will have the opportunity to review and approve the final
drainage plan (including engineered drainage calculations based on the final project
design) to ensure that it meets their standards.
Response to Comment 2 -14
See Response to Comment 2 -13 and 1 -20. If drainage facilities do not meet Caltrans '
requirements, Caltrans may require changes and re- submittal of the drainage
documentation, including the addition of a BMP. Please see also Appendix I, which
provides a list of all BMPs compiled to date for the project. This list does not limit the
possibility that additional BMPs will be added during the permitting process with
Caltrans.
Response to Comment 2 -15
Comment is noted and provided here for the consideration of the Town Council. The ,
Final Drainage Plan and SWPPP will be provided to CalTrans at District 3 Hydraulics
Branch in Marysville after engineered plans for the project are finalized, which will be
accomplished after final project approval.
Response to Comment 2 -16
This comment indicates that Caltrans Encroachment Permits will be required for work
conducted in the State's right -of -way. Comment is noted and provided here for the
consideration of the Town Council. Section 1.3 of the Draft EIR includes Caltrans
Encroachment Permits among subsequent approvals required for the proposed project.
A Caltrans encroachment permit will be required for repairs and improvements within
the SR 267, SR 89, and 1 -80 right -of -way, and MM 4.6.7 requires Caltrans review and
approval of drainage plans. The project applicant would be required to comply with
all requirements and conditions pertaining to the receipt of an encroachment permit.
Response to Comment 2 -17
The commentor requests a copy of the final environmental impact report for this project
from the Town of Truckee. A copy of the Final EIR prepared for the proposed project will
be forwarded to the party indicated. The comment is noted and is included here for
the consideration of the Town Council. ,
Town of Truckee Final Environmental Impact Report
September 2003 2 -65 Gray's Crossing Specific Plan Project
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1 • AU r,. • - . • -
A �iRAY QAVJS f v rn4[
DEPARTMENT OF FISH AND GAME
I SACRAMENTO VALLEY AND CENTRAL SIERRA REGION
1701 NIMBUS ROAD, SUITE A
RANCHO CORDOVA, CALIFORNIA 95670 Fp
Telephone (916) 358-2900
Wee
flex • R • s d )�r G '
Jul 2 2 2003 POwEe
' July 15, 2003 LETTER 3
Ms. Heidi Scoble, Associate Planner
Town of Truckee
' 10183 Truckee Airport Road
Truckee, CA 96161
Dear Ms. Scoble:
The Department of Fish and Game (DFG) has reviewed the Draft Environmental
Impact Report (DEIR) for Gray's Crossing Specific Plan/Tentative Map
' (SCH# 2002072115). The project proposes development of a 757 -acre site into a
planned development comprised of commercial and residential uses including a golf
' course. The site is located just north of Interstate 80 and is bisected by
State Highway 89 in the Town of Truckee, Nevada County.
3 -1
' Significant resources of the project site include habitat for sensitive species and
movement areas for local resident wildlife. Habitats of the project site, dominated by an
overstory of pine with an understory of sagebrush bitterbrush and grasses, although not
' unique, are locally and regionally significant and further loss of these habitats is viewed
by the DFG as a significant impact. The DEIR has identified a series of mitigation
measures designed to reduce project impacts to vegetation and wildlife and the
' document further concludes that project impacts to vegetation and wildlife, with
incorporation of the identified mitigation measures, will be reduced to levels of less than
significant.
' Mitigation measures for project impacts to vegetation and wildlife as identified in
the DEIR reflect measures designed solely to avoid direct impacts to special status
species during project construction. Alternatively, mitigation measures for impacts to
the habitats of the project site are deemed not to be warranted due to the common
' nature of the habitat. m.We.disagreewithpconclusions and° m( tigations .measures;identified, » ,
in this an&wildlife^andlihd'the documehtinadequate ^ands 3 -2
incomplete. While identified mitigation measures may reduce direct project impacts
' during project construction the value of retained areas subsequent to project
construction, due to indirect impacts and the direct loss of habitat currently occupied by
both sensitive and local endemic wildlife will be irretrievably lost. The°documenthas
' failed to, identify any.,, measures-. designed to:mitigate direct mdir'ect; andwumulative
project.impacts to the .many: hundreds,of,acre& natives habitatand:associated
species directly, indirectly and„ cumulatively „impacted'as °a °result of project`
' implementation.
Ms. Scoble I
July 15, 2003
Page 2
We believe that the failure of this DEIR to identify additional reasonable and 3 -3
feasible mitigation measures for project impacts to native habitat and sensitive species
results in direct, indirect and cumulative project impacts to native habitat and associated
species and movement corridors for local resident species to remain significant.
We suggest development of a mitigation measure that allows for the creation of a
land acquisition /easement program and the creation of a mechanism by which land is
acquired via developer fees and other funding sources. This can be a parcel or acre 3 -4
based program. This program would focus on acquisition (fee title or easement) and
management in perpetuity of adequately sized and suitable habitat areas for all wildlife
species within a reasonable distance from the project site. The DFG believes this to be
a reasonable and feasible mitigation measure.
Additionally, we suggest that acres of Open Space be recalculated to reflect
those sites potentially available and useful to the array of wildlife using the site, such as
those open space areas situated on the perimeter of the project, and those open space 3 -5 II
areas that will be significantly compromised, such as those open space areas
intermingled with urban use including the golf course. This type of accounting will
allow for a more reasonable measurement of project impacts to both sensitive and more
common wildlife within the project site.
Thank you for the opportunity to review this project. If we can be of further
assistance, please contact Mr. Jeff Finn at (530) 477 -0308 or Ms. Terry Roscoe, Habitat
Conservation Planning Supervisor at (916) 358 -2382. I
.,SincereG%; '
Ir
,I 1
J. Larry . j , Ph.D.
U Deputy ' - gional Manager
cc: Ms. Terry Roscoe
Mr. Jeff Finn
Mr. Jim Lidberg '
Department of Fish and Game
Sacramento Valley - Central Sierra Region
1701 Nimbus Road, Suite A
Rancho Cordova, California 95670
State Clearinghouse I
1400 Tenth Street
Post Office Box 3044
Sacramento, CA 95812 -3044 (only if came from clearinghouse) I
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2.O RESPONSE TO COMMENTS
LETTER 3 LARRY L. ENG, PH.D., CALIFORNIA DEPARTMENT OF FISH AND GAME
1
Response to Comment 3 -1
This comment generally describes environmental review for the project and the
project's location and setting. Since this comment does not address the adequacy of
the Draft EIR, no further response is required.
Response to Comment 3 -2
' The commentor disagrees with the conclusions and mitigation measures identified in
the Draft EIR for vegetation and wildlife, especially as habitat for these species will be
irretrievably lost with development of the project. The commentor also suggests that
the Draft EIR concludes that mitigation for impacts to common habitat is deemed to be
unwarranted. See Master Response 2.4.4 Biological Resources, especially as it relates to
the provision of a Natural Resource Management Plan (see Appendix A) that strives to
reduce impacts to common habitat and species.
Response to Comment 3 -3
The commentor believes additional mitigation measuw need to be identified in the
Draft EIR to protect native habitat and sensitive. species. See Master Response 2.4.4
' Biological Resources and Responses to Comments 3-4 and 3 -5.
Response to Comment 3 -4
1 The commentor suggests that an additional mitigation measure be developed that
allows for the creation of a land acquisition /easement program and the creation of a
mechanism by which land is acquired via developer fees and other funding sources.
See Master Response 2.4.4 Biological Resources. In addition, below is some additional
information pertaining to the history of the land exchange between the Hopkins Trust
and the U.S. Forest Service, which included the PC -2 site.
The PC -2 property was previously part of a land transfer between the U.S. Forest Service
' (USFS) and the Hopkins Land Trust that took place in 1983. At that time, the Hopkins
Land Trust agreed to exchange two large parcels totaling 11,007.94 acres (2,248.59
acres in Sierra County and 8,759.35 acres in Nevada County), and determined to be
' high quality wildlife habitat surrounded by existing USFS, for 2,190.38 acres of USFS land
• (437.5 acres located in Placer County and 1,752.88 acres located in Nevada County,
and both located in the vicinity of Truckee), that was determined to be less biologically
valuable and adjacent to urbanizing areas. The land transfer represented over a 5:1
exchange ratio. According to the Environmental Assessment (EA) prepared by the USFS
for the land exchange, the USFS acknowledged that Federal lands to be provided to
the Hopkins Land Trust would most likely be developed for commercial and residential
uses, but that it was an appropriate action in light of the significantly larger tracts of key
wildlife habitat and recreational use areas that the USFS would receive in exchange.
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -66 September 2003
2.0 RESPONSE TO COMMENTS I
Taken from the land exchange EA, below is a verbatim wildlife comparison of the '
Federal lands (which are now private and include the: PC-2 site) and the non - Federal
lands (previously the Hopkins Land Trust parcels):
Non - Federal - The lands contain a number of key wildlife habitat areas. These
sites are essentially meadow and grasslands located along major water courses,
around springs, and in the flats lying southerly of Russell Valley. These riparian
areas are used by ducks for spring nesting and by deer for fawning.
Three deer migration routes pass through the non - Federal lands. The deer utilize '
these routes in the fall returning to their winter habitat east of the Verdi Range.
Bald eagles (on the Federal endangered species list) have been observed. Also, 1
golden eagles, peregrine falcons, prairie falcons, osprey, and goshawk (on the
USFS sensitive list) have been observed in the area. No nesting sites have been
found, however.
Federal - The lands contain no key wildlife habitat areas. Bald and golden
eagles have been observed over the area, but no nesting sites have been
found.
It is unclear if the observations of bald or golden eagles discussed above took place '
over the PC -2 site or on the other approximately 1,400 acres of Federal land that was
part of the exchange. '
The provision of this information simply points out that in 1983, large tracts of private
land, which contain more valuable and diverse wildlife habitat, were exchanged with
the USFS for Federal land (which contained the PC -2 site) with less valuable and diverse
habitat at a 5:1 ratio. A key factor in the USFS decision to participate in the land
exchange was that its land was less valuable from a wildlife habitat perspective. Even
though the land would be developed in the future, the USFS realized it was worth the
exchange to receive a significantly greater amount of land with higher quality wildlife
habitat. In effect, dedication of wildlife habitat at a 5:1 ratio was provided to offset the
habitat that would be lost to development as part of the land exchange.
Response to Comment 3 -5 ,
The commentor would like to see a recalculation of Open Space, which reflects areas
on -site potentially available and useful to wildlife, such as areas situated on the
perimeter of the project, and those areas that will be compromised, including areas
intermingled with urban uses and the golf course. Figure 4.7 -3 found on page 4.7 -23 of •
the Draft EIR provides a graphic representation of open space areas that would be
more compromised by development, as well as larger more undisturbed tracts of open
space. Due to the broad range of objectivity regarding assumptions that would need
to be made in order to provide additional calculations of "useful" and "compromised"
open space, and as there was not a great level of detail provided by the commentor
regarding what standards should be used to meet those thresholds, it is suggested that
the commentor make estimations utilizing the Habitat Disturbance Map already
•
Town of Truckee Final Environmental Impact Report
September 2003 2 -67 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
provided by Figure 4.7 -3. Finally, the provision of this additional information would not
result in changes to any conclusions reached in the Draft EIR. Please see also Master
1 Response 2.4.4 Biological Resources.
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Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 - September 2003
I STATE OF CALIFORNIA —THE RESOURCES AGENCY GRAY DAVIS, Governor
I DEPARTMENT OF FORESTRY AND FIRE PROTECTION
Nevada - Yuba - Placer Unit �
1
qt
3760 Lincoln Way "
Auburn, CA 95603
I Website: www.fire.ca.gov alt {t; 1 - 20
(530) 823-4904 LETTER 4
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1 July 29,2003
1 TO: Heidi Scoble
Town of Truckee Planning Department
I RE: Gray's Crossing Draft Environmental Impact Report
I This project will require a Timberland Conversion and Timber Harvest Plan as per the
following:
IN California Code of Regulations, per section 1103, and Public Resources Code 4581 requires a
Timberland Conversion Permit and /or Timber Harvest Plan be filed with the Califomia
Department of Forestry and Fire Protection if the project involves the removal of a crop of trees of
1 commercial species (regardless of size of trees or if trees are commercially harvested).
4 -1
I The Timberland Conversion Permit shall address the following:
a. The decrease in timber base in the county as a result of the project.
b. The cover type, including commercial species, density, age, and size composition affected by the project.
c. The ground slopes and aspects of the area affected by the project.
d. The soil types affected by the project.
e. Any significant problems that may affect the conversion.
1 If you require further clarification, please contact Forester Jeff Dowling at (530) 587 -8926.
1 Sincerely,
TONY CLARABUT
1 Unit Chief
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Jeff Dowling
c
Truckee Area Forester
jd
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CONSERVATION IS WISE -KEEP CALIFORNIA GREEN AND GOLDEN
1 PLEASE REMEMBER TO CONSERVE ENERGY. FOR TIPS AND INFORMATION, VISIT "FLEX YOUR POWER" AT W W W.CA.GOV.
2.0 RESPONSE TO COMMENTS
1
LETTER 4 JEFF DOWLING, CALIFORNIA DEPARTMENT OF FORESTRY AND FIRE PROTECTION
1
Response to Comment 4 -1
1 The commentor states that a Timberland Conversion Permit and /or Timber Harvest Plan
is required by the California Department of Forestry and Fire protection, per California
Code of Regulations, Section 1103, and Public Resources Code 4581 for the proposed
project. The applicant has submitted an application for a Timber Harvest Plan (THP)
with California Department of Forestry and Fire Protection (CDF). The application has
been received by CDF and given a permit number - No. 2- 03- 117 -NEV. The Draft EIR
recognizes the need to comply with this requirement pursuant to the California Code of
Regulations and the Public Resources Code (Draft EIR page 3 -47).
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Town of Truckee Final Environmental Impact Report
1 September 2003 2 -69 Gray's Crossing Specific Plan Project
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I . -
Town Council Department Heads
1 Town OF Stephen L. Wright, Manager
T ed O wens, M ayor TR;JC-KE p Boon Josh Susman, Vice Mayor Dan Boon, Chief of Police
J. Dennis Boon Town Attorney
Tony Lashbmok, Community Development
I
R onald Florian, Councilmember ••. - — °�T z_� F * . ' David M. Heath, Administrative Services Director
' ,_ Jl-.-i'w•_ _. ' ' •' Patt Osbome, CMC, Town Clerk
Craig Threshie, Councilmember �'• 4. ,, i • � ..
Beth Ingalls, Councilmember `'••. = ^� ,•••`.� Alex Tenazas, Assistant Town Manager
Daniel Wilkins, Public Works Director/TownEnginee
1 LETTER 5
1
July 28, 2003
i Town of Truckee
Attn: Mayor Ted Owens
I 10183 Truckee Airport Road
Truckee, CA 96161
1 . RE: Comments on the Gray's Crossing (AKA PC -2) Draft Environmental Impact Report
(EIR)
Dear Mr. Owens:
1
On July 9, 2003, the Planning Commission publicly reviewed the Draft EIR and
collectively commented on the content of the environmental document. The
I Commission requests responses to the following comments regarding the environmental
document prepared for the Gray's Crossing Specific Plan: •
I 1. Water Conservations Measures. The Commission is requesting
information on any and all water conservation measures that have been or
will be incorporated into all components of the plan (i.e., golf course, village, 5-1
I residential subdivision, attached housing, etc.). This would include
information on mitigation monitoring (i.e., who is responsible for monitoring
and who is responsible for enforcing the mitigation measures).
1 2. Groundwater Recharge. The Commission is requesting additional
information on how the ground water recharge system works and whether the
recharge system would have a significant impact on water quality?
I Additionally, the Draft EIR stated that the golf course will be part of the
groundwater recharge system. The Commission is requesting additional
information on this statement based on the fact that golf courses are known 5 -2
I for its high evapotransporation rates and the Commission does not
understand how a golf course can also be a recharge system and still
balance out the groundwater recharge. Furthermore, the Commission is
requesting information on whether there is actually a balance of recharge for
the golf course areas, or, is the balance expected to be covered by spring
water runoff recharge from snow melt. Please provide clarity and specificity
1 on this issue.
3. Groundwater Protection- Golf Course. The Commission is requesting
1 information on the types of fertilizers (i.e., petro- chemicals vs. organic 5 -3
sources) that are proposed to be used for the golf course. The Commission
is also requesting information on how the fertilizers will be regulated and any
1 monitoring policies that will be incorporated into the golf course maintenance
Gray's Crossing Draft EIR Comments -
July 28, 2003
program. Lastly, the Draft EIR makes reference to CHAMPS for the
maintenance of the golf course. Have CHAMPS for the subject golf course
been prepared, and if so, can additional documentation regarding the
CHAMPS be forwarded to the Commission for review? If no CHAMPS have
been prepared, can a sample CHAMP be included as part of the EIR. This
will help better familiarize the reader with the type of program being
proposed.
4. Location o f a ttached Housing. The Commission has concerns with the
location of the proposed attached housing as it relates to its close proximity to
State Route 89N and the potential negative quality of life impacts relating to 5-4
aesthetics and noise. The Commission is requesting detailed information on
the exact distance the attached housing will be from the highway, and how
any negative noise and aesthetics impacts may be mitigated.
5. Affordable Housing. The Commission i s requesting s pecific a nd detailed
information on the proposed affordable housing program as it relates to the
number and types of units (i.e., 1,2,3, and 4 bedroom units), the number of
saleable units, the number of rentable units, occupancy (i.e., single rate
occupancy vs. families), and the affordability target (i.e., very low, low 5 -5
median, and 120% median). The Draft EIR also has made a statement that
the generated demand for affordable housing for full -time and part-time
employees is less than significant. The Commission believes that the impact
on employee /affordable housing may be greater than the Draft EIR eludes.
Therefore, the Commission would like additional information to support that
statement.
6. Employee Housing. The Commission is requesting detailed information on
the need for employee housing generate by the project to verify that the
project is meeting the employee housing needs as it relates to units, costs,
and target market (i.e., single room occupancy vs. families). The
Commission is also requesting more specific information on the timing of the 5 -6
construction of the employee housing. Furthermore, the Commission is
concerned with the potential of passing over the Old Greenwood units into
the I ater p hases of the Gray's C rossing d evelopment. The C ommission i s
requesting specific information on the exact timing and phasing of the OId
Greenwood units.
If you have any questions regarding the aforementioned comments and requests for
additional information, please do not hesitate to contact Heidi Scoble, Associate
Planner.
1
Sincerely,
Bob Jensen
Chair,
Town of Truckee Planning Commission
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2.0 RESPONSE TO COMMENTS
LETTER 5 TOWN OF TRUCKEE PLANNING COMMISSION
Response to Comment 5 -1
1 The commentor requests additional information regarding proposed water
conservation measures that will be incorporated into the project. The greatest
potential for conservation of water is through judicious operation of golf course
irrigation. Attached as Appendix A is a Draft of the Audubon International Natural
Resource Management Plan (NRMP) as required by MM 4.7.2. Section 6.0 of the NRMP
is entitled Water Conservation Management. This section details strategies for
conserving water and protecting water quality through the use of existing soils and
weather data in conjunction with monitoring and operational /irrigation system design.
' The effectiveness of the NRMP will be monitored by the Town and the Lahontan
RWQCB, as the requirement for a CHAMP has been incorporated into the NRMP.
Further, there is a comprehensive water quality monitoring program included in the
NRMP that will be reviewed and approved by the Lahontan RWQCB. See also Master
Response 2.4.3 Water Quality and Response to Comment 1 -6. Response to Comment
16 -8 discusses the use of drought tolerant landscaping as required by the Landscaping
1 Design Program provided in the Specific Plan, which will further reduce water
consumption. As part of the Audubon International Signature Program that the
applicant must adhere to, buildings will be constructed to meet the objectives of the
U.S. Green Building Council's LEED (Leadership in Energy & Environmental Design)
program: A key component of the LEED program is water conservation.
1 All mitigation measures proposed as part of the Draft EIR have a provision detailing
which authority is responsible for enforcing the mitigation measures.
' Response to Comment 5 -2
The commentor requests additional information on how the groundwater recharge
system works and whether the recharge system would have a significant impact on
1 water quality.
As to the role the golf course will play in recharging groundwater, please see Response
1 to Comment 1 -16. In addition, please see Master Response 2.4.7 Water Supply and
Master Response 2.4.3 Water Quality. The project will not have a significant impact on
water quality.. Through the use of detention basins, runoff will be retained on -site in a
1 manner consistent with pre - development levels (see Appendix B - Preliminary Drainage
Plan). Per MM 4.6.7, the Lahontan Regional Board, Caltrans, and the Town of Truckee
will have the opportunity to review and approve a final drainage plan (including
engineered drainage calculations based on the final project design) to ensure that it
meets their standards.
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Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -70 September 2003
•
2.0 RESPONSE TO COMMENTS '
Response to Comment 5 -3 1
This commentor requests additional information on types of fertilizers proposed for use
on the golf course and information on how fertilizer use will be regulated and
monitored. This comment also requests additional information on the project's
proposed CHAMP.
Attached as Appendix A, is a copy of the Audubon International Institute's Draft
Natural Resource Management Plan (NRMP) for the Gray's Crossing project - a
mitigation requirement of the Draft EIR. A Final NRMP will be developed and available
for review and input by the Town and Lahontan RWQCB. The Lahontan RWQCB will
receive a copy of the NRMP for its review and input as the applicant has chosen to
incorporate the requirements of the CHAMP required by MM 4.6.4 in the Draft EIR into
the NRMP in order to have a comprehensive single- source management plan for the
Gray's Crossing project. Per MM 4.6.4, a project specific CHAMP, or similar
management plan, is required to be reviewed and approved by the Lahontan RWQCB,
Nevada County, and Town of Truckee. Further, per the mitigation measure, if the
CHAMP, or similar program, does not meet the Town's, County's, or Regional Board's ,
requirements, those agencies may require changes and re- submittal of the CHAMP - or
as is the case now, the NRMP. Specific to the use of fertilizers and monitoring, the
commentor is asked to review in particular Sections 4.0 Best Management Practices,
Section 5.0 Integrated Pest Management, Section 7.0 Water Quality Monitoring, and
Section 8.0 Maintenance Facility of the Draft NRMP. These sections spells out protocols
for the .types of fertilizers and pesticides that will utilized, application and irrigation
strategies to reduce water quality impacts, handling procedures, and monitoring
protocols. The Final NRMP will provide a list and description of chemicals authorized for
use on the project site, including all fertilizers, herbicides, fungicides, insecticides and
rodenticides, along with guidelines for their application (Draft EIR, MM 4.6.4). The Town
and Lahontan RWQCB will have an opportunity to provide further input into the
acceptability of the NRMP when a Final NRMP is provided as required by MM 4.6.4
(discussed above).
The intent of the project applicant is that the Gray's Crossing golf course utilize organic
farming techniques to support the growth medium so the soil will, in turn, support the turf
(Draft EIR page 4.6 -18). Fertilizing practices and state of the art irrigation techniques are •
discussed in the Draft EIR on pages 4.6 -19 to 22. With respect to pesticide use, the EIR
states that the project will use only chemicals and chemical application techniques
authorized by the State of California (Draft EIR page 4.6 -20).
Response to Comment 5 -4 1
This comment requests further discussion of noise and aesthetic impacts due to the
proximity of the project's attached housing units to State Route (SR) 89. Noise and
aesthetic impacts to these units are discussed in the Draft EIR on pages 4.3 -3 to 5 and
4.9 -7, 13 to 15. The Draft EIR's analysis of noise impacts involved noise surveys
conducted both before and after construction of the'SR 267 Bypass was completed
(Draft EIR page 4.3 -3). Noise measurement site locations shown in Figure 4.3-2 represent
the approximate locations of the nearest proposed noise - sensitive land uses within the
Town of Truckee Final Environmental Impact Report
September 2003 2 -71 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
project site to 1 -80 and SR -89 (see Draft EIR page 4.3 -5). Noise measurement were taken
in the area of the attached employee /affordable housing complex - noted as Sites 4
and 5. Based on the Tentative Map, the affordable /employee housing complex is
approximately 150 feet from SR 89.
After determining existing noise levels, the Federal Highway Administration Highway
Traffic Noise Prediction Model (FHWA RD_77_108) was used to predict future noise levels
due to traffic at these and other sites. The FHWA model is the analytical method
favored for highway traffic noise prediction by most state and local agencies (Draft EIR
page 4.3 -12 to 13). Measurements of existing noise levels were then compared to
extrapolated future noise levels to determine if increases in noise constituted a
significant impact. The Draft EIR found increases in noise to be less than significant. As
explained on page 4.3 -22, project - generated traffic is expected to result in traffic noise
level increases ranging from 0 dB to 1 dB relative to no- project levels, as indicated by
Table 4.3 -6. Because of this relatively small increase in traffic and the distance from
these roadways to the existing noise sensitive uses, including the attached residential
units, the Draft EIR considered this impact to be less than significant (Draft EIR, Impact
4.3.1).
Additionally, visual resource mitigation measures designed to screen these units from SR
89 will further reduce noise impacts (Draft EIR page 4.3 -24 to 25). Specifically, MM
4.9.2b requires significant vegetative screening and the construction of berms that
would both lessen aesthetic impacts and reduce noise (Draft EIR page 4.9 -14). The
location of these berms and the proximity of attached units to SR 89 are shown in Figure
3 -9 of the Draft EIR. Per the request of the Town, the applicant has provided subsequent
proposed visual treatments for SR 89 in . the vicinity of the Village Center and
affordable /employee housing complex. Please see Response to Comment 6 -17 and
Appendix IC for details of this discussion. Finally, as the affordable /employee housing
structures are currently situated, any exterior activity areas would be placed on the
east side of the buildings away from roadway noise.
Response to Comment 5 -5
The commentor requests additional information regarding the affordable housing
program. See Master Response 2.4.1 Employee /Affordable Housing. The significance
determination was based on previous Town criteria for other projects or those created
specifically for the PC -2 site. There are no generally accepted standards for the
provision of affordable housing for full -time and part -time employees. This is a policy
1 issue as discussed in more detail in Master Response 2.4.1 Employee /Affordable
Housing.
Response to Comment 5 -6
The commentor requests additional information regarding the employee housing
program. See the Master Response 2.4.1 Employee /Affordable Housing.
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -72 September
Town Council Department Heads
' TOWN OF Stephen L. Wright, Manager
Ted Owens, Mayor TWOUE p Dan , Chiefo Police
Josh Susman, Vice Mayor Boon J. Dennis Boon Town o ffomey
Tony Lashbrook, Community Development
•
Ronald Florian, Councilmember •• - — —Jr '�- — — T f > ..' David M. Heath, Administrative Services Director
Craig iFi Councilmember • � � ' v, li � �� I) m" .� • �� Part Osbome, CMC, Town Clerk
Beth Ingalls, Councilmember •''•� � �� � ..... Ale Terrazas, Assistant Town Manager
Daniel Wilkins, Public Works Director TownEnginee
1 LETTER 6 •
•
III
August 8, 2003
I Town of Truckee Community Development Department
Attn: Heidi Scoble, Associate Planner .
10183 Truckee Airport Road
Truckee, CA 96161
RE: Comments on the Gray's Crossing (AKA PC -2) Draft Environmental Impact Report
1 (EIR)
Dear Ms. Scoble:
On August 7, 2003, the Town Council had an opportunity to publicly review the Draft EIR
and collectively commented on the content of the environmental document. The Council
I has determined that additional information and /or clarity is necessary in order prior to
final review of the environmental document. The Council makes the following comments
on the Draft EIR:
1 1. Water Supply. The Town Council is requesting additional information on
whether the project is consistent with the State requirements for water supply 6 -1
I assessment. Specifically, whether Section 10910 of the State of California
Water Code is being met. Detailed information on the project's compliance
with the aforementioned requirement is being requested.
2. Water Quality -Golf Course. In order to get a better understanding on the
water quality impacts associated with the golf course, the council is 6 -2
requesting that a sample CHAMP and the Natural Resource Management
I Program be included in the Final EIR. The Council would also like more • detailed information on the effects of water quality impacts on greens and •
fairways as it relates to drainage and the use of chemicals.
1 3. Water Quality. The Council is requesting that the EIR address the
environmental impacts of landscaping as it relates to water quality, on all
I man -made landscaped lands outside of the areas covered by the CHAMPS.
The Council is also interested in the chemical management of these areas, in •
addition to the impacts of the utilization of turf. Please address the impacts of
I these items in greater detail. Additionally, the Council is requesting
confirmation that the Specific Plan and EIR have addressed all impacts the
land development may have on the water quality for the surrounding areas.
I . 4. Drainage Plan. Due to the environmental sensitivity of the site and its W 6-4
proximity to jurisdictional waters of the state, the Council is requesting
- Gray's Crossing Draft EIR Comments
Town Council
additional information on the adequacy and drainage plan as it relates to golf t ,
course construction.
5. Biology - Flora. The Council is requesting the EIR to comment on the 6 -5 1
impacts of the likely introduction of non - native invasive plant species in the
community and to address any appropriate mitigation measures to reduce the ;
potential impacts to a less than significant level.
6. Cultural Resources. The Council is requesting the EIR to delve further and vi
study the fiscal impact of the recreational amenities of the project and how it 6 -6
will relate financially to the project. Specifically, the Council is requesting
information on whether there would be a direct correlation of an increase in
•
III
lodging if golf and other recreational amenities were available.
7. Noise Contours. The Town Council is requesting additional information on
whether the established noise contours along State Route 89 North will 6-7
negatively impacts the proposed attached housing within the corridor and
whether additional mitigation measures is warranted.
8. Noise Cont. The Council is requesting additional analysis on the impacts of 1
landscaping maintenance equipment on the development and the 6 -8
surrounding land uses, and whether sufficient mitigation has been
incorporated into the plan to address these impacts.
9. Air Quality. The Council is requesting information on how the Gray's E-
Crossing Specific Plan is meeting Objective 5 of the Town's Particulate
Matter Air Quality Management Plan. Objective 5 states that, "innovative
technologies for h eating a nd b uilding e nergy conservation p ractices w ill be '
encouraged to reduce reliance on solid fuel burning devices which generate 6 -9
particulate matter emissions." Has an assessment been undertaken by the
project proponents to include a feasibility study on alternative energy
practices to be incorporated into the project (i.e., solar hot water heaters, use
of photovoltaic cells /panels, etc.), or has the project applicant established any
renewable energy programs that could be implemented into the development
to mitigate potential air quality impacts? 1
10. Air Quality- Vehicle Emissions. The Council is requesting more specificity
on the maintenance fleet as it relates to potential a missions released from
vehicle use. Specifically, the Council is requesting information on the s iz
and type of golf course fleet (i.e., carts, lawn mowers, or any other 6-10
mechanical operating device necessary in the maintenance of the course and
souring greens), and a thorough description of how these items will be used.
Furthermore, the Council is requesting an estimation of the hours of
operation /use of the maintenance vehicles used to maintain the golf course
fairways and greens.
11. Deer Migration Corridor. The Council is requesting more documentation on ,
the Loyalton deer migration corridor and the project's impacts on the 6 -11
migration corridor and whether sufficient mitigation is being supplied.
1
1
- Gray's Crossing Draft EIR Comments
Town Council
I 12. Natural Resource Management Plan. The Council is requesting additional 6 -12
information on the Natural Resource Management Plan and what it consists
of?
13. Audubon Designation. The Council is requesting additional information on 6_
who maintains the Audubon classification as it relates to compliance with the
Natural Resource Management Plan, and particularly if Audubon International
becomes defunct?
14. Employee Housing. The Council would like clarification on who is going to ( 6 -14
manage, operate, and maintain the employee housing units?
15. Full Time Employees. The council is requesting additional information on
the 168 Full Time Employees referenced in the Draft EIR. The Council would
t e correlation bs 6-15
the like a actual bet r number understanding of employees onl the c that would etween be re the quired 168 to FTE run ver the
• development. Specifically, how many employees would be necessary for 168
posititions (i.e., full or part time).
16. Public Utility Capacity. The Council would additional information on the
whether the affected utility companies (TDPUD, TSD, USA, Southwest Gas,
etc.), will have sufficient capacity throughout the phasing and construction of
the development. Specifically, the Council is most interested in water 6 -16
capacity and sewage treatment. Furthermore, the Council is interested in the
cumulative impacts on the increased usage of these utilities on existing
community and whether there are sufficient guarantees or practices in place
to ensure the community will not be negatively impacted by the increased
usages of the utilities.
17. Visual Resources. In order to ensure that the development will not
negatively impact the scenic corridor, the Council is requesting more
specification, above and beyond the photo simulation to ensure the protection
of these designated areas. This information could include details on
landscaping (materials and maintenance), berming (i.e., height, amount of 6d7
' soil, d imensions), I ocation of b uilding structures, a list of b uilding m aterials
and colors, and the buildings proximity to the scenic corridor. Specifically, a
cross - section of the subject area could be prepared and utilized to indicate
the effectiveness of berming and landscaping. Additionally, a more accurate
photo simulation could be useful to satisfy the Council's concerns.
18. Alternatives. The Council would like to know why a "No Golf Course" I 6 -18
• Alternative was not included in the Draft EIR?
Thank you for you consideration on addressing these items in the Final EIR.
Sincerely,
Ted Owens
Mayor
1
2.0 RESPONSE TO COMMENTS
LETTER 6 TED OWENS, MAYOR, TOWN OF TRUCKEE COUNCIL
1
. .Response to Comment 6 -1
The commentor requests additional information regarding wafer supply and
consistency with state requirements for water supply. The commentor is referred to
1 Master Response 2.4.7 Water Supply.
. Response to Comment 6 -2
The commentor requests additional information regarding the proposed CHAMP and
NRMP, as well as further insight regarding the effects of water quality impacts on greens
and fairways. Please see Master Response 2.4.3 Water Quality and Appendix A, as well
as Response to Comments 1 -11 and 5 -3. Details regarding the type and use of golf
course fertilizers, herbicides, and pesticides, as well as detailed BMPs for reducing golf
course operation effects on water quality are provided in the NRMP (or CHAMP).
Response to Comment 6 -3
The commentor requests more information regarding the environmental impacts of
landscaping as it relates to water quality. Specific details regarding the maintenance
of landscaped lands located outside the areas proposed to be covered by the CHAMP
are set forth in the Chapter V of the Specific Plan (Landscape Design Program). It is not
clear what the specific concern is related to water quality and landscaping. The
project will utilize retention basins to ensure that runoff during storm events is retained
and has the opportunity to be filtered, evaporated and /or settled out in the basin. In
addition, a series of temporary and permanent BMPs have been proposed by the
applicant, which will be reviewed and approved by the Lahontan RWQCB (see
Appendix 1). This list does not preclude the use of additional BMPs. See also Response
to Comment 16 -8 and the Landscaping Design Program (Chapter V) of the Specific
Plan regarding limitations on landscaping and artificial turf in each of the land use
zones (i.e., Village Center, Residential).
The Draft EIR has addressed all the impacts that development of the proposed project
1 may have on water quality for the surrounding areas. The commentor is referred to
Section 4.6 Hydrology and Water Quality of the Draft EIR for additional information.
1 Response to Comment 6 -4
The commentor requests the provision of a drainage plan for the site. Please see
M Appendix B for a copy of a Preliminary Drainage Plan. Per MM 4.6.7, the Lahontan
Regional Board, Caltrans, and the Town of Truckee will have the opportunity to review
and approve the final drainage plan' (including engineered drainage calculations
based on the final project design) to ensure that it meets their standards. Please see
also Master Response 2.4.3 Water Quality.
1
Town of Truckee Final Environmental Impact Report
September 2 -73 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
Response to Comment 6 -5 1
The commentor requests information regarding the introduction of non - native invasive
plant species. See Response to Comment 16 -7. In general, while there is always a
minor possibility for the introduction of exotic or noxious plant species on -site during the
construction phase of the project, the impact is not considered "potentially significant"
in light of the fact that project areas will either not be disturbed at all, or if they are
disturbed, they will be subject to comprehensive landscaping guidelines requiring
replanting with native and /or drought tolerant species. The Landscape Program also
requires the applicant to provide for long -term landscaping maintenance of public
areas.
Response to Comment 6 -6 r
The commentor inquires if there is a direct correlation between an increase in lodging
use and the provision of golf and other recreation amenities. Please see the comments
provided by Economics Research Associates (ERA) in Appendix J. According to ERA, a
"nine -hole golf course does not contribute to a destination resort experience. The
consumer, when choosing a location for a vacation (or second home purchase),
carefully evaluates the extent and variety of recreational attributes offered by
competing destinations. The knowledgeable consumer, if golf is a significant part of the
decision making process, will always choose a location with a full length, championship
rated course over a destination without equivalent facilities." There is a direct
correlation between the availability of golf and an increase in lodging and conference
occupancies.
In addition, the applicant has reviewed and analyzed the no golf" and "reduced lot
size" alternatives. According to the applicant, the significant reductions in value and
revenues, as well as the limited market appeal and demand, associated with these
alternatives, and particularly a combination of the two, would reduce the project's
return to such a level the project would become infeasible economically. The
applicant has also stated that this loss of value and revenues would likewise result in the
inability to secure the community facilities district financing that is being pursued by the
project and any other financing that would be necessary for the viability of the project.
The applicant has also stated both alternatives fail to meet the objectives of the project
outlined in Section 3.5.
These alternatives will be considered by the Town Council when it considers the project.
The EIR analyzes the relative merits of these alternatives from the perspective of
environmental impacts. The Town Council may approve one or the other alternative, or
reject these alternatives if they are found to be infeasible or inconsistent with project
objectives. Any such determination will be based on the information set forth in the EIR,
or elsewhere in the record of proceedings. The applicant and the commenter may
submit information to the Town Council regarding the feasibility of these alternatives, or
the extent to which these alternatives meet project objectives.
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -74 September2003
2.0 RESPONSE TO COMMENTS
I Response to Comment 6 -7
As discussed in Section 4.3 (Noise) of the Draft EIR, future plus project noise levels are not
expected to exceed the exterior noise level standards for the Town of Truckee at the
proposed attached residential units. The affordable /employee housing units located at
the southernmost portion of the site would be exposed to future traffic noise levels in
excess of 60 dB Ldn. Due to the required setbacks, MM 4.9.2c (requiring berming and
vegetation screens), and the intervening topography (e.g., the depressed portion of 1-
II 80 at the SR 267 bypass), the future plus project noise levels are predicted to be 60 dB
Ldn or less (Draft EIR pages 4.3 -24 to -25). Other options for noise control were identified
in MM 4.3 -5a, but those options would only be required if the berm were not
1 constructed as proposed. Because the Draft EIR deemed the impact less than
significant no additional mitigation measures are required under CEQA.
See also Response to Comment 5 -4.
Response to Comment 6 -8
The commentor requests additional information on the effects of landscaping
maintenance equipment on residents and visitors at the project and surrounding land
uses. Noise impacts specifically associated with landscaping maintenance equipment
were not evaluated in the Draft EIR Noise Section. Because routine landscape
maintenance activities are a normal component in virtually all residential
developments, especially those near golf courses, there is a general expectation that
the local ambient noise environment will periodically include noise generated by such
activities. As a result, a separate analysis of noise impacts associated with such
maintenance activities was not believed to be necessary provided that the Town's
regulations with respect to hours of operations are adhered to. This situation is
somewhat analogous to traffic speeds. More specifically, if traffic speeds are routinely
well in excess of legal limits, traffic noise levels will be unusually high. Nonetheless,
separate noise impact statements specifically addressing the effects of elevated
vehicle speeds are not normally included in an EIR, as there is a presumption that the
rules pertaining to vehicle speeds will be reasonably enforced. The routine use of
landscaping maintenance equipment will not result in any potentially significant
impacts and no mitigation is required.
Response to Comment 6 -9
The commentor inquires how the project is meeting Objective 5 of the Town's
1 Particulate Matter Air Quality Management Plan, and if additional feasibility studies
have been undertaken on alternative energy practices. A portion of this comment
requests information regarding assessments or studies conducted by the project
1
applicant rather than commenting on the Draft EIR. As explained in Section 4.4 (Air
Quality) of the Draft EIR, the project will result in potentially significant air quality impacts '
from PM emissions, however, MMs 4.4.4a and b regarding restrictions on solid fuel
1 burning devices and fees for re- entrained road dust will reduce this impact to a less
than significant level (Draft EIR pages 4.4 -16 to -17). MM 4.4.4a, in particular, speaks to
' the goal of Objective 5 "to reduce reliance of solid fuel burning devices." In addition,
Town of Truckee Final Environmental Impact Report
September 2003 2 -75 Gray's Crossing Specific Plan Project
•
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2.0 RESPONSE TO COMMENTS
per the Draft Natural Resource Management Plan table of contents (see Appendix A), 1
there will be an entire section (9.0 - Waste Management and Energy Planning)
dedicated to conserving energy. Also part of the Audubon International Signature
Program that the applicant must adhere to, buildings will be constructed to meet the
objectives of the U.S. Green Building Council's LEED (Leadership in Energy &
Environmental Design) program. Per MM 4.7.2, the applicant will submit the NRMP to
the Town for their review.
Response to Comment 6 -10
The commentor requests additional information regarding the maintenance fleet as is
relates to potential emissions. In the Draft EIR golf course maintenance emissions were
estimated assuming that 6 motorized lawn maintenance vehicles would be used
(greens mower, fairway mower, rough mower and utility tractor) and on the typical day
they each would be used 4 hours. They were assumed to be powered by 50
horsepower engines.
Golf cart emissions were estimated assuming the use of 4- stroke gasoline - powered 9-
horsepower engines. Peak day golf cart use was estimated as 108 golf carts (2 carts
per foursome, 4 hours per round, operation from 9 am to 9 pm). Daily usage was based
on each golf cart traveling 2 miles per round at a speed of 10 mph. Resulting daily
usage was 21.6 hours. The daily usage, in horsepower- hours, was multiplied by the
maximum allowable emission rates for model 2003 golf carts in California.
As illustrated in Table 4.4 -6 of the Draft EIR, air quality impacts resulting from landscaping
activities alone have been considered and are less than significant (Draft EIR page 4.4-
14). MM 4.4.3 also requires that all golf carts be electric, and electric or alternatively
fueled equipment be used by the Community Services District for maintenance
purposes (Draft EIR page 4.4 -15). The Draft EIR found that the measures listed in MM
4.4.3 would eliminate emissions from golf carts and reduce emissions from landscaping,
vehicles and natural gas combustion by 5 -10 percent and result in a less than significant
impact.
See also Response to Comment 6 -8.
Response to Comment 6 -11
The commentor requests additional information regarding project impacts to the
Loyalton deer herd. The commentor is referred to the Master Response 2.4.4 Biological
Resources for additional information regarding the Loyalton deer herd and impacts
related to the proposed project.
Response to Comment 6 -12 1
The commentor requests additional information on the Natural Resource Management
Plan (NRMP). A preliminary draft NRMP, as well as the Ecological Design, is attached as
Appendix A for the Town Council's consideration. See also the Master Response 2.4.4
Biological Resources.
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -76 September 2003
2.0 RESPONSE TO COMMENTS
Response to Comment 6 -13
For additional information regarding maintenance of the Audubon classification and
compliance with the NRMP see Master Response 2.4.4 Biological Resources. Audubon
International is an established organization and the Audubon International Signature
I Program has been in place for over nine years (see www.audubonintl.org). The
program is therefore not in jeopardy of becoming defunct. If, for some reason in the
future the program were to become defunct, it would not effect implementation or
enforcement of the NRMP project because the plan will already have been prepared
and continuously implemented as specified in MM 4.7.2.
' Response to Comment 6 -14
The commentor inquires who will be managing and maintaining the employee housing
units. The commentor is referred to the Master Response 2.4.1 Employee /Affordable
Housing regarding what entity will likely manage, operate and maintain the employee
housing units.
1 Response to Comment 6 -15
The commentor requests additional information as to how many employees will be
required for the project. As explained in Section 4.12 (Population, Housing,
Socioeconomics), the project at buildout would have approximately 168 full -time
equivalent employees (Draft EIR page 4.12 -12, and Table 4.12 -7). The Draft EIR also
found that under a worst -case scenario for purposes of CEQA, approximately 235 total
full and part -time jobs could result from the proposed project.
1 Response to Comment 6 -16
The commentor requests additional information on whether affected utility companies
have sufficient capacity to meet the needs of the project, as well as future community
needs. All utilities have been contacted as part of the environmental review conducted
by the environmental consultant to determine if there were any potentially significant
impacts associated with supplying utility service to the proposed project. Section 4.11
summarizes correspondence and /or personal communications with the utilities and
spells out requirements, if any, that the applicant would need to meet in order to
1 receive service. All utilities have anticipated meeting the needs of the project, as well
as other planned growth in the Truckee area. Sufficient water capacity and sewage
treatment will be provided throughout the phasing and construction of the project as
1 illustrated in Chapter I of the Specific Plan (Specific Plan pages 3 -4). Most of the
required infrastructure improvements will be complete after Phase II.
1 Please see also Master Response 2.4.7 Water Supply.
Response to Comment 6 -17
1 The commentor requests additional specification regarding the applicant's intentions
for protecting the visual quality of the SR 89 corridor, and suggests that a cross section
or additional visual simulation could be provided for clarification. In Appendix K, the
Town of Truckee Final Environmental Impact Report
September 2003 2 -77 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
project applicant has provided different berming and landscaped screening options at 1
multiple locations along the SR corridor south of the Alder Drive /Prosser Dam Road /SR
89 intersection. The use of these screening treatments would further reduce visibility of
structures from passing motorist as shown by the cross sections. With regard to
proposed colors for project structures, the applicant has provided a series of graphic
representations of the anticipated architecture and style of the village center and
attached housing. Further, the Specific Plan details design guidelines for all structures
proposed for the project.
Response to Comment 6 -18
The "No Golf Course" alternative suggested by commentors was excluded from
consideration in the Draft EIR because it would not meet several of the . project
applicant's objectives to:
• Develop a neighborhood community consisting of mixed land uses, which
include open space, lodging, recreational amenities (such as a golf course and
trails), local residential uses, and a neighborhood oriented retail shopping area;
and to -
▪ Establish permanent employment opportunities and secondary jobs (Draft EIR
page 3 -20).
The alternatives discussion in the Draft EIR complies with CEQA because it considers a
"reasonable range" of alternatives (CEQA Guidelines § 15126.6(a)). The EIR need not
consider every conceivable alternative, but rather consider a "reasonable range" of '
potentially feasible alternatives that will foster informed decision - making and public
participation. The range of potential alternatives to the proposed project shall include
those alternatives that could feasibly accomplish most of the basic objectives of the
project and could avoid or substantially lessen one or more of the significant effects
(CEQA Guidelines § 15126.6(c)).
Regardless, a Cluster Alternative Concept, or "No Golf Course" alternative, was
provided by a commentor and was assessed in Response to Comment 10 -2.
1
•
1
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -78 September 2003
1
TAHOE-TRUCKEE SANITATION AGENCY LETTER 7
:111t,,,„
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A Pblic Agency
�PP
ti/ 7„� 13720 Joerger Drive Directors
Rt
! 2 8 2(�2UCKEE, CALIFORNIA 96161 O.R. Butterfield
s `s •; lA► ° � , P� /: (530) 587 -2525 • FAX (530) 587-5840 Dale Cox
Erik Henrikson
S. Lane Lewis
25 June 2003 John Shaw
Genera( Manager
Craig F. Woods
1
Ms. Heidi Scoble, Associate Planner
' Truckee Community Development Dept
Town of Truckee
10183 Truckee Airport Rd.
1 Truckee, CA 96161
RE: Gray's Crossing Specific Plan/Tentative Map AKA PC -2
Dear Ms. Scoble:
1 This letter is in response to your request for comments on the Draft Environmental
Impact Report for the above - referenced project.. -
On Page 4.11 -13, Section 13.1. Wastewater Services, Setting, Tahoe- Truckee Sanitation
Agency begins with the sentence: "The Tahoe- Truckee Sanitation Agency provides
sewage collection services to Truckee and conveys it to the treatment facilities located
east of the Town of Truckee." 7 -1
1 This is incorrect. Truckee Sanitary District (TSD) provides sewage collection services to
Truckee as is described on Page 4.1.1 -14.. Tahoe - Truckee Sanitation Agency treats and
disposes of the sewage delivered to its facilities by the Truckee Sanitary District.
Also, the phrase in the last paragraph on Page 4.11 -13, "lodging units are each equivalent
to 1/3 sfu" is not entirely correct. Lodging units with kitchens are 35% of an sfu; lodging 7-2
units without kitchens are 30% of an sfu.
If you have any questions, please do not hesitate to contact this office.
I Sincerely;-,
Craig F. Woods
:General Manager /Chief Engineer
cfwmb
1
• NORTH TAHOE • TAHOE CITY • ALPINE SPRINGS • SQUAW VALLEY • TRUCKEE
2.0 RESPONSE TO COMMENTS
1 LETTER 7 CRAIG F. WOODS, TAHOE- TRUCKEE SANITATION AGENCY
Response to Comment 7 -1
The first sentence on Page 4.11 -13 of the Draft EIR is amended to read:
a The Tahoe - Truckee Sanitation Agency (T -TSA) e e "et = e e - e - 'e -
corvices to Truckoo and conveys it to tho treatment facilities located oast of the
• Town of Truckoo treats and disposes of the sewage delivered to its facilities by
' the Truckee Sanitary District.
Response to Comment 7 -2
1 Page 4.1 1 -13 of the Draft EIR, last paragraph, is amended to read:
USA uses a wastewater generation rate of 200 gallons per day (gpd) per single -
family residential dwelling unit or single - family units (sfu's). Rates for commercial
and other and uses are based on equivalent sfu's. One sfu is equivalent to ten
(10) business plumbing fixture units. Lodging units e - -e - - e - - e - -
I with kitchens are 35% of an sfu, lodging units without kitchens are 30% of an sfu,
swimming pools are equal to Y sfu, and 10 restaurant seats are equal to 1 sfu.
Wastewater volumes produced by non - residential land uses are calculated by
multiplying the equivalent sfu by the 200 gallon per day rate. TTSA's service
charges are based upon the sewer flows and the strength of the sewage
generated from the user categories (Beals, 2001).
1
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1
1
1 Town of Truckee Final Environmental Impact Report
September2003 2 - 79 Gray's Crossing Specific Plan Project
BOARD OF DIRECTORS O.R. eneral , • .• P.E. • I
Chief Engineer
Brian Kent Smart ��,ry'1
Michael F Sullivan p3
Ron Sweet ` ' 3 u LETTER 8
� ° • UC
SANITARY
DISTRICT
A PUBLIC AGENCY
I July 1, 2003 12304 Joerger Dr. • Truckee, California 96161 -3312
Teiephone (530) 587 -3804 • Fax (530) 587 -1340
•
I Town of Truckee
Attention: Heidi Scoble, Associate Planner
1 10183 Truckee Airport Road
Truckee, -CA 96161
II RE: Comments to Gray's Crossing, PC -2 Draft Environmental Impact Report
1 The Truckee Sanitary District (TSD) has reviewed the Draft Environmental Impact Report you
forwarded for the above referenced project and requests the following revisions:
I Page 4.11 -15:
• Section 2, Regulatory Framework, Truckee Sanitary District Code,
I paragraph 2, sentence 2 should read, "If the installed sanitary sewer
system meets TSD .specifications, the developer may petition the TSD 8 -1
Board of Directors to dedicate said facilities to the TSD, whereupon the
I TSD Board reviews the request and votes to accept the dedication and
ultimately take over the responsibility for operation and maintenance of
the system."
1 Page 4.11 -16:
I Wastewater Collection and Conveyance Facilities, Impact 4.11.3,
paragraph 2, item 2, sentence 4 should read, "The Glenshire Outfall is 8.2
proposed as the primary route for sewage flow from the PC -2 and Old .
Greenwood projects as a result of annexation of those properties to the
Truckee Sanitary District in the early 1990's."
1 • Wastewater Collection and Conveyance Facilities, Impact 4.11.3,
paragraph 3, sentence 2 should read, "Further, prior to connection into the
I TSD wastewater collection system, the applicant will be required to
prepare a comprehensive collection system design, including appropriate 84
line sizing to accommodate flows onsite."
H:\ HOME \Engineering\Commerclal Projects \19-379-12,-17,-26 Gray's Crossing \ Comments o DEIR I.wpd
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Page 2
Comments to Gray's Crossing, PC -2 Draft Environmental Impact Report
July 1, 2003
Page 4.11 -16 (continued):
1
Note: Figure 3 -15 as presented in the document is illegible and does not 8 -4
fulfill its purpose in identifying the location of the utilities within the
project. A better map is needed.
If you have any questions or need additional information, please contact me at the above listed 1
address.
Sincerely, ' I
Bradley D. thapley, P.E.
Assistant General Manager
1
cc: Marcia Beals, Tahoe Truckee Sanitation Agency
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r { :FIOMEEnginecring \Commercial Projecis\I9- 37I12; I7, 26 Gray's Crossing \COmncnts m DEIR t.wpl
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2.0 RESPONSE TO COMMENTS
1
LETTER 8 BRADLEY D. STAPLEY, P.E., TRUCKEE SANITARY DISTRICT
1 •
Response to Comment 8-1
The second paragraph of Section 4.11.2, page 4.11 -5 of the Draft EIR, second
paragraph under Truckee Sanitary District Code is amended to read:
1 Typically, the TSD requires large developments to design, fund, and install the
sanitary sewer system necessary to service the proposed development in
' accordance with the TSD Code. If the installed sanitary sewer system meets TSD
specifications, -
w hereu po n th TSDD the developer may petition the TSD Board of Directors to
dedicate said facilities to the TSD, whereupon the TSD Board reviews the request
and votes to accept the dedication and ultimately takes over the responsibility
for operation and maintenance of the system.
1 Response to Comment 8 -2
t The paragraph numbered 2 on page 4.11-16 of the Draft EIR is amended to read:
2. For the area of the project site east of the SR 89, sewage would be
transferred to a sewage lift station at the northeast portion of the property.
From that point a force main would be constructed along the easterly
property boundary, crossing under the Fibreboard Undercrossing, and
connecting to the golf. maintenance facility at Old Greenwood. From
that point sewage would be transferred through the sewer lines being
constructed at the Old Greenwood development to the Glenshire Outfall
which crosses Glenshire Road and then crosses underneath the Truckee
River to the waste treatment facility. This facility is known as the SAD Six
from the PC 2 project The Glenshire Outfall is proposed as the primary
route for sewage flow from the PC -2 and Old Greenwood projects as a
result of annexation of that property to the Truckee Sanitary District in the
• early 1990's.
Response to Comment 8 -3
1 The last paragraph on page 4.11 -16 of the Draft EIR is amended to read:
Environmental review for the off -site sewer infrastructure which will serve the
1 Gray's Crossing project has previously been prepared in conjunction with the
Old Greenwood project and the new middle school and is sized to
accommodate the uses proposed by the Gray's Crossing project (Town of
Truckee, 2002). Further, prior to annexation connection into the TSD wastewater
collection system, the applicant will be required to prepare a comprehensive
collection system design, including appropriate line sizing to accommodate
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -80 September 2003
2.0 RESPONSE TO COMMENTS
flows onsite. The Preliminary Utility Plan (see Figure 3 -15) depicts the location of 1
on -site lines. Again, all facilities must be approved in size and location by the TSD
prior to construction. For these reasons, impacts to wastewater conveyance are
considered less than significant, and no mitigation is required.
Response to Comment 8 -4
The commentor notes that Figure 3 -15 is illegible and requests that a better map be
included in the Final EIR. A color copy of Figure 3 -15 has been sent to the commentor
for review.
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Town of Truckee Final Environmental Impact Report
September 2003 2 - Gray's Crossing Specific Plan Project
TRUCKEE TAHOE AIRPORT DISTRICT
1 DIRECTORS • David V. Gotschall
GENERAL MANAGER
Don Starbard
I PRESIDENT Scott
Ken Foster 1 ASSISTANT GENERAL MANAGER
VICE PRESIDENT
o Michael Golden — .._ . -- :. I
` CONTROLLER n the heart of
Constance I. Stevens America's all -year playground Phred Stoner
Steve Swigard DIRECTOR OF OPERATIONS /MAINTENANCE
I LETTER 9'
August 8, 2003
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Town of Truckee
1 Community Development Department, Planning Division
. Truckee, CA
111 96161 -3306
I RE: Project Routing Request; Draft EIR/Specific Plan /Tentative Map Gray's
Crossing, aka PC -2
I Thank you for providing the Truckee Tahoe Airport District with the opportunity to comment
on the Draft EIR for PC -2. - Please note that the subject property could be affected by the
adoption of the new Comprehensive Land Use Plan (CLUP) currently in staffing by the
Foothill Land Use Commission. It appears that parts of the subject property lie within the
55 dB CNEL and the entire project may lie within the Airport Influence Area. Overall, we
feel the EIR generally accounts for the facts related to aviation operations, with some
1 minor concerns. Please accept the following comments:
EIR Characterization of Aviation /Noise Impact. The characterization of noise impact
1 found on page 4.3 -3 and 4.3 -22 "...frequent overflights of the project site by small aircraft
approaching or departing..." is incorrect. There will, in addition, be frequent overflight of
the project site by larger turbine/jet aircraft due to the site's location under /adjacent to the 9 -1
I primary large aircraft departure routes from Runway 28. We recommend that the project
developer reassess mitigation measures in light of a more accurate characterization of the
1 type of aviation traffic transiting over /near the project. The draft CLUP characterizes the
noise impact from aviation in the project site as moderate. In particular, we would note the
residences planned for lots 1 -48 in Phase 2, Unit 2 will have the very close adjacencies to
1 this traffic. •
Noise Monitoring Results, Given the dates of the noise monitoring outlined on page 4.3-
I 3 and the results in Table 4.3 -1 the figures for Lmax may be low. First, November and -
April are times of the year that see minimal aviation operations. Therefore, the 9.2
measurements may not include as wide a variety and frequency of departing aircraft
1 transiting the project site. In the summer season this issue would manifest itself in higher
average noise levels than reflected in the EIR, particularly for certain times of day.
Another factor of concern is that all the noise monitoring points focused on adjacencies to
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Page 1 of 2
10356 Truckee Airport Road • Truckee, California 96161 • Telephone (530) 587 -4119 • FAX (530) 587 -2984 • manager @truckeetahoeairport.com
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roads, except for site 3 where results were only estimated. Again, the project area will be 1
moderately impacted by aviation - related sound, begging the question of whether broader
mitigation measures might be appropriate for this project.
Avigation /Overflight Easement Requirement: We concur with the EIR's identification of a
a mitigation measure to require an appropriate easement. While an easement does not
alter noise levels (ie. It does not really mitigate), it discloses to potential buyers the
proximity of the property to airport operations. The proposed project is within.the Truckee 9 -3
Tahoe Airport Influence Area, and, more particularly in the traffic pattern area. Impacts
include the parcel's adjacency to common instrument and visual departure routes and
instrument arrival routes. For these reasons the Airport District asks that any approval of 1
the final project be conditioned upon an appropriate easement granted in favor of the
District.
State of California Comprehensive Land Use Plan: A Comprehensive Land Use Plan 1
(CLUP) has been prepared and adopted for the area surrounding the Truckee Tahoe
Airport and is in effect under the laws of the State of California. The CLUP was adopted
by, and is, administered by the Foothill Airport Land Use Commission. Requests for
information on the applicability of the CLUP should be addressed directly to the '
Commission Staff, whose contact information is:
9 -4
Foothill Land Use Commission ,
560 Wall St. Suite F
Auburn, California 95603
530 - 823 -4703
It is our recommendation that the owner consult with the Commission and the Town as
necessary to determine compliance with building policies outlined for residences in this
proximity to the Airport.
If you have any further questions or concerns, please contact Mike Scott at (530)587 -4119
or mikescott @truckeetahoeairport.com.
Sincerely, 1
TRUCKEE TAHOE AIRPORT DISTRICT
/ avid Gotschall
1
eneral Manager
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11 ICKFE TAHOE AIRPORT DISTRICT • 10356 Truckee Airport Road • Truckee, California 96161 • Telephone (530) 587 -4119 • FAX (530) 587 -2984
2.0 RESPONSE TO COMMENTS
LETTER 9 DAVID GOTSCHALL, TRUCKEE TAHOE AIRPORT DISTRICT
1
Response to Comment 9 -1
1 The commentor requests that mitigation measures related to overflight noise be
reassessed in light of the fact that the Draft EIR characterized the aircraft as small, when
1 in fact the overflights include those by larger turnbine /jet aircraft. The commentor also
notes that the draft Comprehensive Land Use Plan characterizes noise impacts from
aviation in the project site as moderate, and that Unit 2 of Phase 2 will have close
1 adjacencies to air traffic. This comment is noted. Although the aircraft overflights
described in the Draft EIR were characterized as small aircraft, a finding of significant
noise impact was nonetheless made relative to airport noise, and Mitigation Measure
4.3.2 would be appropriate to address the noise impacts of both smaller and larger
aircraft overflights of the project areas.
1 Response to Comment 9 -2
The commentor notes that noise monitoring occurred during a period of time
(November and April) that see minimal aviation operations, and that broader
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mitigation measures may be warranted due to a wider variety and frequency of
aviation operations during other months of the year. This comment is noted. The intent
of the noise monitoring program was primarily to document traffic and general ambient
1 noise levels in the immediate project vicinity, but not to check on the accuracy of the
Truckee Tahoe Airport noise contours. While it is recognized that the airport activity is
variable, it was assumed that the airport noise contours provide a reasonably accurate
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picture of existing and projected future typical aircraft activity upon which the
assessment of noise impacts could be conducted. So while the airport noise
environment may have been understated in the noise measurement program, the
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assessment of impacts focused on the airport's noise contour forecasts rather than on
the measured ambient noise levels. As a result, the mitigation measures included in the
EIR are believed to be consistent with the requirements of the Town of Truckee, and
1 adequate to mitigate aircraft noise impacts at the project site.
Response to Comment 9 -3
' The commentor's request that the Truckee Tahoe Airport District be granted an aviation
easement as a condition of the project approval is included here for consideration by
1 the Town Council. It is acknowledged that the proposed project is within the Truckee
Tahoe Airport Influence Area and the Town is therefore required to submit the Specific
Plan, prior to final approval, to the Foothill Airporf Land Use Commission for review
1 pursuant to Section 21676 of the Public Utilities Code.
Response to Comment 9 -4
1 The commentor notes that a Comprehensive Land Use Plan has been prepared and
adopted for the area surrounding the Truckee Tahoe Airport. The existence of a
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Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -82 September 2003
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2.0 RESPONSE TO COMMENTS 1
Comprehensive Land Use Plan ( "CLUP ") for the Truckee Tahoe Airport is noted. Land 1
use designations under the proposed Specific Plan are generally consistent with the
CLUP. 1
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Town of Truckee Final Environmental Impact Report
September 2003 2 -83 Gray's Crossing Specific Plan Project ,
' LETTER 10
Terrell Watt, AICP
Terrell Watt Planning Consultants
1757 Union Street
San Francisco, CA 94123
(415)563 -0543 phone
' (415)563 -8701 fax
terrywatt@att.net
1
• August 6, 2003
' By Express Mail, Email and Facsimile
Attn: Heidi Scoble, Associate Planner
' Town of Truckee Community Development Department
10183 Truckee Airport Road,
Truckee, CA 96161 -3306
Re: Comments on Draft Environmental Impact Report (DEIR) for the
Proposed Gray's Crossing Specific Plan/Tentative Tract Map (AKA PC -2);
SCH No. 2002072115
' Dear Ms. Scoble:
' This comment letter on the Draft Environmental Impact Report ( "DEIR ") for the proposed
Gray's Crossing Specific Plan/Tentative Tract Map project ("project') is submitted on behalf of
Mountain Area Preservation Foundation and Sierra Watch. Mountain Area Preservation
' Foundation (MAPF) is a Truckee -based group of residents and business owners formed in 1987
to protect valuable open space resources of the Town of Truckee, to protect viewsheds in and
around the Town, and to preserve the unique, small town character. In addition, MAPF is 10 -1
1 committed to working constructively with landowners and decision- makers to ensure that new
development uses the remaining land in the Town limits in a manner that is: 1) both wise and
efficient; and 2) that benefits the Town (e.g. by providing housing that is affordable to local
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residents and employees in quality neighborhoods). MAPF and its members have participated in
the Town's current General Plan process. Sierra Watch is a California -based non -profit
' organization formed to assist Sierra -based groups with education and information so that they can
participate effectively in local planning processes. Both MAPF and Sierra Watch have
participated actively in the update process for the Mattis Valley Community Plan to ensure that
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participated actively in the update process for the Mattis Valley Comrnunity Plan to ensure that i
development in the broader region does not impair the regional environment.
These comments are directed at ensuring that development on PC -2 results in wise and efficient
use of the land, and in a project that provides housing first for local residents and employees. To
that end, along with this comment letter, we are submitting a Clustered Alternative Concept' to 10 -2
illustrate a development pattern that provides contiguous, unfragmented open space and a mix of
housing designed to serve local community needs. The Clustered Alternative Concept would
provide 636 units, including 100 affordable employee units, 120 attached units and 416 detached
units. See Exhibit 1. This alternative, or one similar to it, should be analyzed the EIR
In addition, these comments provide a detailed and explicit outline of the problems and
inadequacies presented by: (1) the project itself; and (2) the DEIR, including deficiencies under i
the California Environmental Quality Act ( "CEQA ") (Pub. Res. Code §§ 21000 et seq.) and the
CEQA Guidelines (14 Cal. Code Regs. §§ 15000 et seq.).
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For the reasons described below, MAPF urges the Town Planning Commission and Council to
postpone any further action on the project until the General Plan update is completed. This • i
project site, as well as all other large undeveloped sites in Town, should be included in the
General Plan update process. If the project goes forward in advance of the General Plan update,
a clustered alternative, directed at providing housing affordable to Town residents and employees,
should be given serious consideration by the Planning Commission and Council. We hope that the
illustrative Alternative Concept submitted with these comunents will facilitate review of such an
option. '
L CONSIDERATION OF THE.PROJECT IS PREMATURE
A. The Project Site Should Be Included in the General Plan Update
10 -4
Consideration of the proposed project is premature because the Town has initiated a /
comprehensive update of its General Plan. The Town's General Plan was last adopted in 1996. V
' This Concept, prepared by the SWA Group, illustrates a cluster development pattern. The concept is based on
information provided in the DEIR concerning the location of biological resources on the site. We are currently
seeking additional information concerning where resources actually do occur on the site (including wildlife
corridors) and will modify the Concept as needed to avoid all significant resources.
2 This comment letter was prepared by Terrell Watt, Planning Consultants, with assistance from legal counsel.
Terrell Watt has over twenty years of land use and environmental planning experience. She has expertise in
conservation planning, "smart growth" development projects, CEQA and NEPA, NCCPs/HCPs and government
reorganization projects. Her recent projects include: (1) development of conservation plans for the Central Coast
under a grant from the David and Lucile Packard Foundation; (3) project management of a Sphere of Influence and
Service Review Study for Marin County; (3) consulted on a habitat conservation planning program for the City of
Livermore, partially funded with a grant from the California Department of Fish and Game; and (4) project
management of the Los Angeles Infrll Working Group Project under a grant from Caltrans. The latter is a joint
effort by the State Department of Housing and Community Development, the City and County of Los Angeles and
Environment Now.
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Since that tune, a great deal has changed that merits a review of the land use designations for
Large undeveloped parcels in the Town. Among those changes are the following:
' • The Town of Truckee has grown more rapidly than other cities in the County and
the State. Even with this high growth rate it is difficult for people to find affordable
housing in the Town. See DEIR at 4.12 -3. The gap continues to increase between
' the available supply of affordable housing and the increasing demand for such
housing.
I • Recently approved projects, such as Old Greenwood, will serve a primarily second
home market, a market that generates additional demand for affordable employee
housing and uses precious remaining land within the Town that could have served
' Town needs. The majority of the projects proposed in the Mattis Valley are also
oriented toward second homeowners and resort uses, which will increase the deficit
of housing for local residents and employees.
' • Golf courses have proliferated in the Sierra region, with a new course having just
' been approved on the adjacent Old Greenwood site and a number of new courses
being proposed in the Mattis Valley. According to a recent article in Barron's, the
"golf boom has fizzled unambiguously" ... "and threatens to become a king -sized
' bust." See Why Golf's Prospects are Dimming, Exhibit 2, page 1. It is not clear
what the market it for additional courses in the region.
There are only a handful of large undeveloped parcels in the Town. The need for housing to serve
local residents and employees is acute. These large remaining areas, including the project site and
PC -3, among others, should all be part of the General Plan update process so that the Town can
' revisit the priorities for development on these parcels. Recognizing this, the Town Council at its
February 2003 meeting approved the execution of a contract for a seasonal employee housing
needs study and an affordable housing land use evaluation study. These studies are being
' conducted as part of the General Plan update initiated in September 2002. A market analysis of
the demand for golf courses should also be included in the General Plan update process to inform
the Town whether there is a demand for additional courses. If there is limited/or no demand, and
a new course is approved, existing and /or new courses may fail, leading to blighted properties and
properties that are not well attended and could adversely impact water quality.
1 While the project does include affordable housing and a mix of housing types, the predominant
housing product that will be built if the Project is approved are high -end, large -lot, single family
homes. The DEIR fails to include any information that would support a conclusion that these
'. homes would make a significant contribution to housing need in the Town. In fact, to the
contrary, the proposed Project will generate 168 full time employees' and only provide 64
affordable units (the remaining 28 are employee housing units transferred from Old Greenwood).
' Including part-tine employees, the project will generate up to 235 employees.
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Finally, the proposed Project is not anticipated to build out for at least 15 years. This rate of ,
absorption suggests that a few more months to review the Project as part of the General Plan
update should not pose a hardship to the landowner. It is conceivable that a different product
mix, onemore targeted to local homeownership, might built out more quickly, thereby providing '
a reasonable return to the landowner.
For all of the above reasons, the Town should postpone any further consideration of the proposed
Project until the General Plan update is completed and it is clear that this area is not needed to
meet the needs of the local housing market (rather than to provide additional high end and resort
housing and another golf course). ,
B. The Project Requires A Number of General Plan Amendments, Which
Should Be Considered in the Context of the General Plan Update
The proposed Project would require numerous general plan amendments, which should be
considered as part of the General Plan update. Specifically, a number of components of the
proposed Project appear to warrant general plan amendments, including, but not limited to:
1) The proposal to develop 10 units and a portion of the golf course on the 52.3 -acre '
property incorporated into the Project that is currently designated OSR under the General
Plan. Even if 5 units can be "transferred" to the parcel from PC -2 under a "Planned
Development," the parcel must have an appropriate General Plan designation consistent
with the uses proposed.
2) The proposed gas station within the Village -- even with the reduction ofpumps.
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3) Depending upon the terns under which the Golf Course is open for public play, the mostly 10 -5
private Golf use. ,
4) The lack of adequate setbacks from the Highway — in some areas setbacks appear to be
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less than the 100 foot minimum called for in the Plan.
5) The lack of adequate development intensity standards in the General Plan for
"Recreational Commercial Uses," including the recreation center /fitness center, hotel,
stables, golf maintenance facility, clubhouse, restaurant and lounge,,apd public service
uses. The General Plan contains only "allowable acres," which does not constitute _
adequate intensity standards for the project. The Office of Planning and Research (OPR) _
has specifically stated that "lot size is an inadequate standard of building intensity because
although it regulates lot area, it does not quantify the allowable concentration of
development on each lot." General Plan Guidelines, 1998 Edition. For the same reason,
"allowable acres" of a use is an inadequate standard of building intensity. Case law and
OPR provide guidance as to what does constitute an adequate standard of building
intensity:
° The DEIR glosses over these details. A rigorous analysis must be included in the DEIR concerning the potential 1
inconsistency between the current General Plan designation for this parcel and the type and intensity of the
proposed uses under the Project. 1
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"OPR recommends that each intensity standard include these variables: (1)
permitted land uses or building types; and (2) concentrations of use. Permitted
' uses and building types is a qualitative measure of the uses that will be allowable in
each land use designation. The concentration of use can be defined by one or
more quantitative measures that relate directly to the amount of physical
' development that will be allowed. Maximum dwelling units per acre is a good
residential standard. Floor area ratio (the ratio of building floor area to the total
site area) is a useful measure of commercial and industrial intensity. The dual
' standard of maximum lot coverage and maximum building height is suitable for
agricultural, open space and recreational designations where development is being
limited." General Plan Guidelines, 1998 Edition, page 39, Exhibit 3.
' To the extent the Project does require one or more general plan amendments, it is even more
appropriate for PC -2 to be part of the General Plan update process and the specific type, mix,
intensity and orientation of uses be reviewed and revised as appropriate to suite the Town's
changing needs and vision.
H. THE DEIR IS INADEQUATE UNDER CEQA
1 The DEIR is inadequate. Specifically, an E1R must provide enough analysis and detail about
environmental impacts to enable decision- makers to make intelligent judgments in light of the
environmental consequences of their decisions, See CEQA Guidelines § 15151; Kings County
' Farm Bureau v. City of Hanford, 221 Cal.App.3d 692 (1990). Under the law, the lead agency
must make a good faith effort to fully disclose the environmental impacts of the project. This
requirement cannot be met unless the project is adequately described and existing setting
' information is complete. See County of Invo v. City of Los Angeles, 71 Cal.App.3d 185, 199
(1977). Both the public and decision- makers need to fully understand the implications of the
choices presented by the project, mitigation measures, and alternatives. See Laurel Heights 10-6
Improvement Ass'n v. Regents of University of California (Laurel Heights I), 6 Ca1.4th 1112,
1123 (1988). The DEIR fails to provide sufficient information to enable informed decision -
making by the Town, the public, and the permitting agencies.
The DEIR is a project level EIR intended to cover all necessary approvals for the Project as well
as a `vested right" in the form of a development agreement for the Project. Many of the most
1 significant impacts are irreversible after rough grading has occurred. Thus, detailed information
concerning project level impacts must be provided at this stage of project consideration so that
' the public, agencies and Town decision- makers can fully understand the impacts of the proposed
Project and alternatives. Deferral of information concerning project - related and cumulative
impacts, mitigation measures and alternatives is improper and unacceptable given the types of
' activities and irreversible environmental harm that will result from the approval of the project at
this stage.
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A. The DEIR Fails to Describe the Project Adequately
The DEIR fails to describe the Project and it's setting accurately and completely. It omits key
project features that have the potential to result in significant impacts. The CEQA Guidelines
define "project" as "the whole of an action, which has a potential for resulting in a physical change
in the envifomitent, directly or ultimately ...." CEQA Guidelines § 15378, Among other
components, an EIR's project description must contain a "general description of the project's ,
technical, economic, and environmental characteristics, considering the principal engineering
proposals if any and supporting public service facilities." CEQA Guidelines § 15124(c). As the
Court of Appeal has noted, "The defined project and not some other project must be the EIR's
bona fide subject." County of hryo, 71 Cal.App.3d at 185. An accurate and complete project
description is indispensable because, "[a] curtailed or distorted project description may stultify the
objectives of the reporting process. Only through an accurate view of the project may affected '
outsiders and public decision- makers balance the proposal's benefit against its environmental cost,
consider mitigation measures, assess the advantage of terminating the proposal ... and weigh
other alternatives in the balance. An accurate, stable and finite project description is the sine qua
non of an informative and legally sufficient EIR." Id. at 192.
The DEIR also fails to provide an adequate description of the setting for the project. Such a 10-7
failure is fatal under CEQA. CEQA and the CEQA Guidelines mandate that an EIR include a '
description of "the physical environmental conditions in the vicinity of the project ... from both a
1 local and a regional perspective ... Knowledge of the regional setting is critical to the assessment
of environmental impacts." CEQA Guidelines §§ 15125(a) and (c). This requirement derives
from the principle that without an adequate description of the project's local and regional context,
the ER, and thus the decision- makers and the public who rely on the EIR, cannot accurately
assess the potentially significant impacts of the proposed project.
The DEIR fails to describe key aspects of the proposed Project with the potential to result in
significant environmental impacts. Additionally, it fails to describe accurately and completely the
environmental setting impacted by the project. Accordingly, potentially significant environmental '
impacts cannot be adequately analyzed or addressed by the DEIR and, for this reason, the DEIR
is fatally deficient under CEQA. Specific defects in the project description and setting include,
but are not limited to the following:
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First, the DEIR lacks a complete description of proposed uses at the Project site. Specifically,
the DEIR fails to describe key aspects of the proposed Project including, but not limited to the
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following:
1) The specific details of the proposed employee and affordable units, including, but not 10 -8 .
limited to: whether these units will be subsidized; whether they will be permanently
affordable and how affordability will be ensured; the income levels these units will '
"match," etc. MAPF specifically requested this information be included in the DEIR in its
comments on the scope of the DEIR This information is relevant to a number of DEIR
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analyses, including the extent to which the Project is lobs-housing" balanced and impacts
' to the environment related to longer commutes including traffic, air quality and growth
inducement elsewhere.
2) The number of units that are estimated to serve a second -unit market versus a primary
resident market based on housing cost and local income data, not census data as provided
in the DEIR (see DEIR at 4.12 -14; estimate of 317 foil -time occupied units). This
' information also fails to address the likelihood that fractional ownership of new homes will
result in essentially full -time occupancy, even if by different families. Additional evidence
to support assumptions used in the Population, Housing and Socio - economics section is
needed.
' 3) The cost of the new homes, second units and fractional units and the market area they will
serve.
' 4) The number of second units that may be developed in the Project area under new state
law.
5) The specific means by which the project will ensure that no hazardous materials/pollutants
reach the wetlands /meadow areas/creeks from the golf course or other landscaped areas.
This information must include how the mechanisms will be funded in perpetuity, how
water quality will be monitored and by whom, as well as other details of the program. If
1 the Lahontan Regional Water Quality Control Board staff are involved in the monitoring
program, a letter should be included in the Final EIR from the Board stating that they have
1 the finding and staff time available for such continuous monitoring and reporting. Han
independent firm will be used, it is imperative that they be accountable to the Town, the
Regional Board and the public, and that their monitoring and reporting efforts be
' independent of the development interests (e.g. a program be established that is bonded so
that it can be done in perpetuity and as determined necessary by the Town and the
experts).
' 6) Among other information necessary to accounting for all impacts associated with the new
development.
This information is relevant to a number of impact analyses including, but not limited to demand
for services, traffic, jobs - housing balance, water quality among other issues. A revised project
description must include this information.
' Second, the project description fails to provide an adequate description of project-related and
cumulative construction activities. The DEIR project description includes some information
concerning project development phasing, but fails to include any information about: a) the
duration and extent of grading activities; b) amount and types of construction equipment for each
phase; c) number of construction employees and where they will commute from; d) total 0 "
' construction trips, including trips related to equipment, hauling and employee trips; e) location of
staging areas and spoils sites; and 1) cumulative project construction phasing and activities.-
' Without a description of these activities and phasing, the DEIR cannot adequately identify and
analyze environmental impacts to air and water quality, impacts to biological resources, and other
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impacts associated with truck traffic and traffic and grading emissions, construction noise and '
dust.
An EIR for a project such as this must include a description of the construction period activities,
including, but not limited to: activities by phase; types of equipment; construction employment;
staging areas, borrow sites and spoils disposal sites, among other details of the construction that
could result in impacts. A revised environmental document must be prepared that includes this '
information and revised impact analyses as warranted based on the information.
It is also noteworthy that a number of impacts sections contain construction "impact" discussions ,
since no information is provided about construction activities. These discussions are totally
without any factual basis. For example, the noise section provides a table of noise levels for each
type of equipment, but there is no description of the types and activities of equipment that will be
used to development the project on which to base any "analysis" of impacts. In fact, the impact
discussion is devoid of any analysis. The same holds true for the DEIR's analysis of air quality
impacts. The DEIR's refers to the use of "default" values used in the URBEMIS -2001 program
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to estimate air quality impacts associated with construction of the project. A revised analysis
must provide the "inputs" to that model in terms of the total of construction emissions from site
grading, equipment exhaust, construction worker trips, and other construction impacts based on a -
clear and detailed description of these inputs by project phase over the life of the project. Finally,
the DEIR contains NO analysis of construction- related transportation impacts. A revised DEIR ,
must include detailed information of construction activities for both the project and cumulative
projects in the area and a revised analysis of project and cumulative impacts on air quality, noise
and traffic. To the extent that there will be impacts to biological resources as a result of staging t
areas and runoff related to construction activities, these impacts must also be addressed. Finally,
if the numbers of construction workers for the project and cumulative project that will be long -
distance commuting to the sites are significant, impacts associated with poor jobs- housing ratios
must also be addressed.
Third, the DEIR fails to adequately describe project inconsistencies with applicable plans and
policies. While the DEIR attempts to provide detailed information concerning the project's
consistency with all applicable plans and policies it fails to address all applicable plans, policies
and regulations. Potential Project — plan/policy inconsistencies that are not addressed, include,
but not limited to:
10-10
1 a) The lack of adequate building intensity standards for all land uses (see
above discussion). Where a General Plan is deficient in a way that is
implicated by a project, consistency cannot be found.
b) Inconsistencies between the General Plan land use designation for the
52.3 -acre property and the uses proposed for that parcel.
c) The inconsistency of the Project as proposed and the Town's clustering
policies. While the DEIR argues that the project is consistent with
8
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1
clustering policies, the fact is that by any reasonable definition, this is
not a "clustered" project. By definition, cluster means: A group of the
same or similar elements gathered or occurring closely together; a
' bunch. The American Heritage College Dictionary, Third Edition.
The DEIR states that: "Approximately 417.6 acres of open space is
dispersed throughout the project ... ". DEIR at 3 -24. The DEIR
cannot have it both ways — that the development is "clustered" and the
"open space is dispersed." As the proposed site plan clearly shows,
neither the development nor the open space areas are clustered. For
1 comparison, Exhibit 1, the Cluster Alternative Concept plan, illustrates
a clustered project.
' d) Finally, the DEIR fails to analyze potential Project inconsistencies with
other applicable plans, policies and regulations of other `permitting"
and trustee agencies, including but not limited to the Lahontan
1 Regional Water Quality Control Board, the Department of Fish and
Game, the U.S. Fish and Wildlife Service and the U.S. Army Corps of
' Engineers, among others.
A revised DEIR must include this information. Where the DEIR makes a statement concerning
consistency, facts must be provided to support that statement of consistency where there is any
1 question remaining (e.g. clustering, consistency with other applicable regulations/programs, etc.).
1 Fourth, the project description omits other information that has the potential for resulting in
significant impacts, including, but not limited to:
a) The proposed development agreement.
' b) The extent of public play on the golf course.
c) The specific source(s) of water for various components of the project based on "safe yield"
1 information and credible information concerning the water supply (see Exhibit 4, Letter from
Acton - Mickelson - Environmental Inc., which contains reasons why the Nimbus Study
overestimates the supply of water to serve the region). Moreover, the project description
1 omits adequate information pursuant to SB 221 (Chapter 642, statues of2001) and SB 610
(Chapter 643, statutes of 2001), which require a water supply assessment in EIR's and
1 `proof' of water. The Dept. of Water Resources has published a "Guidebook for 10-11
Implementation of SB 221 and 610," which is posted on their website at
www. owae. wafer.ca.govinrafGuidebook.pdt. A revised project description should provide •
1 additional information concerning water for the proposed project and cumulative
development based on objective data and a calibrated numeric model as proposed by Acton -
Mickelson.
d) The number of second units that could be built under State law.
' e) The size (in s.f feet) of a number of non- residential uses, including the golf course
maintenance facility, lodge, etc..
1 9
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m
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f) And any other information needed to support a thorough analysis of project - related impacts.' l
Finally, in addition to project description information, the DEIR fails to provide all of the I
setting information necessary to support an adequate analysis of project and cumulative
impacts. Setting information missing from the DEIR includes, but is not limited to the
following:
a) The U.S. Army Corps of Engineers statement that the Wetland Delineation included as 1
Appendix GI is adequate and meets their requirements. In addition, it would be useful for
the preparer's credentials for preparing the "delineation" included in the appendix to be ,
included in the response to comments.
b) Sufficient evidence to support the contention there is adequate water at a safe yield to
support cumulative development. See above comments.
c) Setting information for biological resources, including wildlife corridors for a sufficiently
1
large geographic study area. The DEIR fails to include any regional description of
resources related to an adequate map of such resources. 10 -12
d) The current and projected unmet demand for affordable housing in Truckee and the region
as a result of planned, approved and foreseeable developments. ,
• e) Information concerning the nuinber of existing and planned "resort" units similar to those
proposed by the project in the region, the number of unsold units and the market for new ,
.units. Market study information should be provided to support the demand for the types of
resort and fractional units proposed by the project.
f) Information concerning the number of existing and planned golf courses in the region.
• Market study information should be provided to support the demand for another golf course •
on this site. 1
g) Other setting information necessary to support thorough analyses of project-related and
cumulative impacts.
1
B. The DEIR's Analysis of Environmental Impacts is Inadequate
The DEIR's analysis of environmental impacts fails to provide the necessary facts and analysis to
allow the Town and the public to make an informed decision. Without such detail, the DEIR is
deficient under CEQA. The role of the EIR is to make manifest a fundamental goal of CEQA: to 10 -13
"inform the public and responsible officials of the environmental consequences of their decisions
before they are made." Laurel Heights I, 6 Ca1.4th at 1123. To do this, an EIR must contain
facts and analysis, not merely bare conclusions. See Citizens of Goleta Valley v. Board of
Supervisors, 52 Cal.3d 553, 568 (1990). Any conclusion regarding the significance of an 7
10
1
environmental impact not based on analysis of the relevant facts fails to achieve CEQA's
informational goal.
As set forth below, the DEIR is riddled with conclusory statements regarding environmental
impacts, unsupported by facts and necessary analysis. Furthermore, the DEIR attempts to defer
analysis of environmental impacts to a later date. As discussed below, such deferral is not an
option. CEQA mandates that environmental impacts be identified and analyzed in the EIR, not at
a later date. See Sundstom v. County of Mendocino, 202 Cal.App.3d 296 (1988) (holding that a
negative declaration was invalid when county approved a project while postponing the resolution
' of uncertainties regarding environmental impacts to a later date).
1. The DEIRs Analysis of Air Quality Impacts Is Incomplete
The DEIR appears to understate the impacts on air quality that will be generated both by project
construction and by the built project itself. As noted above, the DEIR fails to adequately describe
1 construction activities and phasing, and therefore, fails to adequately and transparently describe
air quality impacts associated with construction activities. Another major deficiency in the
' analysis is the lack of any meaningful analysis of cumulative air quality impacts. A revised
environmental document must include such an analysis (e.g. other construction projects in the
area generating air pollutants; total cumulative project emissions, etc. for an adequate study area).
' 10 -14
Finally, development trends in the region which projects such as this perpetuate include the
construction of high -end second homes serving a `Bay area and beyond" market, and the
' increasing reliance on more remote areas for employee housing must be evaluated in terms of the
air quality implications over the long -term. If these trends continue and are not addressed by
"better" planning, commutes both to second homes and employee residences will increase, with a
' resulting increase in traffic and air pollution. These cumulative impacts have not been addressed
adequately in the DEIR. Nor does the DEIR suggest feasible mitigation measures to address
these potentially significant impacts, including, but not limited to modified General Plan land use
1 designations to provide housing to meet local needs fast.
' 2. The DEIR Fails to Analyze Land Use and Planning Impacts
Adequately
' The DEIR fails to describe all relevant policies and plans, and fails to evaluate the consistency of
the project with each policy. As described above, the DEIR includes a discussion of Project 10 -15
consistency with applicable policies and regulations of other agencies (e.g., policies of the U.S.
Fish and Wildlife Service and the Regional Water Quality Control Board, among others). A
revised environmental document must include this information and analysis. Moreover, as noted
above, the DEIR's conclusions concerning Project consistency with a number of General Plan
' policies is inaccurate or unsupported by sufficient evidence. A mere statement of consistency is
not sufficient to support statements of consistency between the Project and a number of policies.
1 11
Finally, where the General Plan itself is lacking in ways implicated by the Project, Project
consistency cannot be found (e.g. the Town's General Plan lacks adequate standards for building
intensity for a number of non- residential land use types -- Therefore, Project consistency cannot
be found). The DEIR must be revised to provide additional analysis concerning Project — General
Plan consistency.
3. The DEIR Fails to Analyze Impacts to Traffic Adequately 1
The DEIR fails to adequately analyze traffic impacts of the project and cumulative projects for a
number of reasons:
1
First, the DEIR fails to include in the project description all components of the project that
could generate traffic including, but not limited to construction related traffic, second units - 10 -16 '
and the activities that will use the resort/conference facilities. Trips related to each of these
project components appear not to have been considered. Therefore, total trips appear to be
1 underestimated. A revised analysis must be based on a full accounting for new trips.
Second, the DEIR is internally inconsistent concerning its assumptions for occupancy, and
therefore trips generated by project uses. The traffic analysis clearly assumes that many of the
units will be part-time residences. See DEIR at page 4.2 -25. This assumption seems inconsistent 10 -17
with the concept of fractional ownerships, where there would seem to be an incentive for `full -
time" occupancy even though the units are "second- units" by definition. A revised analysis should
assume a worst -case scenario where all units are occupied full-time. Or additional evidence (e.g.
project conditions) must be provided to ensure that the traffic analysis has already evaluated a
worst -case occupancy and therefore trip analysis.
Third, the DEIR omits any analysis of project - related and cumulative construction traffic. 10 -18
This analysis and statements of impact must be included in a revised DEIR. Moreover, mitigation
measures for these impacts must be included in the DEIR
Finally, the DEIR fails to disclose that the project's proposed land use pattern would not
support sound transportation management practices because of its location, low density and ,
contribution to the suburban sprawl pattern in the region. As a result, the project will 10 -19
perpetuate the exclusive use of automobiles for transportation, the very practice that has
contributed to the traffic and air quality problems that are so acute in the area. The DEIR fails to
adequately describe how this pattern of development will continue to frustrate alternatives to the
car for transportation.
1
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•
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1
4. The DEIR Fails to Analyze Adequately Impacts to Hydrology,
Drainage, Water and Water Quality
• Pollution carried by storm water and urban runoff is the largest source of contamination to surface
water both in California and nationwide. Construction sites, in particular, have been identified as
significant dischargers of polluted storm water, involving high concentrations of silt and turbidity,
' as well as oil and grease, trash, sewage, and other chemicals used in construction activities and
equipment maintenance. Despite this well -known and well- documented problem, the DEIR fails
to adequately describe project - related and cumulative construction activities and on -site and off-
, site drainage "improvements," both of which could impact the water quality of the area.
The DEIR concludes that there will be no significant drainage impacts after mitigation because of
a highly engineered system of storm drains, catch basins, and other structures to control drainage
and water pollutants. Specific information about the drainage and water quality features and
how they will be maintained and monitored over the long -term (including information about the
cost of maintenance and monitoring) is essential to determine: 1) whether the extent of drainage
alterations is an acceptable project feature; and 2), whether the proposed system of drainage
features will actually be a viable system over the long -term, and effectively mitigate significant
1 impacts to the natural drainage system. 10 -20
The best way to ensure that water quality is maintained, is to actually "cluster" the project to
1 reduce overall site coverage. A second way to ensure that water quality is not compromised is to
delete the golf course from the Project. For both of these reasons, we urge that a revised DEIR
give serious consideration to an alternative similar to the Clustered Alternative Concept submitted
with these comments (Exhibit 1).
' The DEIR provides insufficient evidence that impacts to water quality and groundwater will in
fact be insignificant. Specifically, the DEIR states:
' `Based upon the above information, it is anticipated that the water demand of the project
would be well within available water supply of the ground water aquifer in the Martis
Valley, therefore this impact is considered less than significant. However, it should be
' noted that the "safe yield" of the groundwater basin has yet to be established under the
Truckee- Carson - Pyramid Lake Settlement Act" Emphasis added. DEIR at 4.6- 25 -26.
1 It is not clear how the DEIR can support the conclusions that impacts to groundwater and water
in general will be insignificant without a final resolution of "safe yield." Impacts statements
concerning water should be revised to be potentially Significant and Unavoidable, unless
1
additional information is provided concerning "safe yield" and based on objective data and a
calibrated numeric model. See Acton letter, Exhibit 4.
1 Finally, the significance of project - related impacts requires that the analysis of cumulative impacts
to drainage and water quality be extensive. The DEIR fails to complete any analysis of these
1 13
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1
admittedly significant cumulative impacts, yet concludes that cumulative impacts would not be T
significant.
5. The DEIR Fails to Adequately Analyze and Mitigate Impacts to
Biological Resources
The biological analysis section of the DEIR is inadequate for numerous reasons, including, but not
limited to the following:
First, the DEIR underestimates the importance of the project site for species habitat and wildlife
1
movement. According to the Department of Fish and Game:
"Significant resources of the project site include habitat for sensitive species and
movement areas for local resident wildlife. Habitats of the project site, dominated by an 10 -21
overstory of pine with an understory of sagebrush bitterbrush and grasses, although not
unique, are locally and regionally significant and further loss of these habitats is viewed by
the DFG as a significant impact." See Exhibit 5, Letter from the Dept. of Fish and Game.
The DEIR fails to identify these resources on the site as significant and finds that the impacts of 1
the project associated with impeding wildlife movement are less than significant. A revised DEIR
must include a revised analysis of project- related and cumulative impacts to core biological values
and movement corridors.
Second, the DEIR fails to adequately mitigate for the indirect and direct losses of habitat 1042 '
currently occupied by endemic wildlife. Because the DEIR fails to provide adequate mitigation to
offset these impacts, project - related and cumulative impacts to biological resources should be
identified as significant and unavoidable in a revised DEIR.
1
Third, the DEIR fails to identify feasible mitigation measures including, but not limited to: '
1) Clustering development so that large, unfragmented open space areas remain.
See Exhibit 1.
2) Increasing setbacks from development to sensitive habitats on the project site, 10-23
including the montane meadow, wetlands and creeks.
3) Payment of an open space mitigation fee. Such a fee could be based on either a •
per acre or per unit fee. The South Livermore Valley Agricultural Specific Plan
includes an agricultural mitigation fee comprised of the amount of funding
necessary for each acre developed to protect an acre and each unit respectively to
protect an acre of agricultural or open space land. The current fee is running
approximately $40,000 per unit, including $10,000 in park mitigation fees.' The
' Source: Telephone conversation with Livermore Planner Stephen Riley on August 6, 2003. According to Mr.
1
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' Town should investigate other open space mitigation fees and retain an economist r.
to determine what level of fee is appropriate to offset the impacts this project will
have on regional habitat and open space. Permanently affordable units (pursuant
to State requirements) could either be relieved of the fee or pay a lower fee.
For all of the above reasons, a revised DEIR must be recirculated which contains an adequate
1 analysis of project-related and cumulative impacts to biological resources and corridors.
6. The DEIR Defers A Number of Impact Analyses
' In addition, the DEIR fails to analyze the significance of a number of other potential impacts due
to a lack of information. Examples of impact analyses improperly deferred include, but are not
1 limited to:
• . Impacts to biological resources, which are deferred due to a lack of adequate 10 -24
' setting information (e.g. deferred surveys) and incomplete information (e.g.
concerning potential wildlife corridors, fawning areas and wetlands). G
• Impacts to wetlands — the DEIR states: "...it is not possible at this time to
determine if impacts to jurisdictional waters will result from development of the •
• proposed SR 89 /Alder Drive/Prosser Dam Road roundabout, and therefore impacts 1 U -25
are considered potentially significant." DEIR at 4.6 -15. Remarkably, although the
impacts are not known at this time, this impact is determined to be less than
' significant. DEIR at 4.6 -15. Clearly, there is some inistake in this conclusion OR
additional information must be presented in the response to comments to support
such a conclusion.
' • Impacts associated with night lighting. The discussion fails to include any analysis
' of the significance of newly introduced night lighting related to the project and
cumulative projects. A revised analysis must include a nighttime lighting study and
provide evidence supporting that the level of newly introduced night lighting will not
be significant. The analysis should also evaluate the efficacy of the proposed
10-26
nighttime lighting program.
•
' A revised DEIR must include thorough impact analyses for project - related and cumulative
impacts. It is not appropriate to defer these analyses until after the public and decision- makers
have completed their review of the project:
1
Riley, fees will increase as mitigation and park land values increase.
6 Once this information is provided, MAPF and Sierra Watch may revise the alternative submitted with these
comments to ensure that development areas will not impact significant biological resources. The Clustered
Alternative Concept should be considered illustrative until this information is provided in a revised DEIR.
15
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C. The DEIR Fails to Adequately Analyze Cumulative Impacts
The DEIR utterly fails to analyze cumulative impacts in the manner or to the degree required by
CEQA. The CEQA Guidelines define cumulative impacts as "two or more individual effects
which, when considered together, are considerable or which compound or increase other
environmental impacts." CEQA Guidelines § 15355(a). "[I]ndividual effects may be changes
resulting from a single project or a number of separate projects." Id. 1
A legally adequate cumulative impacts analysis views a particular project over time and must
consider the impact of the project combined with other projects causing related impacts, including 1
past, present, and probable future projects. Projects currently under environmental review
unequivocally qualify as reasonably probable future projects to be considered in a cumulative
impacts analysis. See San Franciscans for Reasonable Growth v. City and County of San
1
Francisco, 151 Cal.App.3d 61, 74 & n. 13 (1984). In addition, projects anticipated beyond the
near future should be analyzed for their cumulative effect if they are reasonably foreseeable. See 0_27
Bozuugv. Local Agency Formation Conmm'n, 13 Ca1.3d 263, 284 (1975). Alternatively, an EIR
may utilize a summary of projections contained in an adopted general plan or related planning
document, or in a prior environmental document which has been adopted or certified, which
described or evaluated regional or area wide conditions contributing to the cumulative impact.
Any such planning document shall be referenced and made available to the public at a location •
specified by the lead agency. The discussion of cumulative impacts must include a summary of
the expected environmental effects to be produced by those projects, a reasonable analysis of the
cumulative impacts, and full consideration of all feasible mitigation measures that could reduce or
avoid any significant cumulative effects of a proposed project. '
The cumulative impacts concept recognizes that "[fjhe full environmental impact of a proposed . .
. action cannot be gauged in a vacuum." Whitman v. Board of Supervisors, 88 Cal.App.3d 397, '
1
408 (1097). The requirement of a cumulative impacts analysis of a project's regional impacts is
considered a `vital provision" of CEQA. Bozung, 13 Ca1.3d at 283. Moreover, an EIR must
examine not only the anticipated cumulative impacts, but also reasonable options for mitigating or
1
avoiding the project's contribution to significant cumulative impacts. The DEIR does not come .
close to meeting these requirements for the reasons described below.
1. The HEIR Fails to Adequately Establish and Support Adequate
Cumulative Impacts Analysis' Geographic Study Areas
A revised DEIR must identify a meaningful geographic study area and projects within that study
area as a basis for analyzing cumulative impacts to land use, biological resources, transportation,
10-28 ,
hydrology and drainage, noise, growth inducement, public services and facilities and visual
impacts, among others. The revised DEIR must describe and ideally map the relevant study area
for each impact analysis. For example, for biological resources, the study area should include all
areas in the region, which contain the same impacted habitats and species, at a minimum. Without
this level of analysis, a conclusion that the project will result in acceptable losses to habitat,
16
1
' species and wildlife corridors cannot be supported. For traffic, the geographic study area should
at a minimum, include the areas where trips will be initiated and end, including employee and
resort visitor trips. Evidence supports a study area for traffic that includes Lake Tahoe, a nearby
' destination for homeowners and resort visitors, and Reno and the Auburn Corridor, where
employees are likely to reside. If this study area is not reasonable, evidence to that end must be
provided. Similarly, for each impact, study areas should be proposed and defended based upon
1 evidence as to where the project - related contribution are not measurable.
2. The DEIR Fails to Analyze Cumulative Impacts Adequately
' In addition to relying on a far too small geographic study area, the Ievel of analysis in the DEIR's
cumulative impacts analysis is far too cursory. An ER must include objective measurements of a
1 cumulative impact when such data are available or can be produced by further study and are 1 0-29
necessary to ensure disclosure of the impact. See Kings County, 221 Cal.App.3d at 729. Despite
1 this mandate, the DEIR fails to analyze adequately a number of cumulative impacts, including, but
not limited to, impacts to biological resources, water quality and drainage, policy consistency,
services, traffic, growth inducement, among others.
1 Conclusions reached in the DEIR concerning the significance of cumulative impacts are flawed
and devoid of any real analysis, including the lack of adequate study areas. Examples include, but
are not limited to the following:
• The DEIR fails to include ANY analysis of cumulative construction noise. A 10 -30
' revised DEIR must include this analysis and mitigation measures. At least one
adjacent project, Old Greenwood, will be under construction at the same time as
Gray's Crossing.
' • The DEIR fails to support with evidence the conclusion that cumulative water
supply and groundwater impacts will be less than significant. The DEIR itself states:
However, it should be noted that the "safe yield" of the ground water
1 basin has yet to be established under the Truckee- Carson - Pyramid Lake
Settlement Act" Emphasis added. DEIR at 4.6- 25 -26. 10 -31
' In addition, the Acton letter, Exhibit 4, suggests that modeling of the groundwater in the region
may have resulted in an overestimation of water supply, let alone safe -yield supply. Finally, no •
analysis has been completed by a qualified hydro- geologist — biologist team to assess the
' cumulative impacts of water use on biological resources in the region. This analysis should be
completed before any further conclusions are drawn concerning the significance (or insignificance)
of impacts to biological resources dependent on water.
' • The DEIR fails to support with evidence its conclusions that impacts to flooding '
and water quality will be insignificant. To the contrary, the proposed mitigation / 1 0-32
' 17 ` /
1
1 -
measures for flooding and water quality either are improperly deferred (see e.g. MM
4.7.8b, c and d requiring future permits, and MM 4.6.3b future SWPPP, and MM
4.6.4), or would have secondary impacts that have not been evaluated in the DEMR,
including, but not limited to MM 4.6.7, which calls for culverts, ditches and
detention basins, among other facilities for drainage and flood control. •
° The cumulative discussion of biological resource impacts completely misses the ,
point of a cumulative analysis. Once again, the section lacks any description of the
geographic study area for the discussion, or a complete list of projects within that 10 -33
area. There is no quantification of cumulative direct and indirect cumulative losses
of biological resources (in acres and species), nor is any information provided
concerning the cumulative impacts to wildlife corridors or habitat fragmentation. A
revised DE1R must include this information and support conclusions concerning
1
impacts with evidence.
• Equally inadequate are the DE1Rs discussions of visual impacts, impacts to public 1 10 -34
services and utilities, among other topical areas.
Moreover, none of the cumulative impact discussions provide quantified information concerning 1
cumulative project impacts. This information must be provided in revised cumulative analyses.
Without such information, there is insufficient evidence to support the DEIR's conclusion that
cumulative impacts to biological resources, traffic and water quality, among other impacts, will be
insignificant. A revised document must also specify mitigation measures for cumulative impacts.
Currently, the DEIR includes conclusory statements in each section concerning potentially
significant cumulative impacts.
The DEIR's conclusion that the project's cumulative impacts, with the exception of cumulative air '
quality and regional traffic, will not be significant, cannot be supported in light of the inadequacy
of the geographic study areas for cumulative analyses, the lack of an adequate list of projects or 10 -35 s
plan basis for each analyses, the omission of any meaningful analysis of cumulative impacts and
the lack of supporting data and evidence. A revised DEIR must also acknowledge that many
more cumulative impacts are significant, including cumulative impacts to public services, wildlife
corridors, biological species and their habitat, traffic and water quality, among others. This failure
to consider regional or area wide cumulative impacts is fatal under CEQA and, as such, the
document must be revised and recirculated.
Finally, as described above, the DEIR fails to explore the full range of mitigation measures that
could potentially reduce cumulative impacts below a level of significance. An EIR must examine
reasonable options for mitigating or avoiding the project's contribution to cumulative impacts.
1
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•
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D. The DEIRs Discussion of Growth - Inducing Impacts is Inadequate Under
CEQA
The DEIR must consider the growth - inducing potential of the project in this undeveloped area.
CEQA requires that an EIR include a "detailed statement" setting forth the growth- inducing
impacts of the proposed project. See Public Resources Code § 21100(b)(5); City of Antioch v.
' City Council of Pittsburg, 187 Cal.App.3d 1325, 1337 (1986). The statement must "[ diiscuss the
ways in which the proposed project could foster economic growth, or the construction of
additional housing, either directly or indirectly, in the surrounding environment." CEQA
' Guidelines § 15126.2(d). It must also discuss how a project may "encourage and facilitate other
activities that could significantly affect the environment, either individually or cumulatively" or
"remove obstacles to population growth." M.
In this case, the growth inducing analysis fails to adequately analyze the potential growth
inducement associated with the Project's extension of sewer to Prosser Lakeview Estates. DEIR 1 0 -36
1 at 3 -20. Indeed, the extension of sewer beyond the project site is an objective of the project.
Yet, there is no analysis of the potential for additional development once sewer is extended or the
likelihood for larger or additional homes to be built. While providing sewer to areas currently on
septic systems may in the long run be a benefit to groundwater quality, the DEIR.still has an
obligation to analyze the potential for growth inducement as a result of the extension of services.
1 Similarly, the DEIR must disclose and analyze the potential for the new school and water tank to
support growth beyond the Project. This information is simply not in the DEIR.
A revised environmental document must include an adequate analysis of the project's potential for
growth inducement. A revised growth inducing analysis must be prepared, including the status of
1 development permitted on adjacent properties under all applicable plan and policies. This analysis
should inform a revised analysis of cumulative impacts.
E. The DEIR Improperly Attempts to Defer Mitigation to a Later Date, Fails to
Identify Feasible Mitigation Measures, and Relies on Inadequate Mitigation
Measures
CEQA requires that mitigation measures be identified and analyzed. "The purpose of an
environmental impact report is ... to list ways in which the significant effects of such a project
might be minimized ...." Pub. Res. Code § 21061. The Supreme Court has described the
mitigation and alternative sections of the EIR as the "core" of the document. Citizens of Goleta
Valley v. Board of Supervisors, 52 Cal. 3d 553 (1990). As explained below, the DEIR's 10-37
identification and analysis of mitigation measures, like its analysis throughout, is thoroughly
inadequate. An EIR is inadequate if it fails to suggest mitigation measures, or if its suggested
mitigation measures are so undefined that it is impossible to evaluate their effectiveness. See San
Franciscans for Reasonable Growth v. City and County of San Francisco, 151 Cal.App.3d 61, 79
(1984). Moreover, an ElR may not use the inadequacy of its impacts review to avoid mitigation:
1 19
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"The agency should not be allowed to hide behind its own failure to collect data." Sundstrom v.
County of Mendocino, 202 Ca1.App.3d 296, 361 (1988). Nor may the agency use vague
mitigation measures to avoid disclosing impacts. See Stanislaus Natural Heritage Project v.
County of Stanislaus, 48 Cal.App.4th 182, 195 (1996). Lastly, the formulation of mitigation
measures may not properly be deferred until after Project approval; rather, "[m]itigation measures
must be fully enforceable through permit conditions, agreements, or legally binding instruments."
14 CCR § 15126.4 (a). In the present case, the DEIR does not come close to satisfying these
basic CEQA requirements regarding impact mitigation. Most egregiously, it attempts to defer
discussion and development of suitable mitigation measures until after the certification of the
environmental document and the conclusion of public review.
1
1. The DEIR Improperly Defers Identification of Feasible Mitigation
The DE& impermissibly concludes that all of the project's environmental impacts, with the
exception of cumulative air quality and regional traffic impacts, will be mitigated below a level of
significance, while at the same time deferring necessary analysis of mitigation measures. Under
CEQA, an EIR may conclude that impacts are insignificant only if it provides an adequate analysis
of the magnitude of the impacts and the degree to which they will be mitigated. See Sundstrom,
202 Cal.App.3d at 306 -07. Thus, if an agency fails to investigate a potential impact, its finding of
insignificance simply will not stand. M. Further, CEQA generally requires that all mitigation
measures be adopted simultaneously with, or prior to, project approval. An agency may defer
preparation of a plan for mitigation only when the agency commits itself and/or the project
proponent to satisfying specified performance standards that will ensure the avoidance of any
significant effects. Id. 1
10 -38
In the present case, the DEIR violates CEQA by deferring critical analyses of project impacts and
necessary mitigation. The following is a non- exhaustive list of the project design features and
mitigation measures that the DEIR improperly defers to a later date:
1 • Determination of what constitute fair share fees for traffic impacts.
• Completion of a transit plan. Completion of the plan is deferred until prior to the
first building permit or recordation of Final Map.
• Preparation of the SWPPP.
• Completion of a Phase I Site Assessment.
• Acquisition of permits from the resources agencies for impacts to wetlands and
stream coridors, among other impacts.
• Focused surveys for plants and animals.
20 1
1
I
1
1 • Final wetlands delineation approved by the Corps. Based on the "accepted"
delineation, mitigation, including avoidance of these areas, shall be developed for
wetlands impacted by the project.'
1 • Redesign of the project to avoid historic resources where feasible.
' • Among other deferred mitigation measures.
In each of the above cases of defening specific mitigation, the DEIR finds that potentially
significant impacts will be reduced to less than significant, even where the impact analysis is also
deferred (e.g. unknown at this time what the impacts of the roundabout will be on wetlands, etc.).
Not only will this render the development of specific mitigation too late for public and decision-
maker review to determine the adequacy and efficacy of the plan it is improper under CEQA.
Either specific mitigation measures must be developed at this time, based on complete impact
analyses, or a number of project-related and cumulative impacts must be listed as Significant and
Unavoidable. Such impacts include, but are not limited to impacts related to impacts to:
biological resources, including wetlands, species and wildlife corridors, additional traffic impacts,
' impacts to historic resources, impacts to water quality and transit, among other impacts.
The DEIRs failure to adequately analyze the potentially significant effects of the project, and to
' design proper mitigation measures prior to project approval, renders the document inadequate and
vulnerable to legal challenge. With the DEIR in its current form, decision- makers, the public and
permitting agencies cannot evaluate the advisability of project approval.
2. The DEIR Fails to Identify Feasible Mitigation Measures
' The DEIR's consideration of mitigation is inadequate because it fails to identify several feasible
measures that could reduce or eliminate identified significant impacts. Also, the DEIR fails to
identify some impacts, such as impacts to land use, historical resources and water quality among
others, as significant, and therefore omits identification of feasible mitigation. Mitigat i s
defined by.CEQA as including:
10 -39
(a) Avoiding the impact altogether by not taking a certain action or parts of an action.
(b) Minimizing impacts by limiting the degree or magnitude of the action and its implementation.
(c) Rectifying the impact by repairing, rehabilitating, or restoring the impacted environment.
(d) Reducing or eliminating the impact over time by preservation and maintenance operations
during the life of the action.
(e) Compensating for the impact by replacing or providing substitute resources or environments. J
M
' Again, to the extent that there are other or more extensive wetlands on the site, Exhibit 1 will be modified to
' avoid these areas.
21
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1
CEQA Guidelines § 15370. The DEIR fails to consider measures, which could mitigate in the
fashion described above significant impacts in several resource categories, including, but not
limited to, biology, loss of open space, hydrology and water quality, among others.
Furthermore, the DEIR improperly concludes that all impacts except cumulative air quality and 1
regional traffic impacts, are mitigated to below a level of significance based either on deferred
mitigation measures, as discussed above, incomplete and "future" project features, or on
mitigation measures ofuuproven efficacy. These determinations are not supported by substantial
evidence.
A partial list of impacts that should be identified as significant and unavoidable in a revised
environmental document include, but are not limited to the following: 1) plan and policy
inconsistencies; 2) changes in land use and land use compatibility; 3) project - related and
cumulative drainage and water quality impacts; 4) impacts to biological species, species habitat
and wildlife movement condors; 5) impacts associated with inadequate affordable housing in the
region — air quality and increased traffic -- and 6) cumulative impacts associated with increased
nighttime lighting, loss of habitat and wildlife movement corridors, inadequate water supply,
water quality and traffic impacts, among others. Growth inducement should also be identified as a
significant adverse result of the project unless an adequate analysis proves otherwise. The DEIR
does not include sufficient evidence to identify these and other impacts as less than significant
after mitigation. 1
Finally, the DEIR omits feasible mitigation measures for a number of impacts, including the
following:
1
• Water Quality — A feasible mitigation measure would be to reduce the footprint of f 10 -40
development by clustering the development. See Exhibit 1, Clustered Alternative
Concept.
• Water Quality — A feasible measure, which would effectively address potentially 110 -41
significant impacts to water quality would be to eliminate the golf course. See
Exhibit 1.
• Water Quality — A feasible measure would consist of increasing the setbacks for ` 10 -42
development from water features.
• Inadequate Affordable Housing/Housing to Meet Local Demand — A feasible •
measure would be to increase the number of small units; for -sale units and units
targeting the local, full -time resident market. See Exhibit 1. Also, to build 10 -43
affordable units in first phases of the project and require affordable units to be
permanently affordable. 1
22 1
1
1
• Loss of Open Space — A feasible measure to offset the loss of habitat and open 10 -44
space would be to place an open space mitigation fee ou all new market rate and
resort units /rooms and the golf - course area, if it remains a part of the project.
1 Other feasible measures, in addition to those identified above, must be included in a revised DEIR. I 10 -45
The efficacy of each measure should also be evaluated and proven in the revised DEIR.
F. The DEIR Does Not Adequately Discuss Alternatives to the Proposed Project
' The DEIR fails to adequately analyze alternatives. Under CEQA, an EIR must analyze a
reasonable range of alternatives to the project, or to the location of the project, that would
feasibly attain most of the basic objectives while avoiding or substantially lessening the project's
1 significant impacts. See Pub. Res. Code § 21100(b)(4); CEQA Guidelines § 15126.6(a); Citizens
for Quality Growth v. City of Mount Shasta, 198 Ca1.App.3d 433, 443 -45 (1988). As stated in
' Laurel Heights 1, "Without meaningful analysis of alternatives in the EIR, neither the courts nor 10-46
the public can fulfill their proper roles in the CEQA process ... [Courts will not] countenance a
result that would require blind trust by the public, especially in light of CEQA's fundamental goal
that the public be
fully informed as to the consequences of action by their public officials." 47 Cal.3d 376, 404
( 1988). The DEIRs discussion of alternatives fails to meet these standards.
First, none of the development alternatives are "transparently" based on a comprehensive
' constraints map that identifies areas of high resource values and areas that should be avoided
based on Town and other guiding policies and regulations. A revised analysis should include an
alternative based on a site constraints map, which illustrates current information about high value
' resources, wildlife corridors, hazard areas, among other environmental features on the site. This
alternative should also cluster development in a true cluster development pattern. See Exhibit 1. 10_47
1 Second, an alternative or alternatives should be developed which provide for housing to meet
local needs, rather than resort/second home markets. See also Exhibit 1.
Third, at least one development alternative should include additional local passive recreation uses
in lieu of the golf course. See also Exhibit 1. .
$ In the absence of additional alternatives that address project - related impacts and local needs, the
` range of alternatives presented in the DEIR is inadequate.
1 CONCLUSION
' As set forth above, the DEIR suffers from numerous deficiencies, many of which would
10-48
independently render it inadequate under CEQA. Taken as a whole, the deficiencies of the DEIR
are so pervasive as to necessitate further extensive revision of the document— and recirculation fort
1 23
1
1
public comment. The project should not be considered further until a legally adequate EIR is
1 prepared.
In the alternative, MAPF and Sierra Watch support further review of project alternatives for this 1
site as part of the General Plan update and update DEIR
Very truly yours,
1
`j < Wa—
Terrell Watt, AICP ,
CC. 1
U.S. Fish and Wildlife Service
California Department of Fish and Game
U.S. Army Corps of Engineers
Lahontan Regional Water Quality Control Board
Mother Lode Chapter of the Sierra Club
i 1
1
1
1
1
24 1
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2.0 RESPONSE TO COMMENTS
1
LETTER 10 TERRELL WATT, AICP, TERRELL WATT PLANNING CONSULTANTS
Response to Comment 10 -1
This comment describes the organizations on whose behalf the comment letter is
submitted. Since this comment does not address the adequacy of the Draft EIR, no
' further response is required.
Response to Comment 10-2
•
The commentor provides a Clustered Alternative Concept (attached as Exhibit 1 to
Comment Letter 10), and requests that this concept be analyzed. The alternative
provided by the commentor is briefly discussed below under the same environmental
issue areas provided in the Draft EIR. Further, some additional information has been
provided by the project applicant regarding the economic viability of the proposed
Clustered Alternative Concept below.
Economic Viability
1 According to the project applicant, the proposed Gray's Crossing project provides a
. variety of housing options, including affordable, employee, attached, cottage,
secondary units and a range of single - family residences, which allows for a mixture of
social relationships to occur. Providing the opportunity for people with a wide range of
income levels to live in one community enhances social integration. Moreover, the
alternative concept may result in physical impediments to the construction of
secondary units due to smaller lot sizes.
The economic success experienced at Old Greenwood points to the fact that the
applicant is competent at designing and developing destination recreational
communities that are appealing to the marketplace. The proposed Gray's Crossing
' project would take this effort a step further by also addressing the housing needs and
demands of local residents consistent with the Town's General Plan. However, the wide
range of housing can only be accommodated with the single - family lots, some with golf
course frontage, that would be the economic engine that would allow for an array of
affordable housing as well. Restricting the variety of housing options, as is done with the
alternative concept, would inhibit the ability of the proposed project to provide the
desired affordable and workforce housing. In addition, the alternative concept
appeals to only a limited market segment whereas the proposed project responds to a
. broader market demand.
I Also, the applicant has reviewed and analyzed the "no golf" and "reduced lot size"
alternatives. According to the applicant, the significant reductions in value and
revenues, as well as the limited market appeal and demand, associated with these
alternatives, and particularly a combination of the two, would reduce the project's
return to such a level the project would become infeasible economically. The
' applicant has also stated that this loss of value and revenues would likewise result in the
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -84 September 2003
2.0 RESPONSE TO COMMENTS
inability to secure the community facilities district financing that is being pursued by the
project and any other financing that would be necessary for the viability of the project.
•
Finally the alternative concept would limit the ultimate value of the property for
purposes of property tax revenue. This could compromise the fiscal integrity of the
project by systematically reducing property tax revenues necessary to cover the cost of
Town services.
See also Appendix J detailing additional viability concerns regarding a nine -hole golf
course alternative, which was prepared by Economics Research Associates at the
request of the project applicant.
Environmental Issue Areas 1
Land Use
Under the Clustered Alternative Concept, an additional approximately 300 acres of
natural open space would become available with the reduction in lot sizes, elimination
of the.golf course and associated facilities, reduction in commercial /retail area, and
placement of all development south of Prosser Dam Road. Regardless, the Clustered
Alternative Concept is not consistent with the Town's General Plan.
One of the primary goals and policies of PC -2 (as outlined under policies #6 and #7 for 1
PC -2 in the Town's General Plan) is to develop the site as a "destination recreational
community." As such, a variety of amenities, such as golf, hiking, lodging, and a trail
system, are contemplated to be part of the plan. The Clustered Alternative Concept
does not fulfill Truckee's General Plan goal of utilizing PC -2 as a destination recreational
community, including a golf course and lodge.
In addition, while the alternative concept would address the residential housing needs
of some sectors of the community, it would not create a resort environment, a primary
goal of the General Plan. There is no lodge or active recreational amenities. The
proposed project provides a destination resort community, as well as housing
opportunities for a broad segment of the local community. '
The intent behind the PC -2 designation in the Town's General Plan was to allow
Truckee, through the proposed project site, to compete in the resort market, as is
currently being done by other successful resorts in the area. In fact, the General Plan
specifically earmarked other locations throughout the community for residential uses
only. The alternative concept is not consistent with the specific goals or intent of the
Town's General Plan.
Population, Housing and Employment
Impacts under the Clustered Alternative Concept would vary from those under the
proposed project. With the elimination of the golf course and associated facilities and
lodge, as well as a reduction in the commercial /retail area, there would be a
commensurate and significant reduction in the number of year -round and seasonal
employment opportunities generated. The clustered alternative calls for retaining the
100 affordable /employee housing units, which would mean its has a similar impact
Town of Truckee Final Environmental Impact Report
September 2003 2 -85 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
related to the provision of affordable /employee housing per General Plan guidelines.
• The jobs- housing balance would be improved as there would be a significant reduction
in employment opportunities associated with the project while there would remain the
same number of affordable /employee housing. (Note: as a reminder to the reader,
Alternative 3 (the Density Increase Option) provides for an additional 103 housing units
' (a percentage of which would be affordable depending on negotiations between the
Town and the project applicant), above what is provided in both the proposed project
and Clustered Alternative Concept, which represents up to a 100 percent increase in
1 the number of affordable housing units.)
The Clustered Alternative Concept provides for less expensive homes than the
' proposed project, which may support the Town's goal of increasing affordable housing
opportunities. However, as discussed above and in Appendix J, a reduction in the
availability of higher -end market homes and the elimination of the golf course would
' make the project financially unviable to the applicant.
Visual Resources /Light and Glare
' In general, impacts under the Clustered Alternative Concept would be similar to those
under the proposed project, as residential and commercial development on the
southern portion of the project site, especially adjacent to SR 89, was the area
' pinpointed by the Draft EIR as visually sensitive. In order to accomplish the alternative
concept, approximately 105 acres in the southern portion of the project site would be
cleared of most vegetation, which would substantially change . the site's visual
' characteristics from adjacent properties, as well as within the development. As
evidenced by the attached aerial photograph and cross - section (see Appendix R),
due to the Clustered Alternative Concept's lack of consideration of natural features this
' heavily treed area would be lost. Development proposed for the area north of Prosser
Dam Road and west of SR 89, as part of the proposed project, was determined to have
less than signficant visual impacts in the Draft EIR. As they would for the proposed
1 project, mitigation measures identified in Section 4.9 would reduce potential visual
impacts associated with this alternative.
' Transportation and Circulation
Impacts under the Clustered Alternative Concept would be similar to those under the
proposed project. There are similar residential unit counts and a village center similar to
' the proposed project. The clustering of residential units may exacerbate impacts in a
specific area, whereas the project spread the movement of traffic around to several
areas. However, the elimination of the golf course, lodge, and associated facilities, as
' well as the reduction in commercial /retail area would result in an incremental decrease
in average daily trips. As they would for the proposed project, mitigation measures
identified in Section 4.2 would reduce potential traffic impacts associated with this
alternative.
Air Quality
Impacts under the Clustered Alternative Concept would be similar to those under the
1 proposed project.. However, there would be an incremental reduction in emissions from
project- generated traffic as a result of the elimination of the golf course, lodge, and
' associated facilities, as well as the reduction in commercial /retail area. As they would
Final Environmental Impact Report Town of Truckee
111 Gray's Crossing Specific Plan Project 2 -86 September 2003
2.0 RESPONSE TO COMMENTS '
for the proposed project, mitigation measures identified in Section 4.4 would reduce 1
potential air quality impacts associated with this alternative.
• Noise 1
In general, noise impacts under the Clustered Alternative Concept would be similar to
those of the proposed project. However, traffic generated noise would be
incrementally reduced as a result of the elimination of the golf course, lodge, and
associated facilities, as well as the reduction in commercial /retail area. As they would
for the proposed project, mitigation measures identified in Section 4.3 would reduce
potential noise impacts associated with this alternative.
Biological Resources
Impacts under the Clustered Alternative Concept would be less than those under the
proposed project. Development under the Clustered Alternative Concept would lessen
the amount of overall disturbance to the natural habitat and mixed pine forest area.
The overall reduced area of disturbance would provide additional permanent open
space, which would benefit both resident and special status plant and wildlife species.
No development north of Prosser Dam Road, in particular, and providing a sufficient
buffer along the floodplain of the intermittent drainage on the southern portion of the
project would benefit the use of these riparian zones (which are the most highly utilized
movement corridors for resident wildlife) by resident wildlife. The concentration of
development on the southern portion of the project site would reduce its value for
wildlife use. Further, with the elimination of the golf course, there would be significant
reduction in onsite traffic (i.e., golf carts and individuals walking the course), and this
would lessen the amount of human disturbance on wildlife in the open space areas
within the project site. As they would for the proposed project, mitigation measures
identified in Section 4.7 would reduce any potential biological resources impacts
associated with this alternative.
Geology and Soils
While there would be a reduction in the amount of development area as this
alternative proposes the elimination of the golf course, lodge, and associated facilities,
as well as a reduction in commercial /retail area, the intensity of disturbance of natural
slopes and geologic conditions from construction and grading activities on the project
site may potentially be increased under this alternative because the alternative
concept will result in mass grading and clearing that will significantly alter the natural
features of the southern portion of the property. As reflected on the attached croos-
section depiction, this alternative would result in mass grading of two specific areas
(see Appendix R). In the area south of the meadow and south of Prosser Dam Road, ,
the alternative concept would most likely result in a 25 foot cut and 25 foot fill to
balance the earthwork. This area is approximately 1,470 feet wide and approximately
3,200 feet deep, totaling almost 105 acres. Unlike the proposed project, the
alternative concept has not been designed within the context of the site's natural
features. The proposed project proposes roadways along existing contours, leaves
each of the individual lots ungraded and requires individual buildings to be designed to
fit the terrain, and allows the natural integrity of the on -site vegetation to remain intact.
The alternative concept overlays roads and structures onto the property with no
apparent forethought of these environmental constraints.
Town of Truckee Final Environmental Impact Report
September 2003 2 -87 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
For this alternative, potential impacts to soil erosion, shrink -swell potential, and
hazardous materials could be mitigated to less than significant levels using mitigation
measures identified in Section 4.5. Overall, impacts associated with the proposed
project would be similar or slightly increased under this alternative.
' Hydrology and Water Quality
The potential for water quality impacts under the Clustered Alternative Concept may
be reduced compared to those under the proposed project as potential water quality
impacts associated with the golf course, including the use of fertilizers, pesticides and
herbicides, would be eliminated with the elimination of the golf course. The overall
amount of impervious surface onsite would be slightly reduced from the proposed
' project (it should be noted that the 108.5 acre golf course as part of the proposed
project would have served as a pervious surface so the difference between "disturbed"
and "undisturbed" open space is not as significant from a percolation standpoint). The
' storm water runoff from surfaces, such as the 100 acres of contiguous impervious
surface area proposed by the alternative, would result in the need for significant
retention basins in accordance with Lahontan Regional Water Quality Control Board
' standards. Detention basins would further increase the removal of on -site vegetation
and trees. Conversely, the proposed project utilizes the natural features of the land to
cluster neighborhoods together which reduces grading, and allows natural features to
' be used to assist in the filtration of storm water runoff.
Finally, the elimination of the golf course, lodge, and associated facilities, as well as the
' overall reduction in commercial /retail area would reduce project demand for water for
irrigation and domestic use by up to approximately 290 of /yr. This represents
approximately 50 percent of the proposed project's overall projected water demand.
This would reduce the amount of reliance on groundwater supplies, but as the
proposed project did not have a significant impact on groundwater, the level of
impact is comparative.
Ultimately, mitigation measures identified in Section 4.7 would serve to reduce impacts
from the Clustered Alternative Concept to a less than significant level much in the same
' way that they do for the proposed project.
Cultural Resources
Impacts under the Clustered Alternative Concept would be reduced compared to
those under the proposed project. Fewer cultural resources would be affected, since
more natural open space would be retained under this alternative, and the total area
' of disturbance would be reduced by up to 150 acres. As they did for the proposed
project, mitigation measures identified in Section 4.7 would serve to reduce impacts
associated with this alternative to a less than significant level.
' Community Services
Impacts under the Clustered Alternative Concept would be similar to those under the
proposed project. As less development would occur under this alternative, there would
be a resulting decrease in the Town's revenue base that contributes to such services as
police and fire services, and there would also be an decrease in impact fees for school
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -88 September 2003
2.0 RESPONSE TO COMMENTS
and park facilities. Impacts and mitigation measures identified in Section 4.10 related 1
to community services would be similarly relevant to this alternative.
Utilities and Service Systems 1
Impacts under the Clustered Alternative Concept would be less than those under the
proposed project, the elimination of the golf course, lodge, and associated facilities, as
well as the overall reduction in commercial /retail area would reduce project demand
for water for irrigation and domestic use and reduce wastewater and solid waste
generation. The elimination of the golf course and other commercial /retail and lodging
facilities would reduce water demand by approximately 290 of /yr. This represents
approximately 50 percent of the project's overall projected water demand. However,
the project as proposed already represents a significant reduction in the anticipated '
water projections made by the TDPUD for the project site.
Response to Comment 10 -3 •
This comment suggests general deficiencies in the project Draft EIR. This comment is
noted and is included for the Town Council's Consideration. With respect to delaying
project approval until after the Town's General Plan Update is complete, see Master
Response 2.4.5 General Plan Consistency. Since this comment does raise any other
specific issues regarding the adequacy of the EIR, no further response is required.
Response to Comment 10 -4
The commentor believes that consideration of the project is premature, and that it
1
should be included in the Town's General Plan Update. See Master Response 2.4.1
Employee /Affordable Housing and Master Response 2.4.5 General Plan Consistency.
The commentor also cites an article from Barron's which voices concern about the
number of golf courses being constructed and claims that the popularity of golf as a
sport is in decline. The comment is noted and presented here for the consideration of
the Town Council.
Response to Comment 10 -5
1
The commentor believes that because the project requests General Plan Amendments,
it should be included in the Town's General Plan Update. See the Master Response
2.4.5 General Plan Consistency.
•
With respect to the project's proposed gas station, the Draft EIR acknowledges that
locating an eight station 16 -pump service station within the Village Center is
inconsistent with the Truckee General Plan (Draft EIR, Impact 4.1.3). Chapter 2 of the
Land Use Element states that "development on the north side of the Interstate 80 /SR 89
North interchange shall not be freeway oriented and shall be substantially screened
from I -80" (Truckee General Plan page 42). General Plan Land Use Policy 2.1 states that
freeway oriented commercial uses are those which cater to travelers along Interstate
80, such as gas stations and fast food restaurants (Draft EIR page 4.1 -26 to 27). MM 4.1.3
requires the project's service station to be reduced in capacity from an eight station 16-
1
1 Town of Truckee Final Environmental Impact Report
September 2003 2 -89 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
pump service station to a four station 8 -pump station, which is more reflective of a
neighborhood fueling station. Although the Draft EIR concludes that this change
ensures General Plan consistency, the ultimate determination of consistency rests with
the Town Council.
Regarding public play at the project golf course, the Draft. EIR provides that a private
golf course, which was proposed as part of the Specific Plan, would be inconsistent with
PC -2 policies in the Truckee. General Plan (Draft EIR, Impact 4.1.4). MM 4.1.4 addresses
this potential inconsistency. Pursuant to MM 4.1.4, the project golf course must provide
limited use to lodge guests, as well as the public. Thus, the course would be semi-
private, which means that it has members, but is also open to the public and visitors at
' special times. The Draft EIR provides the example that public tee times would be
available two- and - one -half days per week: Wednesdays and Thursdays all day and
Saturday from noon to 2 p.m. The specific details regarding public play, however,
' would be worked out between the project applicant and the Town. For a more
detailed discussion of public play, see pages 4.1 -27 to 28 of the Draft EIR.
' With respect to an alleged inconsistency with required setbacks from highways, it is
unclear from this comment what requirement is at issue. The Draft EIR addresses
setbacks primarily in Section 4.9 as they relate to visual resources and scenic corridors.
' SR 89 in the vicinity of the project site is considered a scenic corridor. Impact 4.9.2
addresses Policy 4.3 and PC -2 Policy 5 in the Town's General Plan, which require the
preservation and maintenance of viewsheds along scenic corridors (Draft EIR, Impact
1 5.9.2). The Town's Scenic Corridor Standards address SR 89 north of 1 -80 in Section
18.46.070 of the Development Code and according to Sheet 31 of the Town Zoning
Map, the scenic corridor development standards extend 300 feet on each side of SR 89
1 (see Draft EIR pages 4.9 -10 to 15).
• The project, as proposed, would develop within the 300 -foot set back area, including
the commercial Village Center. Because the SR 267 Bypass was not anticipated by
these provisions and because the Village Center should be welcoming to passing
motorists, MM 4.9.2a provides several options to the Town Council to address this
potential inconsistency. Options include allowing this limited development within the
300 foot set back area as a policy decision, requiring the applicant to pursue a
variance to allow encroachment within the 300 foot set back area, or requiring the
applicant to modify the tentative map for the project (Draft EIR pages 4.9 -13 to 14). This
decision and the ultimate determination of consistency with the General Plan rest with
the Town Council.
1 This comment also asserts that the General Plan's development intensity standards are
inadequate, which precludes a finding that this project is consistent with the General
1 Plan. The Town's General Plan was adopted in 1996. The 90-day statute of limitation on
challenging the adequacy of the General Plan has run (Gov. Code, § 65009, subd. (c);
A Local & Regional Monitor v. City of Los Angeles (1993) 16 Cal. App. 4th 630, 648 -649).
I The General Plan must now be presumed valid to provide stability and to allow local
land use decisions to proceed. Thus, to avoid paralyzing local government, consistency
requirements are interpreted with some flexibility. Under CEQA, a project is consistent
with a general plan if it will further the objectives and policies of the general plan and
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -90 September 2003
2.0 RESPONSE TO COMMENTS
not bar their attainment. A project need not be in perfect conformity with every ,
general plan policy. To be consistent, a project must be compatible with the
objectives, policies, general land uses and programs specified in the general plan
(Napa Citizens for Honest, supra, 91 Cal.App.4th at p. 378; Families Unafraid to Uphold
Rural 8 Dorado :County, supra, 62 Cal. App. 4th 1332, 1336). The Draft EIR prepared for
the project determined that the project is consistent with the Town's General Plan. As
discussed above, however, the ultimate determination of consistency rests with the
• Town Council.
And finally, with regard to the project's consistency with proposed land uses on the
52.3 -acre parcel on the eastern boundary of the project, a modification of the
proposed project has been proposed to ensure consistency with the General Plan. See
the Master Response 2.4.5 General Plan Consistency.
Response to Comment 10 -6
This comment describes general legal standards governing the adequacy of an EIR
and subsequent approvals required for the project (Draft EIR page 1 -3). Since this
comment does not raise any specific issues regarding the adequacy of the Draft EIR, no
further response is required.
Response to Comment 10 -7
1
This comment describes general legal standards governing the adequacy of the
Project Description and environmental setting in an EIR. This comment states that the L
project Draft EIR fails to provide an adequate environmental setting for the project and
fails to describe key aspects of the project. No specific omissions from the
environmental setting are mentioned and no specific aspects of the project that the EIR
failed to disclose are raised. The Draft EIR provides a detailed Project Description in
Section 3.0. This section of the Draft EIR discusses .011 components of the project and
provides a detailed analysis of the local and regional setting. Additional information on
the existing environment is provided in each impact analysis section of the Draft EIR.
Since this comment does not raise any specific issues regarding the adequacy of the
Draft EIR, no further response is required. ,
Response to Comment 10 -8
The commentor states that the Draft EIR does not include a complete description of 1
proposed uses at the project site, including details regarding housing units. See Master
Response 2.4.1 Employee /Affordable Housing and Response to Comment 5-3.
Additionally, the Draft EIR indicates the percentages of residential units that will be used
as full -time residences on page 4.2 -25.
•
With respect to potential second units that could be developed in the project area .
under new state law, we assume the commentor is referring to AB 1866, which modified
Government Code Section 65852.2. Notably, throughout this comment the terms
second unit and resort unit are used somewhat interchangeably. They can apply,
however, to different types of residential development. To clarify, resort units are those
•
•
Town of Truckee Final Environmental Impact Report
September 2003 2 -91 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
units that would be purchased by individuals as second homes or vacation homes.
These units, therefore, would presumably be occupied on a part time basis by one or
11 more families. If multiple families owned an interest in the same vacation or resort unit
this would be considered fractional ownership. A second unit as used in AB 1866, or
secondary unit, as they are referred to in the Truckee Development Code, is a second
11 permanent dwelling that is an accessory to a primary dwelling on the same site, which
provides complete, independent living facilities for one or more person, including
permanent provisions for living, sleeping, eating, cooking, sanitation, and parking
(Truckee Development Code, §§ 18.220.020, 18.58.230).
AB 1866 makes approval of second units ministerial as opposed to discretionary when
an agency has a second unit ordinance in place (Gov. Code, § 65852.2, subd. (a)(3)).
This change applies to Truckee because the Town has adopted a secondary unit
ordinance (see Truckee Development Code, § 18.58.230). Truckee's ordinance provides
1i • that "secondary units are allowed in the DRS [Downtown Single Family Residential], DRM
[Downtown Medium Density Residential], RR [Rural Residential] and RS [Single Family
Residential] zoning districts" (Truckee Development Code, § 18.58.230 subd. (A)).
11 Although the project area is designated PC (Planned Community) in the Town's Zoning
Code, the project area will be rezoned as part of the specific plan process so that
zoning designations correlate to planned land uses. For example, areas of the project
designated for single family residential use would be zoned RS and areas designated for
commercial use would be designated as General Commercial or GC (Truckee
Development Code, § 18.58.230 subd. (A); see also Truckee Zoning Map; pers. com.
Tony Lashbrook, Truckee Planning Department (rezone to match use as part of specific
plan process)). For areas zoned RS, including the project's 410 planned single - family
11 residential lots, approval of second units would be ministerial, not discretionary under AB
1866.
The Town's General Plan Housing Policies, however, already require the Town to
"[p]ermit secondary units by right in single - family residential areas where it is determined
that adequate infrastructure exists to serve the second unit" (Truckee General Plan,
Housing Policy 1.2.3). Because the Town's General Plan already mandates approval of
secondary units as a matter of right in certain zones and subject to certain infrastructure
requirements, this new state law does not change the number of second units that
could be developed in the project area. Possible second units for the project's single -
family homes are mentioned in the Specific Plan and discussed in the Draft EIR
(Specific Plan page 48, Draft EIR page 3 -31). Although it is unlikely that all of the future
11 owners of the project's single - family residential units would apply to construct secondary
units, the potential exists for 410 second units within the project area. For the purposes
of environmental analysis, the EIR assumed that 20 percent of the single - family
11 residential units will have a secondary dwelling, resulting in an approximate total of 82
secondary residential units (Draft EIR page 3 -31). Beyond this planning assumption,
determining how many future property owners may apply for second units constitutes
speculation not required under CEQA.
As to concerns raised by the commentor regarding water quality and future monitoring,
please see Master Response 2.4.3 .Water Quality and Response to Comment 1 -6. In
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -92 September 2003
2.0 RESPONSE TO COMMENTS 1
addition, attached as Appendix A is a preliminary Draft of the Audubon International 1
Natural Resource Management Plan (NRMP), which spells out special precautions for
the use of fertilizers and pesticides in sensitive areas, including wetlands, meadow
areas, and creeks. Also available in the Draft NRMP is a comprehensive water quality
monitoring program to ultimately be reviewed and approved by the Lahontan RWQCB.
Response to Comment 10 -9 1
The commentor states that the Draft EIR does not provide an adequate description of
project- related and cumulative construction activities. See Master Response 2.4.6
Construction Impacts and Master Response 2.4.2 Cumulative Impacts. Construction
noise impacts are addressed in Impact 4.3.4 of the Draft EIR. Due to the myriad
possibilities for combinations of construction equipment types, locations, and duration
of operations, it is not feasible to precisely predict construction noise levels. Although
construction activities will be temporary in nature, and would occur during daytime
hours, a finding of significant noise impact was made for this aspect of the project, and
mitigation measure 4.3.4 was applied to address this impact.
Response to Comment 10 -10 1
See Master Response 2.4.5 General Plan Consistency and Responses to Comment 10 -5
1 and 10 -8. This comment also raises the issue that plans, policies, and regulations
produced by trustee and permitting agencies, including the Corps, CDFG, and the
Lahontan RWQCB, were not evaluated for consistency with the project in the Draft EIR.
1 This comment, however, does not mention any specific plans, policies, or regulations
produced by these agencies that should have been addressed. These agencies
generally have independent permitting authority over the project, which they rely on to
1 enforce federal and state statutory requirements. For example, although the Corps
and the Department of Fish and Game do not produce regional or local plans, these
agencies have independent permitting authority over projects. If the Corps is not
satisfied with a project's compliance with its statutory requirements regarding the fill of
wetlands (33 U.S.C. § 1344), it can deny a fill permit, thereby precluding development
absent avoidance of all jurisdictional wetlands. Of the agencies mentioned in this
comment, only the Lahontan RWQCB produces a regional plan. The Lahontan RWQCB
1
Basin Plan is applicable to the project and serves the basis for the Board's regulatory
program. The EIR indicates that as part of this Program the Lahontan RWQCB will
independently review the project's NPDES permit application and SWPPP for
compliance with the Basin Plan (see Draft EIR, MM 4.6.3, 4.6.4, 4.6.9a).
CEQA Guidelines Section 15125 subdivision (d) requires an EIR to "discuss any 1
inconsistencies between the proposed project and applicable general plans and
regional plans. Such regional plans include, but are not limited to, the applicable air
quality attainment or maintenance plan or State Implementation Plan, area -wide
waste treatment and water quality control plans, regional transportation plans, regional
housing allocation plans, habitat conservation .plans, natural community conservation
1 plans and regional land use plans for the protection of the coastal zone, Lake Tahoe
Basin, San Francisco Bay, and Santa Monica Mountains." (Note that the project is
outside of the Lake Tahoe Basin as governed by the Regional Plan for the Lake Tahoe
Town of Truckee Final Environmental Impact Report
September 2003 2 -93 Gray's Crossing Specific Plan Project
I 2.0 RESPONSE TO COMMENTS
1 Basin available at www.trpa.orq and there are no governing HCPs
www. ecos2. fws .qov /plansServlet /PlanSelect. The Draft EIR's analysis satisfies this
1 requirement.
Response to Comment 10 -11
The commentor suggests that the Project Description omits information that has the
potential for resulting in significant impacts. See Responses to Comments 10 -5 and 10-8.
I Additionally, the Draft EIR provides detailed information on square footage of non-
residential uses as well as acreage for commercial and residential lots on pages 3 -23 to
24 and 4.2 -24. Tentative maps for all phases of the project are also provided. Non-
I residential uses associated with the Village Center and the golf course are shown in
detail in Figure 3 -11 (see Draft EIR, Figures 3-7 to 11). See also Figure 3-11 in the Project
Description of the Draft EIR, which provides square footage for building footprints in the
I Village Center and at Golf Parcel 3 (fitness center, pro shop, locker rooms, dining area).
The commentor requests a draft of the proposed development agreement. In the
I present case, the comment period for the Draft EIR will have concluded before the
Development Agreement is finalized. Nonetheless, the public will be kept appraised of
the status of the Development Agreement for the project. Approval of a Development
I Agreement is a legislative act that will be the subject of a noticed public hearing (Gov.
Code, §§ 65867, 65867.5). There is, however, no requirement that the Development
Agreement for the project be circulated.
The commentor inquires about the extent of public play at the golf course. Please refer
to Response to Comment 10 -5.
Il The commentor requests additional information regarding the specific sources of water
for various components of the project. For information regarding water supply, please
I refer to Master Response 4.2.7 Water Supply.
The commentor states the EIR is inadequate because it does not contain water supply
1 verification information under SB 221 and SB 610. Please refer to Master Response 2.4.7
Water Supply.
The commentor references a Guidebook published by the Department of Water
Resources. The commentor is referring to the following document: California
Department of Water Resources, Draft Guidebook for Implementation of Senate Bill 610
' and Senate Bill 221 of 2001 (Draft September 25, 2002). This publication has been issued
• in draft form: In addition, even if this publication were issued in final form, it would
constitute non - binding guidance, rather than a binding regulation. In any event, the
I water supply information in the Draft EIR for Gray's Crossing has been prepared in light
of the guidance set forth in the draft guidebook.
I The commentor states the Town should revise the analysis in light of the
recommendations set forth in a report prepared by Acton Mickelson (September 5,
2001). Please see Master Response 2.4.7 Water Supply.
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -94 September 2003
2.0 RESPONSE TO COMMENTS I
The commentor requests additional information regarding the number of second units 1
that could be built. Please refer to Response to Comment 10-8.
Response to Comment 10 -12 1
The commentor states that the Draft EIR does not provide complete setting information
needed to adequately analyze the project and any cumulative effects, including
information related to wetlands, water supply, biological resources, affordable housing
needs, and similar projects in the region. See Master Response 2.4.4 Biological
Resources, Master Response 2.4.1 Employee /Affordable Housing, and Master Response
2.4.7 Water Supply.
This comment also requests that the U.S. Army Corps of Engineers (Corps) verification of
1
the project's wetlands delineation be provided. The project's, wetlands delineation is
included as Appendix G1 to the Draft EIR. There is no requirement to provide the Corp's
verification of the wetlands delineation as part of the EIR. The verification, however,
must be obtained by the project applicant before the project can proceed. MM
4.7.8b requires the wetland delineation study and map prepared by EcoSynthesis be
submitted to the Corps for review and verification prior to the issuance of a grading
permit. Also pursuant to this measure, the appropriate Section 404 CWA permit must be
acquired if impacts to waters of the U.S. cannot be avoided and any wetlands that
would be lost or disturbed must be replaced or rehabilitated on a "no net loss" basis in
accordance with the Corps mitigation guidelines (Draft EIR pages 4.7 -29 to 31).
Additionally, the Resume /Vitae for Dr. Adrian Juncosa, Senior Ecologist for EcoSynthesis
Scientific, who prepared the wetlands delineation for the project, has been attached
(see Appendix 1).
With regard to information requested by the commentor regarding existing and
1
planned "resort" units similar to those proposed by the project, as well as existing and
planned golf courses in the region, Table 3 -1 in the Project Description of the Draft EIR
provides a list of land use projects in the Mortis Valley area that are either proposed,
under application, or recently approved. The projects' table is not intended to be all -
inclusive of all development activity in the region, but rather a description of large -scale
projects in the region that the project may share cumulative impacts with. Table 3 -1 lists
the number of units for each project and whether a golf course is proposed as part
proposal. The request by the commentor for additional market study information and
unsold resort units is outside the scope of the Draft EIR, but is provided here for the
consideration of the Town Council.
Response to Comment 10 -13 1
This comment describes general legal standards governing the adequacy of an EIR.
This comment states that the project Draft EIR fails to provide necessary facts and
1
improperly attempts to defer analysis. No specific omissions of fact or instances of
improper deferral are discussed in this comment. The EIR serves as an informational
1 document and provides complete and accurate factual information on the project
(Draft EIR, Section 3). Mitigation and environmental analysis are not improperly
deferred. In certain instances more detailed analysis, such as final site surveys and
Town of Truckee Final Environmental Impact Report
September2003 2 -95 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
1 preparation of a SWPPP, will take place after project approval to account for changes
to the project required as part of the planning process. For example, final survey for
1 nesting birds will take place immediately before construction because nesting sites are
not currently occupied (see MM 4.7.5). Such practices are common and do not
constitute improper deferral. Since this comment does not raise any specific issues
1 regarding the adequacy of the Draft EIR, no further response is required.
Response to Comment 10 -14
The commentor states that the Draft EIR's analysis of air quality impacts is understated,
particularly with respect to construction related air quality impacts. See Master
Response 2.4.6 Construction, Master Response 2.4.1 Employee /Affordable Housing, and
,• Master Response 2.4.2 Cumulative Impacts.
' See Response to Comment 10 -9 regarding construction emissions and phasing. Given
• the uncertainty regarding schedule and the variability of construction emissions from
day to day as well as seasonally any attempt to quantify cumulative construction
emissions for multiple projects would be too speculative to be of use. The Draft EIR
found that construction emissions were significant and requires appropriate mitigation.
It should be noted that construction activity is an identified cumulative source of
emissions that is currently included in the Town. of Truckee Particulate AQMP. It is not
possible to determine whether construction at any specific project is included or not in
the AQMP's inventory of emissions, so the worst -case assumption that project emissions
represent new emissions was made.
•
The Draft EIR .utilized the URBEMIS -2001 program that calculates emissions from all trip
types, including employee travel. The analysis of trip generation upon which the air
quality analysis was based did not provide information on average trip length by trip
1 type. In the absence of such data, default values for the air basin were used, as
directed by the Northern Sierra AQMD. It is speculative to presume that the project
would result in trip lengths greater than the default values for the air basin. If such an
1 effect did occur, it would not affect the Truckee air basin, since this travel would occur
outside the basin.
The project's air quality impacts are addressed in Section 4.4 of the Draft EIR Air Quality.
The Draft EIR discusses cumulative impacts in this section and in Section 5. This section
of the Draft EIR analyzes the cumulative impacts of approved, proposed, and under
' application projects in the Martis Valley region against the backdrop of the Town's 1996
General Plan EIR (Draft EIR page 5 -2). Cumulative air quality analysis utilizes the
"summary of projections" approach based on General Plan build -out to determine
level of impact. The analysis is based on conditions within the entire air basin, which
extends well beyond the bounds of the Martis Valley (Draft EIR page 5 -3).. The Draft EIR
determines that cumulative air quality impacts remain significant and unavoidable, in
spite of proposed mitigation (Draft EIR, Impact 5 -6). ,Mitigation measures, including the
Air Quality Mitigation Fund, were adopted in order to address region -wide impacts
(Draft EIR, MM 4.4.4b, page 4.4 -17).
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -96 September 2003
2.0 RESPONSE TO COMMENTS
•
Response to Comment 10 -15
The commentor requests additional analysis regarding the project's consistency with
the Town's General Plan. See the Master Response 2.4.5 General Plan Consistency and
Response to Comment 10 -10 regarding the project's consistency with other applicable
policies and regulations.
1
Consistency is evaluated as a component of each impact area in the relevant EIR
environmental analysis section. Where policies appear to be omitted in a particular
section they are generally reviewed for consistency under a more applicable impact
area. Certain policies, however, that were determined not to be applicable to the
project were omitted. For example, Conservation and Open Space Policy 1.2 requires
the Town to "je]stablish an Open Space Zone District along both sides of the Truckee
River outside of the Downtown Study Area which prohibits all commercial, residential,
and industrial development within a minimum of 150 feet of either side of the River..:'
Because the Truckee River does not pass through the project area, this policy is
inapplicable to the proposed project. An additional review of the General Plan's goals
and policies was conducted to confirm that all general plan goals and policies relevant
to the project were evaluated in the Draft EIR. A full list of the General Plan's goals and
policies is available for review as part of the Town's General Plan. The Truckee General
Plan is available at the Town's Community Development Department or on line at
<http: / /www.truckee2025.org/ 96genlplan /gpcont.htm >.
•
Response to Comment 10 -16
The commentor states that the project description fails to include all components of the
project that could generate traffic including, but not limited to, construction - related
traffic, second units, and the activities that will use the resort/conference facilities. Each
of these items are addressed individually below under the sub - headings Construction
Traffic, Traffic Generated by Second Units, and Traffic Generated by the Conference
Facility. See also Response to Comment 10-8.
Construction Traffic:
An analysis of construction - related traffic has been conducted. Traffic generated by
employees, truck hauling, materials delivery, .and concrete pours under Phase II has
been estimated by SCO Engineering, as the most intense construction traffic would
1
occur under this phase. The traffic generated by Phase I would be negligible as it
would primarily consist of the construction of single - family dwelling units over a long
1 period of time.
On page 4.2 -47 of the Draft EIR the following text shall be added between Table 4.2 -14
and Impact Statement 4.2.1.
1
• Construction Traffic
0 is important to analyze traffic generated by construction activities in addition to
the traffic generated by the project land uses. Traffic generated by employees,
1
Town of Truckee Final Environmental Impact Report
September 2 -97 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
1 truck hauling, materials delivery, and concrete pours under Phase 11 has been
estimated by SCO Engineering, as the most intense construction traffic would
I occur under this phase (see Appendix M in the Final EIR for estimated
construction traffic). The traffic generated by Phase 1 would be negligible as it
would primarily consist of the construction of single - family dwelling units over a
I longer period of time. The results of the analysis are summarized in Table 4.2-
14A. The construction activities are split into two categories: roadway and utility
construction and building /concrete construction. As these two types of activities
would not occur concurrently they are analyzed separately.
1 TABLE 4.2 -14A
ESTIMATED TRAFFIC GENERATED BY PHASE 11 CONSTRUCTION ACTIVITIES
1
b I r AACtenal
L � k 4- � r Delivery �Matenal
x ,, , ; 3 ',, , Roadway ;Delivery ' .1
f - . Off -Haul -and VencCal Concrete =
:Employees Trucking - 'Grading . y Constiuchon =Pours , ' TOTAL
Roadway and Utility
Construction
I Number of Vehicles on 50 1 5 0 0 56
Site per Day (1)
Maximum Number of
One -way Trips 100 2 10 0 0 112
I
Generated per Day (2)
Percentage of Trips
Expected to Exit the 75°J, 10% 10%
Site During P.M. Peak 10°J, 10�
III
Hour
P.M. Peak-Hour
Generated Exiting 38 0 1 0 0 39
I Traffic
Building and Concrete
Construction
Number of Vehicles on
I 30 0 0 3 6 39
Site per Day (1)
Maximum Number of
One -way Trips 60 2 0 6 12 80
I Generated per Day (2)
Percentage of Trips
Expected to Exit the 75% 10% 10%
Site During P.M. Peak I0� 10�
I Hour
P.M. Peak -Hour
Generated Exiting 23 0 0 0 I 24
Traffic
I Note 1: Assumes one person per vehicle occupancy.
Note 2: Assumes two one -way trips per person per day.
I As the table indicates, during peak construction activities, the .project will
generate a maximum of 112 daily one -way construction - related trips and 39 P.M. •
peak -hour trips. In addition, most of these trips will be distributed to 1 -80 to the
I
Final Environmental Impact Report Town of Truckee
1 Gray's Crossing Specific Plan Project 2 -98 September2003
2.0 RESPONSE TO COMMENTS 1
east or west. This trip generation is less than 35 percent of the trips generated by 1
Phase 1. As indicated in the Draft EIR, the critical intersections, or the intersections
that will most likely exceed LOS standards with increased traffic are the SR
89 /Alder Drive /Prosser Dam Road and SR 89 /Donner Pass Road intersections.
Adding 39 PM peak -hour to either of these intersections would result in an
increase in total peak -hour traffic volumes of 3 percent. Weekday LOS with this
additional traffic was analyzed at these two intersections to see the impact the
construction traffic would have on intersection LOS. The LOS calculations may be
found in Appendix N. 1
At the SR 89 /Donner Pass Road intersection, the construction traffic would
exacerbate the no- project LOS F condition. However, as this would be an
existing deficiency the following. Town of Truckee thresholds of significance
would apply:
For intersections with an unacceptable level of service, the project
1
increases the total traffic volumes of the intersection 5% or more above
existing traffic volumes. The significant impact may be reduced to a less
than significant level by incorporating intersection improvements and
other mitigation into the project, which maintains the level of service of
the intersection at pre - project levels.
As the construction traffic would not increase traffic volumes through the SR
89 /Donner Pass Road intersection by more than 5 percent under Phase 1
construction, this would not result in a significant impact. However, the impact of
Phase 1 land uses and Phase 2 construction traffic would result in an increase in
traffic volumes through this intersection of more than 5 percent.
The construction traffic at the SR 89 /Alder Drive /Prosser Dam Road intersection
generated by Phase 11 and after the completion of Phase 1 would increase the
average intersection delay at the intersection from 11.7 (LOS B) to 36.8 (LOS E),
which would exceed the Town of Truckee LOS thresholds.
Traffic Generated by Second Units: '
•
It was assumed in the traffic analysis that the second units contained on the single -
family lots would not have a significant impact on total project trip generation.
According to the Town of Truckee Development Code (Truckee Municipal Code, Title
18, Section 18.58.230), the owner of a single- family parcel shall occupy and continue to
occupy either the main dwelling or the secondary dwelling as their permanent or
seasonal residence in the event the second unit is rented. Conservatively assuming that
on a peak summer holiday week half of the anticipated second units are occupied at
one time, a maximum of 41 second units would be occupied on a peak summer
weekday (82 second units were estimated for the proposed project in the Project
Description in Table 3 -5 on page 3 -31). Applying a recreational home trip rate to these
units indicates that the 41 units would generate 11 PM peak -hour trips and 130 daily trips
on a peak weekday. Comparing this estimate to the total project trip generation of 869
PM peak -hour trips (identified on page 4.2 -31 of the Draft EIR) it can be concluded that
Town of Truckee Final Environmental Impact Report
September 2003 2 -99 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
under peak conditions the inclusion of the second units would only increase total
project trip generation by 1 percent. This increase in PM peak -hour trip generation is
considered negligible and, therefore, the inclusion of these units in the trip generation
analysis, even considering worst -case conditions, has no impact on the conclusions of
the traffic analysis.
1 Traffic Generated by the Conference Facility:
The conference facility was considered an ancillary use to the lodge. The lodge was
assumed to generate 51 weekday PM peak -hour trips and 126 weekend PM peak -hour
trips. According to SCO Engineering, the conference facilities would have a maximum
' capacity of 330 persons. The peak traffic event that could be generated would be if a
maximum crowd of 330 persons depart during the PM peak -hour of traffic. Assuming an
average vehicle occupancy of 2.5 persons per vehicle (typical for the area and this
' type of facility), 330 people exiting the conference facility at one time would generate
132 PM peak -hour exiting vehicle- trips. As stated in Table 4.2 -12 of the Draft EIR, the two
most critical intersections under 2005 conditions (intersections operating at the worst
LOS with the project - generated traffic) are the SR 89 /Donner Pass Road and SR
1 89 /Alder Drive /Prosser Dam Road intersections.
These 132 peak -hour vehicle trips (generated by the worst -case operation of the
conference facility) were assigned to these study intersections based upon the
distribution percentages defined in the Draft EIR and LOS was re- calculated. The results
of the LOS analysis, which can be found in Appendix N, indicate that the mitigation
measures identified in Table 4.2 -15 of the Draft EIR would still result in adequate LOS D or
better during weekday PM peak -hour plus project conditions. If roundabouts are
' constructed, the roundabouts at both intersection will operate at a LOS B or better. As
the Town of Truckee maintains a LOS D threshold at these intersections, the impact of
this worst -case scenario use of the conference facility would not result in any new
significant traffic impacts.
Response to Comment 10 -17
1 The commentor requests that a revised analysis be prepared assuming full occupancy
of units. Please refer to Response to Comment 10 -16. The traffic analysis did assume
full occupancy of all units.
Response to Comment 10 -18
' The commentor states that the traffic analysis does_ not consider impacts associated
with traffic generated by construction activities. Please refer to Response to Comment
10 -16, which includes such an analysis.
Response to Comment 10 -19
The commentor states that the traffic analysis does not disclose that the project's
proposed land use pattern would not support sound transportation management
practices because of its location, low density, and contribution to suburban sprawl.
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -100 September 2003
•
2.0 RESPONSE TO COMMENTS 1
However, although the traffic analysis assumes many of the person -trips generated by
the project and uses will be made by private automobile, the close proximity of
commercial and recreational uses to the residential uses would keep many trips internal
to the site as documented on page 4.2 -33 of the Draft EIR. In addition, many of these
internal trips will likely occur as walking trips as there is an extensive and comprehensive
trail system being developed as part of the proposed project. In addition, MM 4.2.9
requires the project applicant to develop a transit plan and pay its fair share to transit
operating costs, thereby promoting the use of public transit. Finally, it should be noted
that site is located between the downtown area to the south and an extensive existing
residential subdivision to the north and is thus, to a degree, infill of existing Town
development rather than sprawl beyond all existing development. •
See also Master Response 2.4.5 General Plan Consistency. The project was designed as '
a clustered development with a pedestrian friendly Village Center. The Draft EIR
determined that the project does not contribute to sprawl in that it represents planned
growth in close proximity to the Town core and is surrounded by existing development.
The Draft EIR further determined that the project is consistent with the Town's General
Plan goals and policies regarding clustering. It is acknowledged, however, that these
concepts are subjective. This comment has been forwarded to the Town Council for its
consideration.
Response to Comment 10 -20 �.
The comment letter notes the deleterious effects of storm water and urban runoff on
water quality generally. The Draft EIR contains an extensive analysis of the potential
impacts from project related and cumulative construction activities on water quality
(Draft EIR Section 4.6). The Draft EIR also considers the effects of on -site and off -site
drainage improvements (Draft EIR pages 4.6 -26 to -29, and Appendix B - Preliminary
Drainage Plan). Please see also Master Response 2.4.3 Water Quality and Responses to
Comment 1 -2, 1 -3, 1 -5, 1 -6, 1 -7, and 1 -9 for information regarding the adequacy of the
proposed storm drains, retention and catch basins, as well as all other water quality
• related BMPs proposed by the applicant.
The specific cost of maintenance and monitoring has not been determined, however,
this is a socioeconomic concern that does not result in a potentially significant adverse
impact on the environment and therefore does not require analysis under CEQA (CEQA
Guidelines, § 15131).
The commentor believes that clustering of units is the best way to ensure water quality
preservation. As explained in Sections 3.0 (Project Description) and 4.6 (Hydrology and
Water Quality) of the Draft EIR, the proposed land use plan does achieve clustering in
compliance with the General Plan and the listed project objective to: "cluster
residential development in response to natural features and resources on the site
consistent with the economic goals of the project" (Draft EIR Section 3.5). Section 4.1
(Land Use) of the Draft EIR details how the proposed land use map includes clustering
of higher- density residential, commercial, office and destination lodging uses in the
southern portion of the site. Specifically, the map clusters residential uses adjacent to
interior streets, avoids biological and hydrological site constraints, and provides large
Town of Truckee Final Environmental Impact Report
September2003 2 -101 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
open space areas around proposed developed areas. In addition, the map clusters •
multi - residential development and the affordable /employee housing adjacent to
commercial uses in the southern portion of the site to facilitate access and the use of
public transportation (Draft EIR Table 4.1 -1).
•
Fiscal considerations regarding a "nine -hole golf course" alternative are included in
Appendix 1 Further, the applicant has reviewed and analyzed the "no golf" and
"reduced lot size" alternatives. According to the applicant, the significant reductions in
1 value and revenues, as well as the limited market appeal and demand, associated
with these alternatives, and particularly a combination of the two, would reduce the •
project's return to such a level the project would become infeasible economically. The
1 applicant has also stated that this loss of value and revenues would likewise result in the
inability to secure the community facilities district financing that is being pursued by the
project and any other financing that would be necessary for the viability of the project.
Finally, the no golf course alternative does not meet most of the basic project
objectives (nor specific PC -2 policies for the project site) and is fiscally infeasible (CEQA
Guidelines, § 15126.6, subd.(c)). The commentor's suggested Clustered Alternative
t Concept was considered in detail in Response to Comment 10 -2.
See Master Response 2.4.7 Water Supply for information regarding the adequate water
,I supply to serve the project, "safe- yield" of the groundwater basin, and the sufficiency
of the Draft EIR's analysis of water supply.
To the extent that the commentor reiterates the opinion that the Draft EIR fails to
include any analysis of cumulative water quality impacts relating to drainage, the
commentor is referred to Master Response 2.4.3 Water Quality and Responses to
Comments 1 -2, 1 -3, 1 -5, 1 -6, 1 -7, and 1 -9.
Response to Comment 10 -21
The commentor expresses concern that the Draft EIR underestimates the •biological
importance of the project site for habitat and wildlife movement corridors. The
commentor is correct in noting that the Draft EIR fails to identify common mixed pine
and basin sage scrub habitat as a significant biological resource. The commentor is
also correct in noting that the Draft EIR found that the proposed project will have a less
than significant effect on wildlife movement corridors (Draft EIR pages 4.7 -13 to -14, and
Impacts 4.7.1, 4.7.2). The conclusions of the Draft EIR are supported by substantial
evidence in the record. See Master Response 2.4.4 Biological Resources.
' The commentor's opinion that the proposed cumulative loss of common mixed pine
and sage scrub habitat is a significant impact is included for consideration by the Town
Council. As explained in the Draft EIR (Impact 4.7.1), great basin sage scrub habitat is
common throughout the Sierra Nevada and no measures have been established by
local, state, or federal agencies to regulate the removal of this habitat. As a result,
impacts to this habitat as a result of project implementation are considered less than
significant and require no mitigation.
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -102 September 2003
2.0 RESPONSE TO COMMENTS '
Response to Comment 10 -22 1
The commentor suggests that the Draft EIR fails to adequately mitigate for the indirect
and direct loss of habitat currently occupied by endemic wildlife and that this impact
should be found significant and unavoidable. The commentor's opinion is included
here for consideration by the Town Council.
See Response to Comment 10 -21 and Master Response 2.4.4 Biological Resources.
Implementation of MM 4.7.2 (Al Program) would further reduce the already less than
significant impacts associated with the loss of mixed pine forest habitat.
Response to Comment 10 -23
The commentor believes that the Draft EIR fails to identify feasible mitigation measures
such as clustering, increasing setbacks from development, and payment of an open
space mitigation fee. As explained in Section 4.1 (Land Use), the proposed land use
map achieves clustering of units consistent with Goals 7 and 7.1 of the Town's General
Plan, and the preservation of large open space areas consistent with General Plan PC -2
policies. The project applicant has agreed to maintain approximately 417 acres of the
757 -acre site as open space (Draft EIR page 3 -1). See Master Response 2.4.5 General
Plan Consistency and Master Response 2.4.4 Biological Resources for additional
information pertaining to open space and clustering.
1
Sufficient setbacks are already required as part of the project to protect sensitive
habitats on the project site, including riparian wetlands and creeks (Draft EIR, Section
4.6). Those setbacks include a no development zone within the 100 -year floodplain of
the two intermittent drainages that traverse the project site. The 100 -year floodplain •
delineation was developed in consultation with the Lahontan RWQCB and represents a
setback based on hydrologic and biological factors. The buffer area is consistently
larger than the 100 -foot buffer referenced in the Development Code, and is also based
on biological characteristics (Draft EIR pages 4.6 -10, 4.7 -18).
1
Prior to construction, the project applicant shall complete focused biological resource
surveys pursuant to MMs 4.7.4 to 4.7.7 and in compliance with the conditions listed in
those measures. If special- status plant or animal species are found, the applicant may
pay into an open space mitigation fund. Lands acquired for open space /easements
and offered as mitigation shall be dedicated to the Truckee Donner Land Trust or an
open space agency designated by the Town to protect and preserve the open space.
Fee title may be dedicated to the Town or the open space agency as 'directed. •
The suggested $40,000 per unit South Livermore Valley Agricultural mitigation fee
referenced by the commentor is infeasible and inapplicable to the project area. The
high demand for housing in Livermore Valley and the quality of farmland at issue in that
program is.not equivalent to the land at issue here.
If an open space mitigation fund is developed, the Town should exempt the affordable '
and employee housing units from participation in the program. Imposition of an open
9 P P P 9 P P
space mitigation fee would increase the cost of affordable and employee housing
Town of Truckee Final Environmental Impact Report
September 2003 2 -103 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
units; thus operating to defeat the Town's goal of providing more units at an affordable
price to its residents.
In general, the comment is noted. The commentor provides no specific reason that
would require recirculation of the Draft EIR. Revision and recirculation of a revised Draft
' EIR is not required because the EIR does not include any new significant information
showing that: (1) a new significant environmental impact would result from the project .
or a new mitigation measure proposed to be implemented; (2) a substantial increase in
the severity of an environmental impact would result unless mitigation measures are
adopted; (3) a feasible project alternative or mitigation measure considerably different
from the others previously analyzed would clearly lessen the significant environmental
' impacts of the project, but the project proponents decline to adopt it; or that (4) the
draft EIR was so fundamentally and basically inadequate and conclusory in nature that
meaningful public review and comment were precluded. Recirculation is not required
where, as here, new information added to . the EIR merely clarifies or amplifies
information previously included in the EIR (CEQA Guidelines § 15088.5).
Response to Comment 10 -24
The commentor suggests that the Draft EIR improperly defers its impact analysis relating
to biological resources by requiring site - specific surveys prior to construction. See Master.
Response 2.4.4 Biological Resources, for information regarding the adequacy of the
environmental setting described in the Draft EIR, as well as the adequacy of the less
than significant impact conclusion to wildlife migration corridors. Section 4.7 (Biological
Resources) of the Draft EIR adequately explains why the proposed land use map will not
significantly impact biological resources.
1 MMs 4.7.2 to 4.7.10 require, among other things, preparation of site - specific surveys
governed by performance standards prior to construction. Because circumstances
may change on a particular property site, it is logical and entirely appropriate under
CEQA to require preparation of pre- construction site - specific surveys. Draft EIR MM
4.7.7, for example, requires that prior to grading or construction activity, and on an
1 annual basis, a focused survey is required for the Sierra Nevada snowshoe hare to
determine if the species is breeding on site. A qualified biologist must conduct the site
survey during the breeding season and assistance from the CDFG and /or USFWS shall
be requested. At a minimum, construction activities shall not occur within 500 feet of an
active nest (Draft EIR page 4.7 -28). Similar mitigation measures are required for special
status bat species (MM 4.7.6), raptors and other migratory birds (MM 4.7.5), and special-
status plant species (MM 4.7.4).
The special status plant species listed in Table 4.7 -1 of the Draft EIR were evaluated for
their potential to occur on the project site or to be affected by project implementation.
These species were considered based on field surveys and review of the CNDDB
database, CNPS literature, and existing documentation for the Martis Valley vicinity.
Foothill Associates biologists also originally surveyed the project site on July 6th and 17th
of 1999. Field investigations included general plant and wildlife surveys focusing on
areas within the project site with the potential to support special- status species and
I sensitive habitats. Color aerial photography of the project site was also examined to
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -104 September 2003
2.0 RESPONSE TO COMMENTS 1
identify . biological resources and to map vegetation types. Jody Gallaway of Gallaway 1
• Consulting, Inc. conducted additional field reconnaissance on November 8, ,2002
(Draft EIR pages 4.7 -21 to -22, and Table 4.7 -3).
Deferral of precise mitigation measures is allowed under CEQA if clear performance
standards are required (CEQA Guidelines, 15126.4(a); Sacramento Old City Ass'n v. City
Council (1991) 229 Cal.App.3d 1011 (EIR set forth a menu of mitigation measures with
performance standards to offset parking and traffic impacts but did not specify which
mitigation measures within the menu would be adopted)).
Response to Comment 10 - 25
The commentor disagrees with the conclusion in the Draft EIR that potentially significant t
impacts to wetlands and /or the 100 -year floodplain, adjacent to and east of SR 89, will
be less than significant with mitigation. The commentor believes this conclusion is
erroneous because the precise location of the SR 89 /Alder Drive/ Prosser Dam Road
roundabout has yet to be determined.
As the Draft EIR explains, the potentially significant environmental effects from the
potential for increased erosion and sediment (Impact 4.6.1) will be avoided or
mitigated to less than significant levels through implementation of MMs 4.7.8b to 4.7.8d
(Draft EIR page 4.6 -14 though 15). Generally, the mitigation measures require the
project applicant to acquire permits from the U.S. Army Corps of Engineers, the
Lahontan RWQCB, and the California Department of Fish and Game (Draft EIR pages
4.7 -31 to -32). Specifically, MM 4.7.8b requires that prior to the issuance of a grading
permit, the wetland delineation study and map prepared by EcoSynthesis, and relied
on by the project applicant in designing the project, shall be submitted to the Corps of
Engineers for review and verification. If the impacts to waters of the United States
cannot be avoided, a Section 404 permit shall be acquired by the applicant. More
importantly, the measure requires that any wetlands that would be lost or disturbed
shall be replaced or rehabilitated on a "no net loss" basis in accordance with the Corps
mitigation guidelines (Draft EIR page 4.7 -31).
Additionally, MM 4.7.8a requires that upon verification by the RWQCB of the 100 -year t
floodplain delineation, the area shall not be altered. The measure prohibits structures
and earth disturbance within the delineated zone, and requires design techniques such
as free -span bridges and utility borings where any roadway, fairway, cart path or utility
crosses (Draft EIR page 4.7 -31).
The preliminary project design is therefore adequate under CEQA to gauge the
potentially significant impacts of the roundabout, and the mitigation measures are
sufficient to reduce the potential impact to a less than significant level. The comment
does not demonstrate how .the Draft EIR's description of the potential impact and
avoidance measures narrows the scope of environmental review or minimizes •
environmental impacts. In addition, the comment does not explain how more detailed
engineered drawings would allow the public and decisionmakers to fully understand
the environmental consequences of the entire project. The discussion of the potential
impacts to waters of the United States included in the Draft EIR is adequate under
Town of Truckee Final Environmental Impact Report
September 2003 2 -105 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
CEQA (Dry Creek Citizens Coalition v. County of Tulare (1999) 70 Cal.App.4th 20, 36
(rejecting appellant's claim that the general description of stream diversion structures in
EIR coupled with approval of final designs after the project is approved violated any
CEQA mandate)).
Response to Comment 10 -26
The commentor states that the Draft EIR fails to include any analysis of the potential
effects from nighttime lighting in the project area. Section 4.9 (Visual Resources /Light
and Glare) of the Draft EIR considers whether the proposed project and lighting plan is
consistent with the Town's General Plan goals and . policies related to visual and
aesthetic considerations. The Draft EIR concludes that any impacts from the proposed
project would be less than significant and are consistent with the Town's Development
Code and General Plan (Draft EIR page 4.9 -4 to -9).
1 Appendix I to the Draft EIR includes a Lighting Masterplan prepared by Francis Krahe &
Associates, Inc. for the project. The report summarizes the lighting design objectives
' and criteria for the project, and recommends lighting solutions. Design standards
based on energy efficiency, durability and safety include: Certification program from
Leadership in Energy and Environmental Design (LEED), International Dark Sky
Association (IDA), and Illuminating Engineering Society of North America (IESNA)
standards (Appendix I pages 2 -13; Specific Plan pages 141 -149). The report includes
specific lighting recommendations for the gas station, main and secondary streets, the
1 village retail area, and residential uses based on the Specific Plan (Appendix I pages
14 -20; Specific Plan pages 141 -149).
The lighting plan is consistent with the Specific Plan objectives to "maintain visibility of
stars in the night sky; establish a warm, inviting character; create a unique identify,
responding to local vernacular; provide functional lighting safety; [and) minimize light
during non - active (l 1 pm -dawn) hours" (Specific Plan page 141).
See also Responses to Comments 10 -24 and 10-25 regarding deferral and the
adequacy of the Draft EIR.
Response to Comment 10 -27
•
This comment describes general legal standards governing the adequacy of an EIR.
Since this comment does not raise any specific issues regarding the adequacy of the
Draft EIR no further response is required. See also Master Response 2.4.2 Cumulative
Impacts.
Response to Comment 10 -28
I The commentor states that the Draft EIR does not include a large enough geographic
area to determine cumulative impacts. See Master Response 2.4.2 Cumulative
Impacts. The Draft EIR includes and describes a large geographic area from which
cumulative impacts of the proposed project were measured (Draft EIR pages 3 -2 to 3-
6). A comprehensive list of existing and proposed projects, including the Old
' Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -106 September 2003
2.0 RESPONSE TO COMMENTS 1
Greenwood Resort project and projects within the Mortis Valley area, are also identified 1
and considered as part of the Draft EIR's analysis (Draft EIR pages 3 -7 to -13 (Table 3 -1)).
For purposes of the biological resources and cumulative hydrology and water quality
analysis, the Draft EIR considered a 428 square mile area covering portions of the
watershed located within the Town of Truckee, Placer County and Nevada County,
and including the area that extends from the outflow of Lake Tahoe to the
California /Nevada state line (Draft EIR, pages 4.6 -31, 4.7 -34).
With respect to the extent of the study area for the Draft EIR's traffic analysis, and given
the distance from the cities of Auburn and Reno, the project is not expected to result in
significant traffic impacts from those areas and no evidence has been submitted that
illustrates such a cumulative traffic impact could occur. Analysis of such impacts is
speculative and not required under CEQA.
For additional information regarding biological resources see Master Response 2.4.4
Biological Resources. The commentor's claim that the Draft EIR must defend the study
area determined for each impact, and based on evidence demonstrating "where the
• project - related contribution are not measurable" is burdensome and not required by
CEQA. CEQA Guidelines Section 15125 provides that It] he description of the
environmental setting shall be no longer than is necessary to an understanding of the
significant effects of the proposed project and its alternatives."
The commentor states that the ,traffic analysis should include at a minimum the areas
where trips will terminate or end and a study area that includes Lake Tahoe. As shown -
in Figure 4.2 -5 in the Draft EIR the project would generate approximately 57 peak -hour
trips into Lake Tahoe upon build out. This would result in a 4 percent increase over
existing volumes along SR 28. This is not considered a significant impact. • To further
validate this conclusion, the existing peak season traffic volumes contained in the
administrative draft Kings Beach Commercial Core Traffic Study were used to calculate
LOS at the SR 267 /SR 28 intersection with and without the project - generated traffic. The
LOS calculations may be found in Appendix N. Without the project traffic, the
intersection operates at a LOS B. With the addition of Gray's Crossing project -
generated traffic, the LOS decreases from a B to C, but total intersection delay only
increases by 3.3 seconds per vehicle. As TRPA's LOS threshold at this intersection is up to
four hours per day of LOS E, the project can be considered to not have a significant
impact within the Tahoe Basin.
Response to Comment 10 -29
Contrary to the commentor's statement, the Draft EIR adequately considers cumulative 1
impacts to biological resources (Draft EIR pages 4.7 -34 to -35), water quality (Draft EIR
pages 4.6 -31. to -33), land use consistency with the Town's General Plan goals and
policies (Draft EIR Table 4.1 -1 and page 4.1 -36), and traffic (Draft EIR page 4.2 -89).
Section 5.0 also offers a summary of the potentially significant cumulative impacts from
the project. Regarding the commentor's statement that the Draft EIR did not
. adequately consider growth inducing impacts, see Response to Comment 10 -36. See
also Master Response 2.4.2 Cumulative Impacts.
Town of Truckee Final Environmental Impact Report
September 2003 2 -107 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
1 • Response to Comment 10 -30
The commentor states that the Draft EIR does not include an analysis of cumulative
construction noise. Construction noise impacts are addressed in Impact 4.3.4 of the
Draft EIR. Due to the highly localized nature of construction noise, the combination of
' construction noise from this project in conjunction with construction noise from other
more distant projects (such as Old Greenwood) would be negligible. In fact, it is
anticipated that activities such as roadway construction within the Old Greenwood
project site would be faint to inaudible at the Gray's Crossing project site. As a result,
no assessment of cumulative construction noise impacts was warranted for this
assessment.
Response to Comment 10 -31
The commentor requests additional information regarding cumulative water supply
impacts. Please refer to Master Response 2.4.7 Water Supply. The commentor requests
information regarding whether water.supply demand generated by the project may
affect biological resources. The commentor does not identify the biological resources
to which this comment refers. Although the thinking behind this comment cannot be
determined without engaging in speculation, presumably the commentor is concerned
that groundwater pumping associated with the project, in conjunction with the
I development of other water supplies, may result in declining groundwater levels, which
could in turn affect biological resources on the surface that rely on shallow
groundwater. For example, a surface stream that depends on groundwater recharge
could be de- watered by a declining groundwater table, which in turn would affect
biological resources that depend on the stream environment.
This same comment was submitted to Placer County in comments on the proposed
Martis Valley Community Plan (MVCP). The County provided a response to this
I comment. This response is attached as Appendix 0 and is incorporated by reference.
The response concludes that properly sited wells will not affect surface features (see
attached MVCP Final EIR (2003), Master Response 3.4.4).
Response to Comment 10 -32
The commentor states that the Draft EIR fails to support with evidence its conclusions
1 that impacts to flooding and water quality will be insignificant, and fails to consider
"secondary" impacts from MM 4.6.7 and the construction of culverts, ditches and .
detention basins. Please see Master Response 2.4.3 Water Quality, and Responses to
Comments 10 -24 and 10 -25.
Response to Comment 10 -33
The commentor states that the cumulative impact discussion for biological resources
does not include an adequate geographic discussion, nor a list of projects in the area.
The commentor also requests quantification of cumulative direct and indirect losses of
biological resources. Please see Master Response 2.4.4 Biological Resources and 2.4.2
. Cumulative Impacts.
' Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 - 108 September 2003
2.0 RESPONSE TO COMMENTS
Response to Comment 10 -34 1
The commentor expresses a general opinion that the Draft EIR is inadequate with
respect to visual impacts and public services and utilities. Please see Section 4.9 of the
Draft EIR, and Response to Comment 10-26 regarding the adequacy of consideration
for visual resources.
Since the comment does not raise any specific issues regarding the adequacy of the
Draft EIR no further response is required.
Response to Comment 10 -35
The commentor states that the cumulative impact discussions do not provide quantified
information concerning cumulative project impacts. Please see the Master Response
2.4.4 Biological Resources and 2.4.2 Cumulative Impacts. See also Response to
Comment 10-29.
The commentor never specifically states what projects are believed to be missing from
the Draft EIR (Table 3 -1 and Figure 3 -5) and cumulative impacts analysis, nor does the
commentor suggest a specific geographic range for the cumulative impacts analysis.
Because the comment does not raise any specific issues regarding the adequacy of
the Draft EIR, no further response is required.
1
Please see Response to Comment 10 -23 explaining why recirculation of the Draft EIR is
not required. Additional mitigation measures are not required under CEQA to mitigate
the project's cumulative impacts because most of these impacts have been deemed
less than significant (CEQA Guidelines, § 15126.4).
Response. to Comment 10 -36
The comment is noted to the extent it describes the general legal standards governing
the adequacy of an EIR. No further response is required. The commentor believes that
the analysis of potential growth- inducing impacts in the Draft EIR (Section 7.3) is
inadequate under CEQA because it does not consider the proposed extension of
sewer lines to the existing Prosser Lakeview Estates subdivision. As explained in the Draft
EIR, the proposed project will not result in growth- inducing impacts, in part, because the
water distribution infrastructure has been sized to accommodate only onsite demand
from the project, and existing development on parcels adjacent to the project site and
• is consistent with the TDPUD Water Master Plan (Draft EIR pages 7 -4 to 7 -5). The
proposed sewer lines have also been sized to serve only the proposed project and
existing development at a future date for properties to the north that are currently on
septic (i.e., Prosser Lakeview Estates, Prosser Woods, and Prosser Lake Heights) (Draft EIR
pages 7 -4 to -5). See also Appendix P provided by the applicant, which summarizes
additional background information detailing the anticipated benefits of extending
sewer services to the Gray's Crossing project site. Development of the PC -2 site will
result in a public health and water quality benefit by improving the existing
infrastructure (i.e., septic). The project would not result in growth- inducing impacts
requiring analysis under CEQA.
Town of Truckee Final Environmental Impact Report
September 2003 2 -109 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
The conversion of the PC -2 site, moreover, is consistent with the residential and
commercial designations of the Town of Truckee General Plan. The impacts of
development in the PC -2 area were discussed in the General Plan EIR; which has been
incorporated by reference. Since development in the PC -2 area is consistent with and
guided by the Town's General Plan, the project would have no direct growth- inducing
' impacts. There are, moreover, no significant undeveloped sites adjacent to the project
(Draft EIR pages 7 -4 to -5).
The , "new school" referenced by the commentor was previously approved as part of a
separate project after the applicant transferred 35.7 acres of land south of Alder Drive
and west of SR 89 to the Tahoe - Truckee Unified School District for construction of the
new middle school (Draft EIR pages 4.10 to -11). The TTUSD is currently constructing the
school and anticipates opening in the fall of 2004 (Draft EIR page 4.10 -16). The Draft EIR
nonetheless considers the school as part of the cumulative imp acts analysis (Draft EIR,
1 page 3-17).
Water supply service to the Gray's Crossing Specific Plan area will require
I approximately 400,000 gallons of storage capacity depending on fire flow
requirements. A new 1.5 million gallon water storage tank is due to be constructed on
TDPUD property (west of SR 89 and just north of I -80), and the applicant has committed
to paying its fair share of the cost. The storage tanks are unrelated to the proposed
project and will not cause the project to result in growth- inducing impacts.
Because the Draft EIR contains adequate information regarding the project's potential
to result in growth- inducing impacts, a revised document is not required under CEQA.
Response to Comment 10 -37
The comment is noted to the extent it describes the general legal standards governing
t the adequacy of an EIR and no further response is required.
Response to Comment 10 -38
The commentor believes that the Draft EIR improperly defers mitigation. Please see
Response to Comments 10 -24 and 10-25 explaining generally why the Draft EIR does not
impermissibly defer the identification and adoption of mitigation measures for those
impacts deemed potentially significant. •
Specifically, the Draft EIR does not improperly defer calculation of the applicant's "fair
share" of traffic impact fees. As explained in the Draft EIR, and for purposes of MM
4.2.1, "fair share" is determined by the project's percentage contribution to future PM
peak -hour intersection volumes at each intersection requiring mitigation and as
presented in Table 4.2 -16 in the Draft EIR.
1.
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -1 10 September 2003
•
2.0 RESPONSE TO COMMENTS
TABLE 4.2 -16 1
PROJECT'S FAIR -SHARE CONTRIBUTION TO INTERSECTION IMPROVEMENTS
1, ` Cost of Fair'
f ' ; ` x ' r Improvement Share
Intersection : , na . ', . u: Eatr Share*Percent , , (Note 1) .,.,..pCost a;
I.SR 267 /Northstar Drive l0% $342,086 $34,209 111 Donner Pass Road /Bridge Street 25% $500,000 $125,000
Note 1: Cost of improvements to Donner Pass Road / Bridge Street Intersection estimated by Town of Truckee Public
Works Department and cost of improvement to Northstar Drive / SR 267 Intersection estimated by Psomas as a part of the
Northstar Village EIR. However, please note that Improvement costs are preliminary and subject to change.
(Draft EIR pages 4.2 -48 to -50).
Furthermore, and as explained in the Draft EIR and MM 4.2.8, the Town of Truckee and
Placer County are conducting a joint study of a potential joint regional traffic impact
mitigation program that would coordinate mitigation for the impacts from planned
growth on regional facilities. If a regional traffic impact fee program is implemented by
the Town of Truckee and Placer County and all the intersections and roadways a
identified as requiring mitigation in the EIR are contained in a fee program, the project
applicant shall pay the appropriate amount into the fee program prior to the issuance
of the first building permit for the projector the recordation of final subdivision maps.
The project applicant's fee will be determined by the methodologies adopted as a
part of the regional fee program and based on individual traffic contributions in relation
• to other projects in the area. If some of the roadways or intersections identified above
are not contained in the fee program, the project applicant shall pay its fair share to
the additional improvements.
If, however, such a fee program is not in place prior to the issuance of building permits
1
or the recordation of final subdivision maps, the project applicant shall pay its fair share
cost of improvements at the SR 267/1 -80 Westbound Ramp, SR 267/1 -80 Eastbound
Ramp, SR 267 /Brockway Road, SR 267 /Airport Road /Schaffer Mill Road, SR 267 /Northstar
Drive, Donner Pass Road /Pioneer Trail, Donner Pass Road /I -80 Eastbound Off Ramp,
Donner Pass Road /Glenshire Road, Donner /Pass Road /Bridge Street, and Donner Pass
Road /West River Street intersections, as well as its fair share to the cost of widening SR
267 and Schaffer Mill Road. Placer County and Town of Truckee Public Works
Departments would determine the cost of these improvemehts. /
•
Determining the "fair share" cost of infrastructure improvements at a later date does
not constitute deferral of mitigation under CEQA. •So long as there is a "reasonable
plan for mitigation" and contributions are "sufficiently tied to the actual mitigation" of
the project's impacts, a commitment by the project proponent to contribute a fair
share to such a program discharges its mitigation duty under CEQA (Save Our Peninsula
Committee v. Monterey County Bd. of Supervisors (2001) 87 Cal. App. 4' 99, 141; see
also CEQA Guidelines, § 15130). In reality, public agencies would often be
shortchanged if they established fixed "fair share" fees early in the planning process
and before the actual improvements come to fruition.
1
Town of Truckee Final Environmental impact Report •
September 2003 2 -111 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
Completion of the transit plan pursuant to MM 4.2.9, and prior to the first building permit
or recordation of the Final Subdivision Map under Phase II, also does not constitute
impermissible deferral of mitigation because there is a firm commitment to prepare and
implement a plan (Sacramento Old City Assn v. City Council of Sacramento (1991) 229
Cal.App.3d 1011, 1028 -1030 (affirming trial court holding that the City's commitment to
develop a Transportation Management Plan was adequate under CEQA)).
Preparation of the SWPPP, completion of a Phase I Site Assessment, acquisition of
permits from the various agencies (including final wetlands delineation approved by
the Corps), and focused surveys for plants and animals are also not required prior to
project approval for the same reasons. Please also see Responses to Comments 10-13
and 10 -24. Also see Appendix Q, which is a letter from the applicant's attorney
explaining the applicant has obtained a Phase I assessment prepared by Holdrege &
Kull (H &K). H &K conclude that their "investigation did not reveal evidence that
incidents involving hazardous or potentially hazardous materials have impacted the
property."
With respect to historic resources, the project has been designed where feasible to
avoid known resources. Further, the project's contribution to this cumulative impact has
been identified and considered within the General Plan EIR (State Clearinghouse No.
94092041), for which the Town of Truckee certified and adopted a Statement of Facts
and Findings (Resolution 96 -09, which is included in the Technical Appendices). The
Statement of Facts and Findings indicates that cultural and historic resources could be
destroyed or degraded by new development accommodated by the General Plan.
However, all policies under Conservation and Open Space Goal 9 address impacts to
cultural and historic resources. The cultural and resource analysis that has been
prepared for this CEQA process has identified impacts and corresponding mitigation
measures (see MM 4.8.1a, MM 4.8.1b, MM 4.8.2a, and MM 4.8.2b) that would reduce
impacts to a less than significant level and bring the project into consistency with the
General Plan goals and policies identified in Table 4.8 -2. Therefore, cumulative impacts
to historical resources were found less than significant (Draft EIR page 4.8 -21).
The commentor's opinion regarding the legal adequacy of the Draft FIR is noted and
included for consideration by the Town Council.
Response to Comment 10 -39
1 The comment describes general legal standards governing the adequacy of mitigation
measures under CEQA. To the extent this comment fails to identify specific feasible
mitigation measures that the .Draft EIR purportedly excludes, no further response is
required.
1 Please see Response to Comments 10 -24 and 10 -25. The commentor's opinion as to
what impacts should be identified as significant and unavoidable are noted and
included for consideration by the Town Council.
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -1 12 September 2003
2.0 RESPONSE TO COMMENTS
Response to Comment 10 -40 1
The commentor states that a feasible mitigation measure for water quality impacts
would be reduction of the development by clustering it. See Response to Comment 10-
20 regarding the adequate clustering of units proposed in the land use plan and water
quality. See also Master Response 2.4.3 Water Quality and Response to Comment 10-2
regarding the proposed Clustered Development Concept.
•
Response to Comment 10 -41
The commentor states that a feasible mitigation measure to water quality impacts
would be the elimination of the golf course from the development. See Response to
•
Comment 10 -2.
Response to Comment 10 -42
The commentor's suggestion that setbacks be increased around water features is
noted and included for consideration by the Town Council. See also Master Response
2.4.3 Water Quality.
Response to Comment 10 -43
The commentor's suggestion to increase the number of "small units, for -sale units and 1
units targeting the local, full time resident market" is noted and included for
consideration by the Town Council. The suggestion addresses socio- economic effects
of the project, however, and is not a feasible mitigation measure required to reduce a
potentially significant impact under CEQA.
As explained in the Master Response 2.4.1 Employee /Affordable Housing, sufficient
affordable and employee housing is included as part of the proposed project,
The commentor's suggestions that Phase I include the construction of some affordable
units, and that some units be made permanently affordable, are noted and included
for consideration by the Town Council.
Response to Comment 10 -44
The commentor states that a feasible mitigation measure for impacts related to open . $
Space would be to require open space mitigation fees from all new market rate and
resort units /rooms and the golf course area. See Response to Comment 10 -23.
1
Response to Comment 10 -45
The commentor notes that other feasible mitigation measures must be included in a
revised Draft EIR but fails to identify any additional specific measures. To the extent this
comment fails to identify specific feasible mitigation measures that the Draft E1R
purportedly excludes, no further response is required.
Town of Truckee Final Environmental Impact Report
September2003 2 -113 Gray's Crossing Specific Plan Project
W 2:0 RESPONSE TO COMMENTS
ii Response to Comment 10 -46
I The comment describes general legal standards governing the adequacy of an
alternatives analysis under CEQA. To the extent this comment fails to identify specific
alternatives that the Draft EIR purportedly excludes, no further response is required.
1 Response to Comment 10 -47
P The commentor suggests several development alternatives in addition to those
analyzed in the Draft EIR. In preparing the land use map and the reasonable range of
alternatives considered in the Draft EIR, the existing site constraints were taken into
I consideration and over 417 acres of open space preserved throughout the project site.
As explained in the Draft EIR, careful consideration was given when developing the
Specific Plan to preserve and protect sensitive area, including floodplains, wetlands,
I and open meadows a(Draft EIR page 3 -27). Several Figures within the Draft EIR
document the areas containing resource values, including special- status plants, wildlife
corridors, and riparian areas (see Figures 4.7 -1 (Vegetation Habitat Map), 4.7 -2 (CNDDB
Search Results), and 4.7-3 (Habitat Disturbance Map)). The land use map is consistent
I with the project objective to "conserve wetlands, natural drainages and other wildlife
habitat of significant biological, scenic, and recreational values" (Draft EIR page 3 -20).
I See also the Master Response 2.4.4 Biological Resources.
The commenfor requests analysis of an alternative that provides only housing to meet
-$ local needs, rather than resort /second homes and cites Exhibit 1, which is a Clustered
Alternative Concept provided by the commentor. As discussed in Response to
Comment 10 -2, the applicant has serious financial viability concerns with the proposed
i alternative. Further, the alternative is inconsistent with the objectives of the project. The
suggested alternative would not meet most of the basic project objectives including:
'• Develop a neighborhood community consisting of mixed land uses, which
I include open space, lodging, recreational amenities (such as golf course and
trails), local residential uses, and a neighborhood oriented retail shopping area;
• Provide for both an environmentally and economically sound development;
and
1 • Provide trails, lodging, professional office space and neighborhood retail
services.
Also, in response to a request from the Town Council; the Draft EIR considered an
I . alternative to provide additional affordable housing. The "Density Increase Option"
(Alternative 3), would increase the number of residential units for the Specific Plan area
from 628 to 753 and would also provide additional affordable housing opportunities
I (Draft EIR pages 6 -2 to 6 -3, and Figure 6 -1). The Draft EIR found that Alternative 3 would
have slightly greater impacts on transportation, air quality, noise, biological resources,
among others. The alternative may also be inconsistent with the land use goals and
policies specific to the PC -2 site (Draft EIR page 6 -16).
Lastly, the commenfor believes that at least one development alternative should
1 include additional local passive recreation uses in lieu of the golf course. The
Final Environmental Impact Report Town of Truckee
I Gray's Crossing Specific Plan Project 2 -1 14 September 2003
•
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2.0 RESPONSE TO COMMENTS
commentor's suggestion is vague and does not specify what additional passive 1
recreation uses should be included in lieu of the golf course. The proposed project
already provides for passive recreational including a fitness center and clubhouse,
biking, cross - country skiing, snowshoeing, walking, running, and hiking (Draft EIR page 3-
34).
The Draft EIR considers a reasonable range of alternatives under CEQA. CEQA
Guidelines Section 1 5126.6, subdivision (a), provides that "an EIR shall describe a range
of reasonable alternatives to the project ... which would feasibly attain most of the
basic objectives of the project but would avoid or substantially lessen any of the
significant effects of the project, and evaluate the comparative merits of the
alternatives. ". The EIR need not consider every conceivable alternative suggested by
commentors, but rather consider a "reasonable range" of potentially feasible
alternatives that will foster informed decision - making and public participation. The
range of potential alternatives considered in the EIR include those alternatives that
could feasibly accomplish most of the basic objectives of the project and could avoid
or substantially lessen one or more of the significant effects (CEQA Guidelines, §
15126.6, subd. (c)).
The commentor's opinion regarding the range of alternatives analysis is noted.
Response to Comment 10 -48 1,
The commentor's statements about the adequacy of the Draft EIR, and the need to
consider additional alternatives for the site as part of the Town's General Plan update
are noted and included for consideration by the Town Council.
Please also see Response to Comment 10 -23. 1
1
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Town of Truckee Final Environmental Impact Report
September 2003 2 -115 Gray's Crossing Specific Plan Project
' /O /
II GRAYS CROSSING COMMENTS • LETTER 11
I SUBMITTED BY MOUNTAIN AREA PRESERVATION FOUNDATION
We have appreciated the applicant's willingness to discuss alternatives -and to review
I their project with our organization. 11-1
MAPF has retained the design firm of S WA and Joe Runco to develop a truly clustered
alternative; one that we believe will conform to the GP policy for clustered development
and provide an alternative to the existing plan. This plan will be forthcoming.
1 GLOBAL COMMENTS:
It is important to PLAN this site properly — the Town is not expanding and this major
i remaining undeveloped site must be planned and developed to meet the needs of the 11-2
community. Therefore, the Town should take the time necessary, without rushing, to get
I the plan right for this important property.
The Town is currently engaged in updating its General Plan. As part of that update, the
Town may conclude that properties currently designated for "recreational uses" and
I "second homes" may be needed for primary homes in order to address local housing
needs. If this project is to proceed in advance of the GP Update (we would prefer it wait 11 -3
I for completion of the update) then alternative land uses of the site must be evaluated
based on the public's input thus far to the GP visioning process which clearly directs the
Town to do more to provide a greater supply of housing to meet local demand. We must
,.11 not squander the scarce resource of available land and opportunity for local housing.
Also, a project alternative should be evaluated which does not include a golf course in i 11 -4
addition to the no project and 9 -hole course alternatives — again, per public input during
the General Plan visioning process.
I DETAILED COMMENTS:
The project will include a Development Agreement. A draft of the DA should be made
I available for public review during the circulation period of the DEIR so that if the DA 11'5
has the potential for impacts or mitigation value, it can be part of the review and
comment process. See Table 4.12 -5, page 4.12 -9 for requirement.
1 Information about the general range of salaries of the 235 employees generated by the
project should be identified, as well as the range of housing costs. This information
I should form the basis for an analysis of how well new jobs are balanced with housing 11.6
affordability. General ratios of jobs- housing balance are not terribly useful without this
additional analysis. Also, information about availability of affordable housing in the •
I immediate area should be provided along with the number of units needed to meet the
unmet need in the area for affordable housing.
a
1 1
1
East/West projects are being marketed as "Lake Tahoe" projects. Marketing literature for
Old Greenwood states: "Only 99 Families will make a home on the Nicklaus Course in 11 -7
North Lake Tahoe." As such, the cumulative study area must include the north and west -
shore of Lake Tahoe for impacts including traffic, air quality, growth inducement,
recreation, parking, biological resources and Lake threshold attainment, among others.
General Plan policy requires that units be "clustered." PC -2 Policy 8. We question I 11 -81 .
whether the project meets this "test."
ALTERNATIVES: 1
A graphic should be prepared which illustrates the Reduced Development Alternative 11 -91
( #2). Absent such a graphic, it is impossible to analyze the impacts accurately and
difficult for the decision- makers and public to visualize the differences from the proposed
project.
An alternative should be included that "clusters" all development on the site to the South
of Prosser Dam Road in a "neo- traditional" development pattern. This alternative should
still avoid sensitive resource areas. Also, an alternative should show the proposed 11 -1
development to the West to be clustered on the West side of Highway 89 on smaller lot
sizes, more conducive to affordable homes along with all development to the East of
Hwy. 89 being clustered South of Prosser Dam Road. These alternative, as well as
others, should orient the housing to for -sale and rental housing for primary residency,
rather than second homes.
MITIGATION ADEQUACY:
11 -11
Additional explanation is needed as to how payment of "fair share" fees will result in the
timely completion of needed infrastructure, including, but not limited to: local and
regional roadway and intersection improvements, transit, other services.
Feasible mitigation that should be considered includes open space mitigation fees for the 11 -11
loss of open space.
HOUSING: 1
Details should be provided concerning the housing component of the project, including; 11 -13
the range of housing costs /rental rates; permanency of affordable units; details of 1
affordable program; etc.
Th. o for is opportunity to comment.
e ante ivieri
Preside t, Mountain Area Preservation Foundation
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2.0 RESPONSE TO COMMENTS •
LETTER 11 STEFANIE OLIVIERI, MOUNTAIN AREA PRESERVATION FOUNDATION
1
Response to Comment 11 -1
I The commentor has retained a design firm to prepare a clustered alternative to the
project.
1 Please see Response to Comment 10-2.
Response to Comment 11 -2
`� The commentor recommends that the Town not rush in planning for the development
I of this property. See the Master Response 2.4.5 General Plan Consistency. The
comment is noted and provided here for the consideration of the Town Council.
I Response to Comment 11 -3
The commentor notes that the General Plan update may affect land use designations
in terms of addressing local housing needs, and asks that alternative land uses for the
1 project site be considered as an alternative. See the Master Response 2.4.5 General
• Plan Consistency and Master Response 2.4.1 Employee /Affordable Housing.
1 Response to Comment 11 -4
The commentor states that a no, golf course alternative should be evaluated during the
I public input portion of the General Plan visioning process. See first Response to
Comment 10 -2. See also Response to Comment 6 -18 and Master Response 2.4.5
General Plan Consistency. Also Appendix J details why a 9 -hole golf course would
I render the project financially vulnerable. Many of the concerns raised in the
Economics Research Associates memo would also apply to a "no golf" alternative.
Finally, the applicant has reviewed and analyzed the "no golf" and "reduced lot size"
alternatives. According to the applicant, the significant reductions in value and
revenues, as well as the limited market appeal and demand, associated with these
I alternatives, and particularly a combination of the two, would reduce the project's
return to such a level the project would become infeasible economically. The
applicant has also stated that this loss of value and revenues would likewise result in the
inability to secure the community facilities district financing that is being pursued by the
project and any other financing that would be necessary for the viability of the project.
The applicant has also stated both alternatives fail to meet the objectives of the project
1 outlined in Section 3.5. .
These alternatives will be considered by the Town Council when it considers the project.
The EIR analyzes the relative merits of these alternatives from the perspective of
environmental impacts: The Town Council may approve one or the other alternative, or
reject these alternatives if they are found to be infeasible or inconsistent with project
Final Environmental Impact Report Town of Truckee
II Gray's Crossing Specific Plan Project 2 - 16 September 2003
•
2.0 RESPONSE TO COMMENTS
objectives, Any such determination will be based on the information set forth in the EIR,
or elsewhere in the record of proceedings. The applicant and the commenter may
submit information to the Town Council regarding the feasibility of these alternatives, or
the extent to which these alternatives meet project objectives.
Response to Comment 11 -5
This comment requests that the Development Agreement that will be required for the
project be circulated during the comment period for the Draft EIR. In the present case,
the comment period for the Draft EIR. will have concluded before the Development
Agreement is finalized. Nonetheless, the public will be kept appraised of the status of
the Development Agreement for the project. Approval of a Development Agreement
is a legislative act that will be the subject of a noticed public hearing (Gov. Code, §§
65867, 65867.5). There is, however, no requirement that the Development Agreement
for the project be circulated.
Response to Comment 11 -6
The commentor requests information about salary ranges for the employees generated 1
by the project, as well as the range of housing costs, in order to analyze how well new
jobs are balanced with housing. This comment is provided here for the consideration of
the Town Council. See the Master Response 2.4.1 Employee /Affordable Housing. 1
Response to Comment 11 -7
The commentor asks that the cumulative study area include the north and west shores
of Lake Tahoe. See the Master Response for 2.4.2 Cumulative Impacts.
Response to Comment 11 -8 1
The commentor questions whether the project meets the clustering policy of PC -2. See
the Master Response 2.4.5 General Plan Consistency and Response to Comment 10 -8.
Response to Comment 11 -9
The commentor requests that a graphic depicting the Reduced Alternative be
prepared. '
Page 6 -5 of the Draft EIR provides the following description of the Reduced Alternative -
Under Alternative 2, development would occur similar to the proposed project, 1
but there would be an overall reduction in development distributed over the
proposed multiple land uses for the PC -2 site: residential, commercial /retail, and
recreational. For example, residential areas would be reduced in size through a
reduction in lot size and via the elimination of different residential lot types; the
golf course component would be condensed to a 9 -hole course, and the
associated facilities such as the clubhouse and fitness center would also be
reduced; and the village center would have a reduction in commercial and
retail space to minimize the overall footprint of development. The residential
Town of Truckee Final Environmental Impact Report
September 2 -117 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
development would be clustered and moved further away from the two
intermittent drainages that traverse the project site by reducing residential lot
' sizes in Residential Units 1 through 4, and by eliminating fifty (50) single - family
residential units, seven (7) cottage units, and five (5) units of attached
townhomes, resulting in a total of 360 single - family dwelling units, 50 cottage
units, and 43 units of attached townhomes, respectively. The 92 units of
affordable /employee housing would remain unchanged. The reduction in lot
sizes and elimination of a number of residential units and the reduction in size of
. the golf course and associated facilities, as well as the overall reduction in
commercial /retail area, would result in an increase in open space of
approximately 150 acres.
1 This level of description for an alternatives analysis is sufficient under CEQA, and the
consultant does not agree with the commentor that provision of a graphic
representation of the Reduced Density Alternative would enhance the ability of
decision - makers and the public to assess impacts. See also Response to Comment 11-
10. See also Response to Comment 10-2, which is an analysis of a Clustered Alternative
Concept. The comment is noted and provided here for the consideration of the Town
Council.
Response to Comment 11 - 10
See generally, Response to Comment 11 -1. This comment requests that two variations
on a clustered "neo- traditional" alternative be evaluated. One alternative would cluster
development south of Prosser Dam Road and the other would cluster development
west of SR 89.
t The Draft EIR for the project considered a No Project /No Build Alternative, a Reduced
Development Alternative, and a Density Increase Alternative (Draft EIR pages 6 -2 to 6-
4). Evaluating an Off -Site Alternative, which would consist of developing the entire
�- project on another site within the Town limits, was also proposed, but it was determined
that no feasible off -site location is available (Draft EIR pages 6 -3 to 6 -4). A number of
other alternatives identified in the prior PC -2 Draft EIR for the Boca Sierra Estates Project
were also evaluated but ultimately rejected as candidates for more in depth analysis.
CEQA Guidelines Section 15126.6(a) requires an EIR to "describe a range of reasonable
alternatives to the project, or to the location of the project, which would feasibly attain
most of the basic objectives of the project but would avoid or substantially lessen any of
the significant effects of the project." An EIR need not consider every conceivable
alternative, but rather a "reasonable range" of potentially feasible alternatives. 'The
discussion of alternatives need not be exhaustive, and the requirement as to the
discussion of alternatives is subject to a construction of reasonableness. CEQA does not
demand what is not realistically possible given the limitation of time, energy, and funds
(Residents Ad Hoc Stadium Committee v. Board of Trustees (1979) 89 Cal.App.3d 274,
1 286).
The Draft EIR complies with CEQA's requirement that an EIR must consider a reasonable
range of alternatives. The project itself is considered a clustered development and
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -118 September2003
2.0 RESPONSE TO COMMENTS
there is also no indication that the proposed "neo- traditional" clustered alternatives
offers any substantial environmental advantages to the project as proposed or would
meet the project's objectives. Further intensifying development west of SR 89 could
impair wildlife habitat and would require substantially more grading due to the slope
increase to the north and removal of significant amounts of additional forest habitat
(see Gray's Crossing Specific Plan, Vegetation Constraints and Landform Constraints
Maps). �.
Clustering all development to the south of Prosser Dam Road would unreasonably
constrain use of the site making development financially infeasible. The project's
clustered development was designed to avoid sensitive natural features and resources.
Sensitive natural features, including wetlands, floodplains, and plant communities, were
mapped and the protection of these resources was then achieved primarily through
their avoidance. See also Response to Comment 10 -2 and Appendix J.
Response to Comment 11 -11 J
This comment requests additional discussion of how fair -share fees facilitate timely
completion of roadway infrastructure improvements. Mitigation of the project's traffic
impacts involves payment of mitigation fees and also construction of specific roadway
improvements (see e.g., MM 4.2.1, 4.2.7, and 4.2.8). Construction of roadway
improvements and payment of traffic mitigation fees is discussed in Section 4.2 of the
Draft EIR (Transportation and Circulation) and, with respect to mitigation of cumulative
traffic impacts, in Section 5 of the Draft EIR Cumulative Impacts. Construction of
roadway improvements has been coordinated with the project's phases of
development in order to correlate the improvements to the time at which they would
become necessary. Payment of mitigation fees is generally required up front.
The Town of Truckee approved a traffic impact fee program, effective January 2000.
Traffic impact fees are required of any project that would generate new traffic within
the Town of Truckee. The traffic mitigation fee required for the build out of the Gray's
Crossing Project is shown in Table 4.2 -20 in the Draft EIR. The Placer County Board of
Supervisors has adopted the Countywide Traffic Fee Program, requiring new
• development within the County to pay traffic impact fees. These fee programs, in
addition to other funding sources, allow for the construction of transportation facilities
needed as a result of new development (Draft EIR pages 4.2 -54 to 56, 4.2 -77 to 79, and
5 -3 to 4). Courts and the CEQA Guidelines recognize that the payment of such fees
adequately serves to mitigate impacts (see Save Our Peninsula Committee. v.
Monterey County Board of Supervisors (2001) 87 Cal.App.4th 99; Gentry v. City of
Murrieta (1995) 36 Cal.App.4th 1359; CEQA Guidelines, § 15130, subd. (a)(3)). The
CEQA Guidelines expressly recognize that the payment of a fee under an adopted
program may suffice to mitigate a project's otherwise "cumulatively considerable"
incremental contribution to significant cumulative impacts (CEQA Guidelines, § 15130,
subd. (a)(3)).
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Town of Truckee Final Environmental Impact Report
September 2003 2 -1 19 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
Response to Comment 11 -12
The commentor notes that open space Mitigation fees should be considered. See
Master Response 2.4.4 Biological Resources.
Response to Comment 11 -13
The commenter requests information regarding the range of housing costs /rental rates,
permanency of the affordable units, and details of the affordable housing program.
See the Master Response 2.4.1 Employee /Affordable Housing.
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Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -120 September 2003
1
LETTER 12 •
1
1 Tony Lashbrook August 2 2003
Planning Department, Town of Truckee
10183 Airport Rd.
Truckee CA
96161
Re: Gray's Crossing
1 Dear Tony:
Conventional wisdom has been that a golf course will not only facilitate selling real
estate, but will be an economic asset to a community. Recent information, outlined in the
enclosed article from Barron's gives evidence to the contrary and provides reason for
great concern about the number of golf courses that are being built in our area:
• The number of golfers is no longer increasing.
• The number of rounds of golf played is actually decreasing.
• Record numbers of golf courses are in foreclosure, converted to other uses,
or sold at a loss. It is estimated that 400 courses are for sale for less than it
cost to build them. Golf course REITS are liquidating properties.
• In today's economy, fewer people are in a position to take on the costs of an
exclusive golf course built by a well -known designer. 12 -1
• Many companies making golf equipment have filed for chapter 11 bankruptcy
or been sold for a loss.
• In recognition of these facts, golf course openings have sharply fallen off
nationally, unlike our area where they are burgeoning.
A failed golf course, like a failed shopping center, is a dead whale on our beach. They
are often handed over to the development where they are located when it is completed
and the developer leaves, making it a burden on the people who were attracted to it.
1 Unlike other failed businesses, it can result in "open space" the community had been
promised and was counting on being converted to more buildings.
In view of these facts, we strongly suggest that the EIR for Gray's crossing contain a
section on economic feasibility, as well as cumulative economic and environmental
effects of the golf course. It should also include an alternative in which a golf course and
its infrastructure would be shared with Old Greenwood.
Sincerely Yours,
1
Stefanie Olivieri
President, Mountain Area Preservation Foundation
Cc: Roger Lessman
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I 2.0 RESPONSE TO COMMENTS
1
LETTER 12 STEFANIE OLIVIERI, MOUNTAIN AREA PRESERVATION FOUNDATION
1
Response to Comment 12 -1
' The commentor requests that an economic feasibility study of the project's proposed
golf course be included in the Final EIR. The commentor also requests that the study
I include an alternative that shares a golf course with the Old Greenwood Resort project.
The comment is noted and presented here for the consideration of the Town Council.
I An economic analysis was previously prepared in conjunction with the Boca Sierra
Estates EIR. The Town commissioned a new fiscal impact report, which has been
completed (the economic analysis is available from the Planning Department at the
, Truckee Town Hall). The report analyzes the potential recurring fiscal impacts to the
Town of Truckee, the Truckee Fire Protection District, and the Truckee - Donner
Recreation and Park District from the proposed Gray's Crossing development. The
I fiscal analysis compares the annual costs of providing public services against the
annual revenues that will be generated by the new development to determine the net
fiscal impact to an agency or fund.
1 Also, please see comments provided by Economics Research Associates (ERA) in
Appendix J. There is a direct correlation between the availability of golf and the viability
I of the lodging and conference facilities.
In addition, the applicant has reviewed and analyzed the "no golf" and "reduced lot
I size" alternatives. According to the applicant, the significant reductions in value and
revenues, as well as the limited market appeal and demand, associated with these
alternatives, and particularly a combination of the two, would reduce the project's
I return to such a level the project would become infeasible economically. The
applicant has also stated that this loss of value and revenues would likewise result in the
inability to secure the community facilities district financing that is being pursued by the
I project and any other financing that would be necessary for the viability of the project.
The applicant has also stated both alternatives fail to meet the objectives of the project
outlined in Section 3.5.
1 Finally, the commentor summarizes an article from Barron's, which voices concern
about the number of golf courses being constructed in the Truckee area and claims
1 that the popularity of golf as a sport is in decline. The comment is noted and presented
here for the consideration of the Town Council.
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Town of Truckee Final Environmental Impact Report
I September 2003 2 -121 Gray's Crossing Specific Plan Project
•
PROSSER WOODS ESTATES
% John P. Moore LETTER 13
193 Contractors Street
•
Livermore, CA 94551
Phone(925)243 -0133
' August 7, 2003
Heidi Scoble
Town of Truckee
Community Development Department
10183 Truckee Airport Rd •
Truckee, CA 96161
•
Re: Gray's Crossing Specific Plan/Tentative Map Draft Environmental Impact Report
1 Dear Ms. Scoble,
Immediately adjacent to the north -east boundary of the Gray's Crossing ( "GC ") proposed
project is the 12 lot subdivision consisting of 5 acre estates referred to as Prosser Woods
Estates ( "PWE "). The Homeowners Association of PWE has reviewed the GC Draft EIR
and herein provides comments to specific EIR issues. The comments provided herein are
not intended to be all- inclusive. Indeed, at a later date PWE may have additional
comments to.the EIR or follow -ups to the comments herein. PWE's comments
reference two main EIR categories: Infrastructure / Sewer and Traffic:
INFRASTRUCTURE /SEWER
1 Impact 4.11.3 and Section 3.5 (Project Objectives: provide opportunity to link sewer
services to Prosser Lake View Estates)
1 One of the utilities that will service GC lots is sewer. PWE perceives a potential impact
from GC's delivery of sewer. The 5 -acre Lots within PWE currently enjoy new septic
systems and do not want to be "forced" to hook into the new GC sewer utility. The
project developer has told PWE that the Sewer District's policy is to mandate adjacent
projects hook into the new sewer system if the system is within 200 feet of the adjacent
project. Although PWE's lots exceed 500 feet linear distance from the future sewer
system layout, PWE wants to be assured that no mandatory sewer hook up will be
required now or in the future. However, PWE does want to reserve the ability, now 13 -1
and/or, in the future to voluntarily hook into the system. Given the above referenced
project objective to link sewer services to Prosser Lake View Estates, PWE has concerns
that the Sewer District might employ a "domino theory". That is, Prosser Lake View
Estates is potentially within 200 feet of the GC sewer system at the northwest boundary
of the project and thus eligible to be mandated into the sewer system. If that occurs, PWE
could also be considered within 200 feet of the new inclusive boundary of the sewer
' system. Employing the "domino theory" is unacceptable to PWE.
1
1
August 7, 2003 1
Heidi Scoble, Truckee Community Development Department
GC Draft EIR Comments
1
TRAFFIC
PWE has 4 major concerns relative to Traffic impacts from GC. 1
1). (Impacts 4.2.1 and 4.2.8) The 127 lots that compose all of GC Phase 4 rely
entirely on one access point. Essentially, the one access point planned at East
•
Alder Creek Road and the new subdivision road creates a giant cul -de -sac effect.
This will impact PWE access towards Prosser Dam Road. A second full time
access point is needed (not just an emergency road access). Please refer to Exhibit
1, created by PWE, to locate three potential additional access points.
a). In Exhibit 1, highlighted "A ", is the potential for the existing 13 -2 1
emergency access road at Rainbow Rd. to become a full -time access point.
b). In Exhibit 1, highlighted "B" is the potential for eliminating the 1
planned cul -de -sac and extending the road for a new connection to Hwy
89N located between Rainbow Rd. and Prosser Dam Rd., potentially
opposite the access point for Phase 1 at Hwy 89.
c). Finally, in Exhibit 1, highlighted "C" is the potential for-
1
eliminating the planned cul -de -sac and continuing the road back to Prosser
Dam Rd.
2). (Impacts 4.2.1 and 4.2.8) The proposed intersection alignment (See Exhibit
2A) at the northeast corner of the GC project (Phase 4) impacts PWE. As
currently aligned, 127 future GC lot owners and the 12 PWE lot owners would 1
utilize the intersection. The proposed alignment impacts PWE because 127 future
GC lot owners would be heading directly towards PWE on East Alder Creek and
will have to make 90 degree left turns into their area. On the other hand, only the
12 PWE owners will utilize the alignment that provides a straight access to PWE. 13 -3
It seems logical, to prevent possible missed turns by 91% of the traffic, that the
road alignment/intersection change to the manner depicted in Exhibit 2B. The
revised alignment would benefit the vast majority of the traffic by providing
direct access and less potential confusion. Because PWE is a private community
with a gated entry, many vehicles (lost or otherwise) are forced to make awkward
maneuvers to turn around at the gated entry. To address the "tum- around"
problem, PWE desires to see a circular (urn- around area developed south of the '
PWE gated entry. This should ease an existing problem that will only get worse
with residential traffic and construction traffic.
3). (Impact 4.4.1 and Mitigating Measures 4.1.1c and 4.4.1a) The impact 1
resulting from the timing of road improvements within GC has not been
adequately addressed, specifically as they affect East Alder Creek Road in the 13 -4 ,
northeast portion of GC. Mitigation measures, such as dust control during
construction and partial or complete road closures, do not address the impact of
GC construction traffic over the existing gravel/dirt road (East Alder Creek)
during the early GC phases 2 and 3, golf course construction, and sewer system
Page 2 of 4
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August 7, 2003
' Heidi Scoble, Truckee Community Development Department
GC Draft EIR Comments
!
' construction (Sewer Pump Station at the northeast area of the project). Because
PWE lot owners, on a daily basis, access PWE via the unpaved road, the
construction of phases 2 and 3, the golf course construction, and the sewer system
•
' construction, will greatly impact PWE access long before homes are actually
under construction in Phase 4 (the adjacent phase). In order to avoid the road
being badly damaged and unusable by PWE residents (or even closed), mitigation
measures should be included in the EIR that require the developer to install
necessary base rock and the first lift of asphalt, along the approved final
horizontal and vertical alignment of the road, at the commencement of Phase 2.
Then, to complete the road, the developer should be required to install final
asphalt during Phase 4 construction.
•
4). The last Traffic related impact to PWE not addressed in the draft EIR is
the need for new easements relative to East Alder Creek Road.
(a). If the Road is realigned relative to the comment made in Traffic:
Section 2, a new easement will be necessary.
(b). Coinciding with that potential realignment, a small monument sign 13 -5
might be located at the revised intersection indicating the direction of the PWE
private gated community (also a "No Outlet" sign).
1 (c). The new easement(s) need to be expanded to include sufficient area
for potential minor landscape, irrigation, and electrical needs associated with the
1 signage.
(d). The same expanded easement(s) would be necessary to allow for the
1 "turn- around" area on East Alder Creek Road just south of the PWE entrance.
PWE would like to take a moment to state that East West Partners purchase of the old 13 -6
PC -2 / Hopkins Trust project / property was a real positive for the Town on Truckee. The
proposed plan is far superior to the old PC2 / Hopkins Trust plan.
However, as outlined herein, PWE has real concerns about the impacts of GC upon PWE.
PWE desires that the EIR and the Project's Conditions of Approval address the fore-
' mentioned concerns and include the PWE mitigations. In light of the scope and
magnitude of the overall Gray's Crossing project, the requested mitigations are logical, 13 -7
proper, and minimal. PWE believes, with the mitigations included, the Gray's Crossing
' Project will be a win — win proposition for both East West Partners and for PWE. Please
address questions to John Moore, co -chair of the PWE Planning Committee, at the
letterhead address or phone number. •
' Sincerely,
The Lot Owners of Prosser Woods Estates (Signatures attached)
1 Page 3 of 4
August 7, 2003
Heidi Scoble, Truckee Community Development Department
1 GC Draft EIR Comments
1
Ed and May Candler Dennis and Pat Ward ,
Lot 1 Lots 2 and 3
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Jo and Janet Moore E ie Grossman/Margaret Lewicki
ot4 Lot5
Gra; e Ras, /Tracey Lum Tom and Elisabeth Grossman
Lo . 6 and 7 Lot 9
Pat Setter
Lot 11
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Page 4 of 4
Jul 31'03 02:47p First Real t;; 5305926021 p. 2.
elf 31/2603 12:56 925243013 J PATRICK LAND - PAGE 07
- August 7,2003 ..
Heids l able, Truckee Community Development Deparmnent
GC Draft TJR Comments
•
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Ed and May ! Damns and Pat Ward
Lot 1 Lots 2 and 3 - -
•
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Graeme Fraser /Tracey Lum Tom and Elisabeth Grossman
Lots 6 and 7 Lot 9 •
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2.0 RESPONSE TO COMMENTS
LETTER 13 THE LOT OWNERS OF PROSSER WOODS ESTATES
1
Response to Comment 13 -1
This comment expresses the concern that the 5 -acre lots within Prosser Woods Estates
will be forced to hook into the project's sewer system. Although it is the Truckee
I Sanitation District's policy to require adjacent lots to hook into a new sewer system if
that system is within 200 linear feet of a sewer line, this comment indicates that Prosser
Woods lots are more than 500 feet from the project's sewer system (see also Specific
' Plan, Preliminary Utility Plan (Map 6)). While one of the project's objectives is to provide
the opportunity for sewer hook ups for the smaller Prosser Lakeview Estates lots, it is not
anticipated that these hook ups will affect Prosser Woods Estates (Draft EIR page 3 -20).
' The Truckee Sanitation District has confirmed that there are no plans to require Prosser
Woods Estates to hook into the project's sewer system at this point in time. Prosser
Woods Estates is, however, within the District's five -year sphere of influence. Even if
' - sewer systems are eventually extended directly to Prosser Woods Estates, the Lahontan
RWQCB can issue an exemption from required sewer hook ups for lots five -acres or
greater that satisfy certain criteria applied via a point system.
' Response to Comment 13 -2
The commentor indicates that a second access is required for the Phase 4 area
(bordered by SR 89 to the west, Prosser Dam Road to the south, and Alder Creek Road
to the east) to avoid developing one "giant cul -de -sac" and recommends three
' potential alignments for this second access. However, this secondary access is not
required for safety considerations, as a second emergency access is provided. In
addition, it is not required for traffic operations considerations as the EIR indicates
' adequate LOS along Prosser Dam Road and at the Prosser Dam Road /Alder Drive
intersection would result from the proposed configuration. In addition, Caltrans
attempts to limit the number of access points on all state highways in order to improve
• • flow on the highway and to limit the number of vehicle conflicts, thereby reducing
potential for accidents to occur. Since this additional connection would not be
necessary from an operation or safety standpoint and alternatives A and B would
' require a new access on SR 89 (which could in turn require additional highway turn
lanes), these alternative access points are not recommended. In addition, alternative
• C would unnecessarily impact the wetlands area located just north of Prosser Dam
' Road. This comment is provided here for the consideration of the Town Council.
Response to Comment 13 -3
1 The commentor indicates that the Phase 4 access on Prosser Dam Road would impact
Prosser Woods Estates (PWE) as the residences entering the Gray's Crossing Phase 4
area could possibly miss their turn and then be required to turn around in the PWE
gated entry. Although there may be an occasional lost driver in the area, it is unlikely
that the occurrence would happen so often as to significantly impact the PWE access.
In addition, the increase of traffic along Alder Creek Road resulting from the
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -122
September 2003
2.0 RESPONSE TO COMMENTS
construction of 127 dwelling units does not constitute a significant impact. Specifically, 1
the project would add 86 PM peak -hour vehicles to Alder Creek Road north of Prosser
Dam Road, representing a 64 percent increase. The increased volume on the roadway
would still be within the capacity of the roadway and the Alder Creek Road /Prosser
Dam Road intersection. As driving from the site to SR 89 to the north via Alder Creek
Road would take more time than using Prosser Dam Road and SR 89, virtually no '
project - generated vehicles would travel past the PWE site, thereby resulting in no
impact. Regardless, either the proposed intersection configuration or the configuration
suggested by the commentor would work from a traffic operations standpoint. '
Therefore, the suggested configuration should be considered by the project applicant.
Response to Comment 13 -4
The commentor states that the timing of road improvements has not been adequately
addressed because dust control resulting from construction traffic along Alder Creek •
Road within the vicinity of the Prosser Woods Estates development has not been
adequately addressed. See Master Response 2.4.6 Construction Impacts and Response
to Comment 11 -11. On pages 4.4 -11 and 4.4 -12 of the Draft EIR, MM 4.4.1a requires 1
several construction traffic mitigation measures, some of which are as follows:
• Contractors shall be responsible for ensuring that adequate dust control
measures are implemented in a timely manner during all phases of project
development and construction.
• All areas (including unpaved roads) with vehicle traffic shall be watered or have
a dust palliative applied as necessary for stabilization of dust emissions.
• All on -site vehicle traffic shall be limited to a speed of 15 mph on unpaved roads.
• All materials transported off -site shall be either sufficiently watered or securely '
covered to prevent public nuisance.
In addition, MM 4.4.1 b requires that all construction contracts "shall provide a plan for '
approval by the ASQMD demonstrating that heavy -duty off -road vehicles to be used in
the construction project, including owned, leased and subcontractor vehicles, will
achieve a project wide fleet- average 20 percent NOx reduction and 45. percent
particulate reduction compared to the most recent CARB fleet average at time of
construction."
The commentor's suggested provision and timing of road surfacing would not result in
any environmental impacts. The commentor's suggestions regarding the method by
which roads should be constructed and when final asphalt should be installed are ,
noted and are included for the project applicant and Town Council's consideration.
Response to Comment 13 -5 '
The commentor states that the EIR did not address the following items regarding new
easement relative to Alder Creek Road: '
a. If the road is realigned relative to comment 13 -3, a new easement will be
necessary. '
Town of Truckee Final Environmental Impact Report
September 2003 2 -123 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS
b. Coinciding with that realignment, a small monument may be constructed at the
new intersection also with a "No Outlet" sign.
1 c. The new easement should provide sufficient landscape, irrigation, and electrical
needs.
' d. The same expanded easement would be necessary to provide a turn - around
area.
' Please refer to Response to Comment 13 -3. This comment and the suggestions provided
are noted and should be considered by the project applicant.
' Response to Comment 13 -6
This comment generally compliments East West Partners and the proposed project.
Since this comment does not address the adequacy of the Draft EIR, no further
1 response is required.
t Response to Comment 13 -7
This comment states that the general concerns expressed in Letter 13 should be
addressed in the project's conditions of approval. Since this comment does not
1 address the adequacy of the Draft EIR, no further response is required.
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Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -124 September
1 LETTER 14
Karen Sessler
' 12375 Poppy Lane
Truckee, CA 96161
' August 3, 2003
Truckee Town Council
10183 Truckee Airport Rd.
Truckee, CA 96161
To the Members of the Truckee Town Council and Planning Commission,
I respectfully submit the following comments on the Gray's Crossing Specific Plan/
' Tentative Map DEIR. As a member of the Town of Truckee Trails and Bikeways Master
Plan Advisory Committee I spent a great deal of time helping to create the Trails and 14 -1
Bikeways Master Plan. It is my opinion that the Gray's Crossing Specific Plan and
' Tentative Map/ Draft EIR (hereafter referred to as "The Plan ") is not in consistent with
the Trails and Bikeways Master Plan. It is also my opinion that "the Plan" is not
consistent with General Plan Circulation Policies that apply to bikeways. I detail my
concerns below and thank you for your diligent consideration.
1. Connectivity and Continuity - Planning Goal 2 of the Trails and Bikeways Master
Plan is "Connectivity and Continuity ". The stated goal is that "the trail and bikeway
system should link the Town's historic downtown, residential and commercial
areas, and recreational, educational, natural, and historical resources utilizing
public and private lands as necessary and appropriate': The stated policies are that
trails should "utilize established routes ...whenever possible" and should "be planned
' through private lands when necessary to (i) ensure connectivity and continuity of
the system (ii) provide access to resources or (iii) link the system with major access
points': The Trails Plan as outlined in "The Plan" fails to provide connectivity and 14 -2
' continuity. The trails in "The Plan" are purely a series of trails for use within the
planned development with no connection with Downtown Truckee or to adjacent
subdivisions. No connection is made to the Prosser Lakeview subdivision to the north
' of the proposed development and the only trail that approaches that subdivision is
separated from it by a busy state highway. That proposed north/south trail, to the east
of Hwy 89N, further has no connection to the Class I bike trail to its south. The plan
does not include any link to Downtown Truckee, nor to the Pioneer Commerce Center
(Sierra College).
' 2. Alternative Transportation Links — The Trails and Bikeways Master Plan states in
Chapter 9 that "A third, equally important, alternative transportation connection is 14 -3
' needed the length of State Highway 89 North between Historic Downtown Truckee/
Donner Pass Road and the Prosser area. Similarly, creation of this bicycle facility
will provide a connection with a major residential area(s) and coinciding with a
commonly used bicycle route on the state highway". Although "the Plan" includes a
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recreation trail along the west side of Hwy 89N, it makes no provisions for an
alternative transportation bikeway and is therefore not consistent with the Trails and
Bikeways Master Plan. 1
3. Truckee General Plan Circulation Policy 5.1 is "to establish a comprehensive and
safe system of bicycle routes and pedestrian trails for short range commuting, ,
shopping trips and for recreation use" The trails, as outlined in "The Plan", do not
establish a "system" by which residents of subdivisions to the north could access the 14 -4 •
shopping in the Gray's Crossing Village and Downtown Truckee nor the recreation
facilities at the middle school now under construction. "The Plan" does not facilitate
commuting to work at Gray's Crossing, Pioneer Commerce Center, or Downtown
Truckee. How would a resident of Prosser Lakeview bicycle to their job in downtown
Truckee, to classes at Sierra College, or to the mallet in the Gray's Crossing Village?
How would residents of Coachland walk to church in the village? '
4. Truckee General Plan Circulation Policy 5.2 is "New bikeways shall be linked with
other bikeways and parks to provide safe continuous routes ". The Trails and
Bikeways Master Plan delineates a Class II Bike Lane along Hwy 89N as well as 14 -5 ,
Class III Bike Route through the Prosser Lakeview Subdivision. "The Plan" is not
consistent with Circulation Policy 5.2 in that it is not linked to the Proposed Class III_
bikeway in Prosser, nor does it further the creation of the Class II Bikeway along
Hwy 89N.
5. The Gray's Crossing Trails Plan is further not consistent with General Plan r
Circulation Policy 5.2 by failing to create a safe link to parks. "The Plan" denotes a
recreation trail along the west side of State Hwy 89N that abruptly ends just south of,
and on the opposite side of, the Hwy 89N entrance to the Prosser Lakewood Estates
subdivision. No provision is made for a safe crossing of this state highway. The new 14 -6
Middle School and its recreation facilities will certainly draw use from the youth of
the Prosser Lakeview Subdivision and a trail whose use requires crossing a busy state
highway is clearly unsafe and unacceptable. That same recreation trail further fails to
connect with the Class I Bike Path along Alder Drive missing an opportunity to
connect with the recreation facilities at the Middle School.
6. General Plan Circulation Policy 5.3 "Encourage the provision of bicycle routes '
along State highways" is flouted by "The Plan" as being "Not Applicable" and that 14-7
"There is no opportunity for this project to provide bicycle routes along state
highways ". This project has a very real opportunity to provide a bicycle route along
state highway 89N and Town of Truckee officials and staff have an obligation to
`encourage' the developer to provide that route.
7. Circulation Policy 5.6 empowers the Town to "require developers to finance and
install pedestrian walkways, equestrian trails and multi -use trails on new 14 -8
development, as appropriate and necessary to address circulation needs." It is
clearly a circulation need to move people from Prosser Lakeview and other
subdivisions to the north into the Downtown core. It is clearly a circulation need to v
1
move students to and from the new Middle School in a safe manner, minimizing the /\
' use of automobiles. "The Plan" does not effectively address these circulation needs
and is not consistent with the General Plan.
8. In assessing the points above, I respectfully point out that there is currently a dirt path
that runs just to the east of Hwy 89, running north and south, through the property
under consideration in "the Plan ". This path has historically been used as a route for
commuting from the Prosser Lakeview subdivision to Downtown Truckee and is used
as a safer alternative to riding on Hwy 89N. My family has personally used this trail
to commute to work in Downtown Truckee. "The Plan" as written eliminates this
1 important route and does not provide a satisfactory alternative. If the Town is to 14 -9
comply with its stated goal of encouraging and facilitating altemative transportation,
then a Class II or Class I Bikeway along the east side of Hwy 89N, connecting with
' the Prosser Lakeview subdivision, to the north, and connecting with Downtown
Truckee and the Pioneer Commerce Center, to the south, must be a component of the
Gray's Crossing Specific Plan.
1 A review of "The Plan" reveals that The Truckee Trails and Bikeways Master Plan" is
glaringly absent from the list of references for chapter 4.2 Transportation and Circulation
' (pg. 4.2 -89). Truckee officials, town staff and community members worked long and
hard to create the Trails and Bikeways Master Plan and it is imperative that the 14 -10
Developers of Gray's Crossing bring forward a plan that is consistent with both the
' Truckee General Plan and the Trails and Bikeways Master Plan. I am confident that
Town staff and the Developers of Gray's Crossing can work together to create a trails •
plan that will truly be consistent with the General Plan Circulation Goal 5 and will
embrace the principals of connectivity and continuity.
' Respectfu y yours,
/r
1 Karen Sessler
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2.0 RESPONSE TO COMMENTS
LETTER 14 KAREN SESSLER, AREA RESIDENT
Response to Comment 14 -1
The commentor expresses the opinion that the plan is inconsistent with the Town of
Truckee's Trails and Bikeway Master Plan. The Draft EIR does provide an analysis of the
plan's consistency with the Master Plan and concludes that the plan is consistent. The
Draft EIR also found that the Plan would have an overall beneficial impact on
pedestrian and bicycle safety (Draft EIR page 4.2 -51 and Figure 3 -13). The commentor's
1 opinion is noted, however, and is included here for the consideration of the Town
Council.
Response to Comment 14 -2
The commentor states that the Gray's Crossing Bike and Trailway System (Figure 3 -13),
proposed as part of the project, fails to connect the area with downtown Truckee,
1
adjacent subdivisions or the Pioneer Commerce Center (Sierra College) in compliance
with the Truckee Trails and Bikeways Master Plan. Please see Response to Comments
14 -4 and 14 -5.
I Response to Comment 14 -3
1 The commentor suggests that the plan is inconsistent with the Trails and Bikeways Master
Plan because it does not provide for an alternative transportation bikeway besides that
provided along the west side of SR 89N between Downtown Truckee /Donner Pass Road
1 and the Prosser area. As demonstrated in the Master Plan and the commentor's own
letter, the Master Plan does not require such an alternative, simply that a third
alternative transportation connection is needed. The proposed Class I Bike Trail does,
' however, link Downtown as it runs adjacent to Alder Drive which allows linkage to
Thayer Drive (Comstock Drive) and ultimately to Downtown (Draft EIR (Figure 3 -13). The
Plan is therefore consistent with Truckee's Trails and Bikeways Master Plan.
1 Response to Comment 14 -4
The commentor states that the project is inconsistent with Circulation Policy 5.1 of the
General Plan. As explained in the Specific Plan, the project is consistent with Policy 5.1
because it allows for the project applicant to work with the Truckee Donner Recreation
1 and Park District to prepare and implement a Bicycle and Pedestrian Trail Master Plan.
Specifically, the plan enables the applicant and the Truckee Donner Recreation and
Park District to create the bicycle and pedestrian master plan that would serve this
property as well as adjacent properties and Downtown (Specific Plan page 33 and
Draft EIR page 3 -34, Figure 3 -13). The Plan's Pedestrian and Bike Trail System Plan,
moreover, shows how the area can and will link surrounding properties to the
I Downtown Truckee area as shown in Figure 1.4 of the Downtown Specific Plan shown
on Plate 5 of the Truckee General Plan (see also Draft EIR Figure 3 -13).
1
Town of Truckee Final Environmental Impact Report
September 2003 2 -125 Gray's Crossing Specific Plan Project
2.0 RESPONSE TO COMMENTS 1
The overall goal of the Town's Trails Master Plan is the provision of comprehensive
regional trails connectivity, which the Gray's Crossing Trail Plan strives to achieve. As
pointed out in the Draft EIR, the Gray's Crossing Trails Plan, does contain some
shortcomings related to _connectivity, as exampled by no provision for a connection
between the trail proposed adjacent to SR 89 with the proposed Class I bike trail
adjacent to Alder Drive. Regardless, per MM 4.1.5, the Town of Truckee will make a final
determination of the project Trails Plan consistency with the intent of the adopted Town
of Truckee Trails Master Plan.
Response to Comment 14 -5 1
The commentor notes that the plan is inconsistent with General Plan Circulation Policy
5.2 because it is not linked to the proposed Class III bikeway in Prosser, and does not
facilitate the creation of a Class II Bikeway along SR 89N consistent with the Trails and
Bikeways Master Plan.
As detailed on page 4.1 -32 of the Draft EIR, the Town's Trails and Bikeways Master Plan
trail routes are general in nature and provide conceptual alignments to get from key
points in the community to other key points. The Trails Master Plan is intended as a
guide for routing and does not establish exact alignments as long as connections are
provided. In fact, strict adherence to the Town's Trails Master Plan may potentially
conflict with circulation patterns and would also increase environmental impacts. The
overall goal of the Town's Trails Master Plan is the provision of comprehensive regional
trails connectivity, which the Gray's Crossing Trail Plan'strives to achieve. As pointed out
in the Draft EIR, the Gray's Crossing Trails Plan, does contain some shortcomings related
to connectivity, as exampled by no provision for a connection between the trail
proposed adjacent to SR 89 with the proposed Class I bike trail adjacent to Alder Drive.
Regardless, per MM 4.1.5, the Town of Truckee will make a final determination of the
project Trails Plan consistency with the intent of the adopted Town of Truckee Trails
Master Plan.
Further, as explained in the Specific Plan, the project is consistent with Policy 5.2
because PC -2 is the hub that will connect surrounding properties, including Tahoe
Donner, Prosser Lakeview Estates, Prosser Heights and surrounding subdivisions with an
updated transportation system that includes, pedestrian, bike and public transit options.
In addition, trolley stops are proposed to serve the Village Center District, adjacent
Coachland Mobile Home Park, school site and the lodging facility (Specific Plan page
34).
Neither the project applicant nor the Town Council can legally require other property
1
owners, including those between the project site and the Class III Bikeway, to dedicate
land to create the trail suggested by the commentor. To the extent the property site
abuts the Old Greenwood Resort project, such links have been considered as part of
the projects (Draft EIR Figure 3 -13).
Consistent with Policy 5.2, the plan will also link new bikeways with other paths and
bikeways to provide safe continuous routes. Any crossing of SR 89 shall be avoided or
mitigated so as to reduce any public safety risks.
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -126 September 2003
• 2.0 RESPONSE TO COMMENTS
The suggestion to connect the proposed recreation trail along the west side of SR 89N
to the Class I Bike Path along Alder Drive is noted and is included here for consideration
1 of the Town Council
Response to Comment 14 -6
The commentor states that the project's Trails Plan is not consistent with General Plan
Circulation Policy 5.2. Please see Response to Comment 14 -5..
1 Response to Comment 14 -7
1 The commentor notes that the Town of Truckee has an obligation to "encourage" the
project applicant to provide a bicycle route along SR 89 North. The ability to create
such a route along a state highway is oufside the Town's jurisdiction, however, and rests
' solely with the California Department of Transportation.
Response to Comment 14 -8
1 The commentor notes that the plan does not effectively address the circulation needs
of Prosser Lakeview residents or residents of the area. The comment is noted and
provided for the consideration of the Town Council
Response to Comment 14 -9
The commentor suggests that an existing dirt path runs just to the east of SR 89 from
Prosser Lakeview to Downtown and must be preserved as part of the plan. None of the
project objectives call for the preservation of each dirt path that exists and is currently
used within the project site. Preservation of each path that criss- crosses the project site
would result in a fragmented and fiscally infeasible plan. Preservation of the path
referenced by the commentor is also unnecessary because construction of the
1 proposed Class I bike trial will provide the same access (Draft EIR Figure 3 -13).
Response to Comment 14 -10
The commentor suggests the Plan neglects to consider the Truckee Trails and Bikeways
Master Plan. Despite the omission of the Master Plan from the list of references for
Chapter 4.2 of the Draft EIR, the Master Plan was considered and any conflict deemed
less than significant (Draft EIR page 4.2 -51). The commentor's opinion is nonetheless
noted and provided for the consideration of the Town Council.
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Town of Truckee Final Environmental Impact Report
September 2003 2 -127 Gray's Crossing Specific Plan Project
Ju.l.16. 2003 2:38PM No.0526 P. 1
1
1 July 16, 2003 LETTER 15
Heidi Scobel R E C EI11 ED
r 582 -7889 Fax ,JUL 1 b VW Re: Grays Crossing
Comments for submission on review of the project;
1 1. Affect of groundwater removal to water Golf Course and landscaping of common (
areas and homes. Homes in the Prosser Ranches and Pannonia are on wells.
2. Any crossings for the Golf Course across Prosser Dam Road should be under the 1 15 -2
roadway so traffic is not affected.
3. Dust mitigation during construction for the properties located down wind of the ( 15 -3
' project.
Thank you for your attention to this matter.
' Sincerely,
Robert Yoder and Nancy Davis
12261 Prosser Dam Road
Truckee
582 -3313
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2.0 RESPONSE TO COMMENTS
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LETTER 15 ROBERT YODER AND NANCY DAVIS, AREA RESIDENTS
Response to Comment 15 -1
The commentor asks about the effects of groundwater removal for golf course and
landscaping watering needs. Please see Master Response 2.4.7 Water Supply and
Master Response 2.4.3 Water Quality.
Response to Comment 15 -2 •
•
This comment suggests that crossings for the golf course over Prosser Dam Road should
be underground. This comment is noted and is included for the Town Council's
I consideration. The project, however, does not currently propose underground crossings
for the golf course. Areas indicated for golf cart crossing are shown in Figure 3 -6 in the •
Draft EIR. Based on standard practices, it is assumed that golf carts will yield to passing
traffic. It is not anticipated that these intermittent crossings will affect traffic or otherwise
create a significant traffic or safety impact.
Response to Comment 15 -3
The commentor requests dust mitigation during construction for properties located
down wind of the project area. See Master Response 2.4.6 Construction Impacts and
Response to Comment 13 -4.
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• Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -128 September2003
I LETTER 16
August 8, 2 0 0 3
I . He i di S c o b l e
T o w n of T r u c k e e
1 1 0 1 8 3 T r u c k e e A i r p o r t Road .
Truckee, C A 9 6 1 6 1
I S u b j e c t : G r a y ' s C r o s s i n g Dr a f t E I R
D e a r Ms. S c o b l e,
1 I a p p r e c i a t e t h e o p p o r t u n i t y t o
c o m m e n t on t h e C r a y ' s C r o s s i n g
1 p r o j e c t and D E I R.
I am an e c o l o g i s t w i t h m a n y y e a r s of
I project experience i n t he Truckee -
Tahoe regi on, and have compl et ed
f i e l d s t u d i e s on b o t h t he Old
I G r e e n w o o d a n d C r a y ' s C r o s s i ng si t e s
under c o n t r a c t t o E a s t - W e s t
P a r t n e r s . I n g e n e r a l , I am f a v o r a b l y
I i m p r e s s e d by b o t h t h e s p e c i f i c s of
t h e G r a y ' s C r o s s i n g p r o j e c t a n d t h e
commi t ment t o envi ronment al
I p r o t e c t i o n of t h e E a s t - W e s t s t a f f
wi t h whom I have wor ke d 16-1
Never t hel es s, t hes e past and 1 i kel y
1
f u t u r e w o r k i n g r e l a t i o n s h i p s wi t h 1
t h e a p p l i c a n t do n o t p r e c l u d e my
I c o m m e n t i n g on c e r t a i n s p e c i f i c ways
in w h i ch more ri g o r o u s document a t i on
in t h e E I ' R m i g h t r e s u l t in m o r e
I e f f e c t i v e m i t i g a t i o n of p o t e n t i a l
e n v i r o n m e n t a l e f f e c t s of t h e
p r o j e c t , wi t h o.0 t i n t e r f e r i n g w i t h
a c h i e v e m e n t I of t h e a p p l i c a n t ' s g o a l s
o r i n c u r r i n g s u b s t a n t i a l m i t i g a t i o n
c o s t s.
1 Trails •
C o n n e c t i v i t y a n d s e t t i n g of wa l k i n g,
I b i c y c l i n g, and s k i i n g t r a i i s i s a . 16_2
✓ e r y i m p o r t a n t f a c t o r i n t h e f u t u r e
s o c i al envi ronment of t he Town of
1 T r u c k e e a n d vi c i n i t y . T h e di s c u s s i on j
1
•
1
o f I mpa c t a n d M i t i g a t i o n M e a s u r e / 1
4.1.5 d o e s n o t p r o v i d e s u f f i c i e n t
c l a r i t y to r e a s s u r e t h e p u b l i c t h a t 1
the goals of the General Plan
p o l i c i e s r e l a t i n g to t r a i l s w i l l be
a c h i e v e d . M i t i g a t i o n M e a s u r e 4.1.5 1
must p r o v i d e s p e c i f i c s t a n d a r d s f o r
t h e T o w n t o u s e i n m a k i n g t h e
c o n s i s t e n c y j u d g me n t .
P a r t i c u l a t e E m i s s i o n s
S e c t i o n 4.4 of t h e D E I R p r o v i d e s
ab's of ut el y no i of or mat i on upon whi ch
t h e p u b l i c c a n j u d g e whether i t is
f e a s i b l e to a c h i e v e f u l l o f f - s i t e
mi t i g a t i on of w o o d - b u r n i n g
e m i s s i o n s , as s u g g e s t e d in t h e
l a t t e r s e c t i o n of M i t i g a t i o n M e a s u r e
4.4.4 ( t h e e n t i r e t e x t f o l l o w i n g t h e
capitalized word "OR "). This
M i t i g a t i o n M e a s u r e is t h e r e f o r e
i n a d e q u a t e u n l e s s t h i s t e x t is
d e l e t e d , or a c o m p l e t e q u a n t i t a t i v e _
a n a l y s i s of t h e a c t u a l p a r t i c u l a t e 16
✓ e d u c t i o n s that w o u l d be a c h i e v e d ,
in e x a c t l y w h a t manner, is p r o v i d e d .
S u c h m i t i g a t i o n s houl d precede the
i n s t a l l a t i o n of e a c h wood - bur n i n g
d e v i c e ( i n c l u d i n g open - hear t h 1
f i r e p l a c e ) that w o u l d be p e r m i t t e d
by the text in question. It would be
m u c h s i m p l e r a n d p r e f e r a b l e m e r e l y
to d e l e t e t h i s u n s a t i s f a c t o r y
al t er nat i ve. Wood- burni ng
p a r t i c u l a t e s a r e a l s o a v i s u a l ( d a r k
s k y ) i m p a c t , b e c a u s e they e n h a n c e
t h e s c a t t e r i n g of a r t i f i c i a l
l i g h t i n g.
Hydr of ogy 1
The DEIR should expl ai n why
Mitigation Measure 4.6.7 relies upon •
speci f i c commercial products 16 -41
( p r o g r a m s ) f o r t h e h y d r o l o g i c
a n a l y s i s . I t s e e m s e x t r e m e l y
u n l i k e l y t h a t o n l y the s p e c i f i c / 1
2 1
' s o f t w a r e m e n t i o n e d in t h e m e a s u r e i s
a p p r o p r i a t e f o r t h e a n a l y s i s i n
q u e s t i o n ; a l s o , no i n f o r m a t i o n i s
p r o v i d e d that i n d i c a t e s why even
' t h e s e p r o g r a m s a r e a d e q u a t e . T h e r e
s h o u l d be m o r e d e t a i l e d d i s c u s s i o n
in t h i s s e c t i o n .
B i o 1 o g i cal Resources
T h e d i s c u s s i o n of v e g e t a t i o n p r e s e n t
on t h e s i t e i s v e r y w e a k a n d
c o n t a i n s both minor and maj or
i naccur aci es in t er ms of dominant
s p e c i e s , o t h e r s p e c i e s p r e s e n t , a n d
c h a r a c t e r i z a t i o n of h a b i t a t t y p e s .
S i n c e t h e f i e l d b i o 1 o g i s t h a d t h e
' b e n e f i t of o n l y o n e d a y in t h e
f i e l d , in a v e r y i n a p p r o p r i a t e
s e a s o n to e v a l u a t e t h e s i t e , i t
' w o u l d a p p e a r to me that t h i s
s u b c o n s u l t a n t p e r h a p s di d n o t h a v e
s u f f i c i e n t r e s o u r c e s or t i m e t o
' a d e q u a t e l y s t u d y t h e i s s u e s . T h e r e
i s no r e f e r e n c e or b a s i s f o r t h e
v e g e t a t i o n t y p e s that a r e d i s c u s s e d .
' T h e D E I R r e f e r e n c e s d o c u m e n t s w h i c h 16 -5
p r o v i d e c o n s i d e r a b l y m o r e d e t a i l a n d
' a c c u r a c y t h a n is r e f l e c t e d in t h e
t e x t . T h i s d o e s n o t i n s p i r e
c o n f i d e n c e in t h e a n a l y s i s of
i mpa c t s, and pr ovi des a poor
f o u n d a t i o n f o r f u t u r e n a t u r a l
r es our ces pl anni ng by the appl i c a.nt
or A u d u b o n I n t e r n a t i o n a l ( A I ) . T h i s
is i m p o r t a n t s i n c e r e v i e w of i n i t i a l
. d o c u m e n t a t i o n by A I f o r t h e Old
' Greenwood project evidenced
i n a d e q u a t e f a m i l i a r i t y w i t h t h e
plant species and .vegetation types
that were act ual I y present on that
s i t e ( r e l y i n g i n s t e a d u p o n o n e
g e n e r a l i z e d r e f e r e n c e that was
' a p p l i c a b l e to m u c h m o r e me s i c w e s t
s l o p e S i e r r a n h a b i t a t s ) . F o r t h e s e
r e a s o n s , m i t i g a t i o n m e a s u r e s t h a t
' r e l y upon t h e A I c e r t i f i c a t i o n f o r
1 3
1
par t i al mi t i gat i on of gener a l or
s p e c i f i c b i o l o g i c a l r e s o u r c e i m p a c t
a r e s u s p e c t wi t h o u t t h e o p p o r t u n i t y
f o r a d d i t i o n a l p u b t i s r e v i e w and
i n p u t .
I n e x p l i c a b l y , t h e t e x t d i s c u s s e s •
only a f e w of the spec i es t ha t are
l i s t e d in T a b l e 4 . 7 - 1 * . S o m e of t h e
s t a t e m e n t s of h a b i t a t s u i t a b i 1 i t y
a r e i n c o r r e c t ; f o r o n e e x a m p l e ,
t h e r e is no n u t r i e n t - d e p t e t e d b o g
h a b i t a t s u i t a b l e f o r a n y s p e c i e s of
Drosera. On the other hand, i t is
u n c l e a r why t h e r a is no d i s c u s s i o n
at all of the CNDDB occurrence of
S i e r r a N e v a d a r e d f o x w i t h i n or
i m m e d i a t e l y a d j a c e n t to t h e p r o j e c t
s i t e , or of h o w t h e p r o j e c t or
m i t i g a t i o n m e a s u r e s w o u l d e n s u r e t h e
c o n n e c t i v i t y of d i f f e r e n t h a b i t a t
a r e a s t h a t m i g h t be u s e d by t h i s
✓ a r e s p e c i e s . T h e r e is m u c h m o r e 1
d e t a i l e d i n f o r m a t i o n avai l abl e on
t h i s s p e c i e s , s n o w s h o e h a r e , a n d
o t h e r s , t h a n is p r o v i d e d in t h e 1
D E I R , l e a d i n g t o r e p r e s e n t a t i o n i o n of p o t e n t i a l i m p a c t s
in s o m e c a s e s a n d o v e r -
✓ e p r e s e n t a t i o n n in o f her s.
For the record, we have document ed 1
t h e o c c u r r e n c e of s e v e r a l n e s t i n g
p a i r s of L e wi s ' s w o o d p e c k e r on t h e
adj acent Old Greenwood site in
✓ e p o r t s p r o v i d e d to t h e a p p l i c a n t
a n d i n t u r n t o t h e T o w n . T h i s
s p e c i e s is a l m o s t c e r t a i n l y l i m i t e d
by t h e a v a i l a b i l i t y of s u i t a b l e n e s t
c a v i t i e s in d e a d t r e e s . T h e r e f o r e ,
r e m o v a l of s u c h t r e e s s h o u l d be
i d e n t i f i e d as a p o t e n t i a l l y
s i g n i f i c a n t i m p a c t on L e w i s ' s
woodpecker, a n d r e l o c a t i o n of a n y
sui t a b l e ( o r k n o w n ) n e s t i n g s i t e s
f o r L e wi s ' s w o o d p e c k e r to s u i t a b l e 1
4
1
h a b i t a t in o p e n space, or, l e s s
p r e f e r a b l y , p r o v i s i o n of a r t i f i c i a l
c a v i t i e s 1 or c r e a t i o n of new s nags ,
s h o.0 1 d be i mp 1 e me n t e d.
1 The DEIR states that there will be
n o d e v e l o p m e n t w i t h i n 100- year
1 f l o o d p l a i n s , a n d that t h i s w o u l d
p r o v i d e a b u f f e r z o n e more t h a n 1 0 0
f e e t w i d e f r o m t h e s e a s o n a l
t r i b u t a r i e s . A l b e i t r e q u i r e d by t h e
L a h o n t an B a s i n P I an f or w a t e r
q u a l i t y r e a s o n s , t h i s p o l i c y
provides an excel l ent el ement in
c o n s e r v a t i o n of g e n e r a l a n d s p e c i a l -
- s t a t u s s b i o l o g i c a l r e s o u r c e s .
1
However, I w a s n o t a b l e t o c o n f i r m
t he wi dt h of b u f f e r z o n e s f r o m t he
f i g u r e s , nor t o j udge whe t her t he
1 s t a t e m e n t a b o u t b u f f e r w i d t h a p p l i e s 16 -6
t o t h e d e l i n e a t e d w e t l a n d s t o o ( a s
w e l l as t h e t r i b u t a r i e s ) . The
1 t r a n s i t i o n a l h a b i t a t s a l o n g we t 1 ands
a s s o c i a t e d w i t h d r a i n a g e wa y s a r e
o f t e n i m p o r t a n t a r e a s in w i l d l i f e
movement and s uppor t a si gni f i cant
p r o p o r t i on of r e g i o n a I bi o d i v e r s i t y,
1 h e n c e , p r o t e c t i o n of b u f f e r zones i s
i m p o r t a n t f r o m a v a r i e t y of p o l i c y
s t a n d p o i n t s . N e v e r t h e l e s s , in my
1 p e r s o n a l o p i n i on, t r a i 1 d e v e l o p me n t
w i t h i n t h e o u t e r p o r t i o n of b u f f e r
zones can probabl y be i mpl eme nt e d
' w i t h o u t r e s u l t i n g in s i g n i f i c a n t
i m p a c t s . W e e d c o n t r o l ( s e e b e t o w)
a n d h a b i t a t e n h a n c e m e n t a r e a l s o
1 a p p r o p r i a t e a c t i v i t i e s w i t h i n b u f f e r
z ones .
1 T h e p r o v i s i o n of a l a r g e p r o p o r t i o n
of o p e n space w i t h i n t h e p r o f e c t
des i gn is I audabl e, a1 though, f or 16 -7
1 p u b t i c i n f o r m a t i on p u r p o s e s ,
d e v e l o p e d o p e n space ( a l l g o l f a r e a s
that a r e c o n v e r t e d f r o m t h e
1 o r i g i n a l l y o c c u r r i n g v e g e t a t i o n )
1 5
1
s h o u l d be d i s t i n g u i s h e d f r o m n a t u r a l
o r h a b i t a t o p e n s p a c e . I t is u n c l e a r
w h e t h e r t h e o p e n s p a c e a r e a s w e r e
p l a n n e d e c o l o g i c a l l y , f or example,
to p r e s e r v - e t h e f u l l r a n g e of' mi nor
s u b t y p e s of f o r e s t a n d mi x e d
h a b i t a t , or to p r e s e r v e c o n t i g u o u s
e x a m p l e s o f h a b i t a t s that pr ovi de
t h e r a n g e of e c o l o g i c a l nee d s of
g e n e r a l or s p e c i a l - s t a t u s w i l d l i f e
s peci es. For one exampl e, Lewi s' s
w o o d p e c k e r s p r e f e r snags in or
a d j a c e n t to r e l a t i v e l y o p e n p a t c h e s
w i t h i n t h e f o r e s t . W o u l d t h i s
c o m b i n a t i on of f e a t u r e s be
p r e s e r v e d ? O n e i m a g i n e s t h a t s u c h
consi der at i on would be part of t he
A I n a t u r a l r e s o u r c e m a n a g e m e n t
s t r a t e g y , b u t t h e p u b l i c d o e s n o t
know, the EIR does not s a y, and the
p r e c e d e n t of AI p l a n n i n g f o r t h e Old
G r e e n w o o d pr o f e c t does not y e t
p r o v i d e to t h e i n t e r e s t e d p u b l i c any 1
b a s i s f o r u n d e r s t a n d i n g t h e
e f f e c t i v e n e s s of t h e c e r t i f i c a t i o n
p r o g r a m , w h i c h is r e f e r r e d to by t h e 1
E I R as a c o n t r i b u t i o n t o t h e
m i t i g a t i o n of v a r i o u s b i o l o g i c a l
✓ e s o u r c e i m p a c t s.
The DEIR is deficient in not
d i s c u s s i n g t h e p o t e n t i a l f o r s p r e a d
o f n o x i o u s w e e d s as a c o n s e q u e n c e of
c o n s t r u c t i o n a n d e q u e s t r i a n t r a i l
u s e ( i f t h e r e w i l l be a n y ) . I n t h e
c o u r s e of f i e l d w o r k in t h e T r u c k e e
✓ e g i o n in t h e past s e v e r a l y e a r s , 1 '
h a v e i n c r e a s i n g l y been f i n d i n g s p o t
o c c u r r e n c e s of s p e c i f i c n o x i o u s 16 -8
w e e d s ( a c c o r d i n g t o d i c t i o n a r y
d e f i n i t i o n , r e g a r d l e s s of w h e t h e r . .
they appear on state or federal weed
l i s t s ) , s u c h as s p o t t e d k n a p w e e d and
t a l l wh i t e t o p . T h e s e s p e c i e s c o u l d
h a v e d e v a s t a t i n g e c o l o g i c a l a n d
e c o n o m i c c o n s e q u e n c e s i f they become J
6 1
•
1•
1 r a mpant , and provi si ons shoul d be
incorporated c o r p o r a t e d i n the e S p e c i f i c Plan
a n
1
a n d E I R t o a d d r e s s t h i s i s s u e .
Visual
I c o m m e n d t he a p p l i cant and t h e D E I R
f o r a d d r e s s i n g t h e i s s u e of
1 v i s i b i l i t y of t h e n i g h t s k y a n d f o r
c o m m i t t i n g to a d h e r e n c e to t h e 16 -9
d e s i g n s t a n d a r d s of t h e
1 I n t e r n a t i o n a l Dark S k y As s o c i at i on.
T h e o u t s t a n d i ng n i g h t s k y t hat we
enj o y i s o n e o f the most p r e c i o u s
1 a n d i r r e p l a c e a b l e r e s o u r c e s in t h e
T r u c k e e r e g i on.
1 I t h a n k t h e - T o w n f o r t h e o p p o r t u n i t y
t o c o m m e n t a n d wo u l d be happy t o
p r o v i d e a d d i t i o n a l i n p u t on any of
t h e i s s u e s r a i s e d above.
S i n c e r e l y ,
1 Ad r i an M. J u n c o s a
1
1
1
1
1
1
1
1
1
2.0 RESPONSE TO COMMENTS
1
LETTER 16 ADRIAN JUNCOSA, AREA RESIDENT
1
Response to Comment 16 -1
1 This comment describes the commentor's position as an ecologist working with East
West Partners and generally compliments the project. Since this comment does not
' address the adequacy of the Draft EIR, no further response is required.
Response to Comment 16 -2 •
The commentor doubts that goals and policies of the Town's General Plan relating to
trails are being met with the project.
See the Master Response 2.4.5 General Plan Consistency and Responses to Comments
14 -1, 14 -4, 14 -5, and 20 -6. With respect to issues not specifically addressed in these
1 responses, the Draft EIR discusses the project's consistency with the General Plan's goals
and policies relating to trails on pages 4.1 -31 to 32. MM 4.1.5 requires the applicant to
modify the project's proposed trails system to ensure that it is in conformance with the
' intent of the General Plan's policies relating to trails (see PC -2 Policies 12 and 13 in the
Draft EIR on page 4.1 -20) and the Trails and Bikeways Master Plan. As described in this
measure, whether the project is consistent with the General Plan is ultimately a
1 determination left to the Town Council. Creating performance standards to assist the
Town Council in making determinations of consistency with the goals and policies of the
General Plan is not feasible nor is it required in an EIR. An FIR serves as an informational
1 document and the "evaluation of the environmental effects of a proposed project
need not be exhaustive, but the sufficiency of an EIR is to be reviewed in the light of
what is reasonably feasible" (CEQA Guidelines, §§ 15121, 15151).
Response to Comment 16 -3
This comment raises issues regarding MM 4.4.4a and questions whether it is feasible to
•
provide full off -site mitigation of wood burning devices. MM 4.4.4a sets forth two
options to mitigate emissions of wintertime PMio attributable to wood burning devices.
' This measure states that "Conditions of Approval and CC &R's for the project shall forbid
the installation or use of wood burning devices within any portion of the project. MM
4.4.4a, would, however, allow a single wood- burning device in the event that an equal
reduction has been achieved elsewhere in the basin" (Draft EIR, p. 4.4 -16 to 17). MM
1 4.4.4a would, therefore, preclude the use of wood burning devices under either option
absent the applicant's ability to reduce wood burning emissions created elsewhere in
' the air basin to off set new emissions from the project. Pursuant to MM 4.4.4a the
applicant would coordinate efforts to obtain off -site mitigation with the Town of Truckee
and the Northern Sierra Air Quality Management District. Through this coordination and
' the requirement that each residential unit and occupied commercial building not emit
more than 7.5 grams per hour of particulate matter, this impact would be reduced to a
less than significant level under the second scenario presented by MM 4.4.4a (Draft EIR
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Town of Truckee Final Environmental Impact Report
1 September 2003 2 -129 Gray's Crossing Specific Plan Project
•
2.0 RESPONSE TO COMMENTS
page 4.4 -16 to 17). The coordination of the alternative provided by MM 4.4.4a is
required prior to tentative map approval.
Response to Comments 16 -4 1
This commentor questions why specific computer programs are required in MM 4.6.7 to '
calculate flows, size culverts, size ditches, and design detention ponds. MM 4.6.7 states
that the "applicant shall utilize the Haestad methods 'Culvert Master' and 'Flow Master'
• programs to calculate flows, size culverts, and size ditches. Detention ponds shall be
designed utilizing the hydrology program included in 'Land Development Desktop' by
Autodeska 0" (Draft EIR page 4.6 -28). Although the Town's Engineering Department
and Lahontan RWQCB require this type of analysis to calculate flows, size culverts, size
ditches and design detention ponds, use of these specific programs is not required. The
use of these programs represents one way to determine design requirements, and was
provided by the applicant. There are, however, several accepted methods and
programs that could be used equally effectively. This language requiring the use of
specific programs will, therefore, be deleted from MM 4.6.7.,
MM 4.6.7, found on page 4.6 -28 of the Draft EIR is revised as follows: 1
MM 4.6.7 The applicant shall develop a Master Drainage Plan in accordance '
with the requirements of Section 18.30.050 of the Town of Truckee
Development Code and the Truckee Public Improvement and
Engineering Standards (except as modified by this mitigation '
measure), which demonstrates how the proposed drainage
improvements shall accommodate the additional runoff and limit
the cumulative effects of runoff from development areas. The Plan
shall contain an estimate of the amount of surface runoff that will
be generated by the proposed development. The applicant shall
utilize the Haestad methods "Culvert Master" and "Flow Master"
programs —te calculate flows, size culverts, and size ditches
consistent with surface runoff estimations. Detention ponds shall be • designed - 'es - - - - - " - -
e - - --.._. •- - - - ^ .. - - -- -• ._•
shall be sized using the SCS TR 20 method along with tho Typo 1A
tabular hydrograph rainfall distribution. Tho SCS method will be
basins shall be and sized to a 20 -year, one -hour storm event prior to
implementation of proposed construction activities. The applicant
shall ensure that existing drainage systems are utilized to their fullest
extent possible when designing stormwater drainage systems. The
plan shall be consistent with standards and guidelines established
•
by the Lahontan Regional Water Quality Control Board (RWQCB )
and CalTrans. Both the Lahontan RWQCB and Caltrans shall be
given an opportunity to review the final design and make a
determination of the effectiveness of the proposed drainage
facilities. If the facilities do not meet Lahontan RWQCB or CalTrans
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Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -130 September2003
•
1 2.0 RESPONSE TO COMMENTS
1 requirements, they may require changes and re- submittal of the
drainage documentation.
1 .
This comment also generally questions the adequacy of the Draft EIR's discussion of
hydrology and water quality. No specific deficiencies are mentioned in this comment.
I The Draft EIR provides a detailed analysis of hydrology and water quality in Section 4.6.
Since this comment does not raise any specific issues regarding the adequacy of the
Draft EIR, no further response is required. See also Master Response 2.4.3 Water Quality.
' Response to Comment 16 -5
I The commentor questions the level of analysis provided in the Draft EIR regarding
biological resources. See Master Response 2.4.4 Biological Resources. Additionally, this
comment asserts that the Draft EIR is inaccurate with respect to species present in the
I project area and regarding characterization of habitat types. This comment specifically
questions whether nesting Lewis' Woodpeckers would be affected by development of
the project. The Draft EIR acknowledges that numerous protected bird species,
' including the Lewis' woodpecker, may utilize habitats within the project site for nesting,
in particular the mixed pine forest (Draft EIR page 4.7 -26). To mitigate this potentially
significant impact, MM 4.7.5 requires a focused annual survey for raptors and other
' listed special- status species be conducted within 30 days prior to the beginning of
construction or grading activity by a qualified biologist in order to identify active nests
onsite. If an active nest is found during the survey, or at any time during construction,
I no construction activities can occur within 500 feet of the nest until the young have
fledged from the nest and the nest is determined by a qualified biologist to be inactive.
Trees containing nests, or burrows that must be removed as a result of project
I implementation will be removed during late September to March, the non - breeding
season (Draft EIR page 4.7 -27). Also, while development of the project would result in
the removal of 187.4 acres of wooded area, consisting primarily of mixed pine forest, it
' would also preserve large areas of this habitat as open space. This commentor's
suggestions regarding the creation of artificial cavities and new snags that could be
used for nesting sites are noted and will be forwarded to the Town Council for
1 consideration. In addition, the Draft NRMP and Ecological Design (attached as •
Appendix A) will provide guidelines to enhance habitat for species of concern.
I . This comment also questions why there is no discussion of the California Natural Diversity
Data Base (CNDDB) occurrence of the Sierra Nevada Red Fox within or adjacent to the
project. site. The EIR states that Sierra Nevada Red Fox habitat exists onsite, but notes
I that this species is extremely rare. As discussed in the EIR, evidence of the Sierrd
Nevada Red Fox was.not found during field reconnaissance of the project site and this
• fox has not been observed in this area since the 1950s (Draft EIR page 4.7 -7, 10). The
111 Sierra Nevada Red Fox CNDDB occurrence is discussed on pages'4.7 -9 to 4.7 -10 in the
Draft EIR.
I This comment also generally criticizes habitat classifications and the Draft EIR's
discussion of vegetation present on the project site. To the extent that this comment is
not addressed in the Master Response 2.4.4 Biological Resources, habitat classifications
I and vegetation present on the site are typical for this area. Similar habitat and
Town of Truckee Final Environmental Impact Report
' September 2003 2 -131 Gray's Crossing Specific Plan Project
2.O RESPONSE TO COMMENTS
vegetation were documented during environmental review for the Old Greenwood
Project and Marfis Valley Community Plan (see e.g., Mortis Valley Community Plan Draft
EIR pages 4.9 -1 to 2 and Figures 4.9 -1, 2; Old Greenwood Draft EIR pages 4.7 -1, 4.7 -4 to
5).
Additionally, this comment expresses concern over the fact that the Draft EIR '
references documents that contain more detailed analysis than found in the FIR itself.
The fact that there may be more detail in documents referenced in the EIR, including
treatises on specific plants and animals, is to be expected. An EIR serves as an
informational document and the "evaluation of the environmental effects of a
proposed project need not be exhaustive, but the sufficiency of an EIR is to be
reviewed in the light of what is reasonably feasible" (CEQA Guidelines, §§ 15121, 15151). 1
Response to Comment 16 -6
The commentor is unsure of the adequacy of the buffer zones for tributaries, and if they 1
apply to delineated wetlands as well.
See Master Response 2.4.4 Biological Resources and Response to Comment 10 -25. 1
Since this comment does not otherwise address the adequacy of the Draft EIR, no
further response is required. 1
Response to Comment 16 -7
See the Master Responses 2.4.4 Biological Resources, and 2.4.5 General Plan '
Consistency, and Response to Comment 16 -5.
Response to Comment 16 -8
The commentor is concerned about the potential introduction and spread of noxious '
weeds due to construction activity and /or equestrian use of the project site. First, the
site is not intended to be used by equestrians. Further, an entire chapter of the Gray's
Crossing Specific Plan is dedicated to a Landscape Design Program (Chapter V). The 1
Landscape Design Program provides basic guidelines for design, selection and
implementation of landscaping, as well as provides specific design treatments for each
proposed land use within the project area, including the Village Center area, '
recreational areas (including the golf course), residential areas, and areas dedicated
as open space. A key component of the Landscape Program is a plant palette, which
was developed utilizing the following criteria: 1) adaptive to local climate and soil, 2) '
water conservation, 3) drought adaptation, 4) reduced maintenance, and 5)
reintroduction of native plant materials. Native and drought tolerant /water conserving
plant materials will be utilized in most cases. If non- native plant material is used, it is to
• be selected for its visual and cultural compatibility with the existing environment. The
guidelines in the Landscape Design Program, as well as the recommended plant
palette matrix will serve to guide the intensity and type of species to be planted in all
areas of the proposed development. 1
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Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -132 September 2003
2.0 RESPONSE TO COMMENTS
According to the guidelines, with regard to site disturbance for the golf course, the
landscape concept is to fine grade each of the fairways leaving as many trees and
I other natural vegetation as possible. Other than the turfed area of the golf course, the
only areas to receive landscaping would be those disturbed by grading and not
planted to turf. The improved rough areas, which will see an increase in human traffic,
will consist of native vegetation, such as grasses and wildflowers. All other areas would
remain in their natural state. Similar themes of non - disturbance and use of native
species hold true for the other land use areas. The Village Center and Residential zones
' provide some leeway in the use of non - native species in an effort to enhance views,
provide color and focus, and highlight corridors, etc. Guidelines for single - family
residential areas call for planting of native and adaptive species with some allowances
for limited areas of turf or ornamental planting. As building plans for new homes are
submitted, which will include landscaping plans, they will have to go through a review
process including the Town's. Planning Department and a Homeowner's Association
1 Design Review Board.
Based on the above information, one can conclude that all project areas will either
' remain in their natural state or be subject to the Landscape Design Program. While
there is always a minor possibility for the introduction of exotic or noxious plant species
on -site during the construction phase of the project, the impact is not considered
' "potentially significant" in light of the fact that project areas will either not be disturbed
at all, or if they are disturbed, they will be subject to comprehensive landscaping
guidelines requiring replanting with native and /or drought tolerant species. The
Landscape Program also requires the applicant to provide for long -term landscaping
maintenance of public areas.
1 Response to Comment 16 -9
The commentor commends the project for satisfactorily addressing issues related to
1 light and glare, in particular the commitment to design standards recommended by
the International Dark Sky Association. This comment is noted and presented here for
the consideration of the Town Council.
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Town of Truckee Final Environmental Impact Report
.September 2003 2 -133 Gray's Crossing Specific Plan Project
1 RTHERN SIERRA AIR QUALITY MANAGEMENT DISTRICT • Gretchen Bennitt, APCO
'STRICT HEADQUARTERS TRUCKEE FIELD OFFICE QUINCY FIELD OFFICE
)0 Litton Drive, Suite 320 13450 Donner Pass Rd., Ste. B, Truckee, CA 96161 264 Hospital Rd.
Box 2509 P.O. Box 9766, Truckee, CA 96162 P.O. Box 3981, Quincy, CA 95971
Valley, CA 95945 (530) 550 -7872 / FAX: (530) 587 -2623 (530) 283 -4654 / FAX: (530) 283 -0699
274 -9360 / FAX: (530) 274 -7546 email: airquality@ncen.net email: nsagmd®psln.com
.agmd®nccn.net or www.neen.net/— nsagmd
1 LETTER 17
August 1, 2003 i , e 4 2 to?
' Town of Truckee
Truckee Community Development Dept. .
' Attn: Heidi Scoble, Associate Planner
10183 Truckee Airport Road
Truckee, California 96161 •
'
Re: Draft Environmental Impact Report for Gray's Crossing Specific Plan/Tentative Map
' Dear Heidi Scoble:
I The Northern Sierra Air Quality Management District (District) has reviewed the notice for the
referenced project and would like to submit the following commenting agency comments for the
official record. •
I . -
The District is pleased to see mitigation measures incorporated into the project to reduce 7 -1
emissions below level C during construction and once completed.
1 The District would like to make one correction on page 4.4 -4, first paragraph under Ambient Air - 7 _ 2
Quality. It was stated, "...PM1O was monitored prior to 2001." From July 2000 through May .
' 2002, the District did not operate the High Volume PM10 sampler. However, PM10 was
continuously monitored via our TEOM monitor, also located at the Truckee -Fire Station.
' Mitigation Measure 4.4.5 under Gasoline Vapor Emissions must be revised. Any Fueling station
must be approved and permitted by the District. The District must be notified before the 17-3
construction of the fueling station commences. The District will calculate risk assessment based
1
on throughput and proximity to receptors. The District should be added to section 3.7:
Regulatory Requirements, Permits, and Approvals if the fueling station is to be constructed.
' Thank you for the opportunity to comment on the Draft EIR. Please add the District to your
distribution list for copies of the administrative final EIR: Please feel free to call Ryan Murano at
(530) 550 -7872 if you have any questions or comments.
I Sincerely, -
1 r tchen •.:en i t
`r� ollution Control Officer
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SERVING THE COUNTIES OF NEVADA. PLUMAS AND SIERRA 1
2.0 RESPONSE TO COMMENTS
1
LETTER 17 GRETCHEN G. BENNITT, NORTHERN SIERRA AIR QUALITY MANAGEMENT DISTRICT
1
' Response to Comment 17 -1
The commentor notes that the District is pleased to see mitigation measures applied to
' the project regarding air quality. The comment is noted and presented here for the
consideration of the Town Council.
' Response to Comment 17 -2
The commentor requests a correction to information regarding air quality monitoring by
the District.
The first paragraph on page 4.4 -4 is amended to read:
1 The Northern Sierra Air Quality Management District (NSAQMD) maintains
ambient air quality monitoring stations in the Truckee area. Ozone and PM2.s are
currently monitored at the Truckee -Fire Station site and PMio
1 4o -2001 was continually monitored between July 2000 and May 2002 via a TEOM
monitor, also located at the Truckee Fire station. PMio was also monitored in the
Glenshire subdivision prior to 2001. In the five -year period between 1997 and
2001, no exceedance of national or state standards for ozone were recorded
(CARB, 2003).
Response to Comment 17 -3
The commentor notes that any fueling station must be approved and permitted by the
District. The comment is noted and included here for the consideration of the Town
Council.
•
In addition, MM 4.4.5 on page 4.4 -18 of the Draft EIR is amended'to read:
Mitigation Measure
1 MM4.4.5 • e es , see - - - e -O -- -
•
guidelines and risk acceptability criteria of the NSAQMD at tho
Prior to construction of the service station, the project applicant shall
obtain a permit from the NSAQMD. Prior to commencing
1 construction of the fueling station, the NSAQMD will calculate risk
assessment based on throughput and proximity to receptors. The
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -134 September 2003
2.0 RESPONSE TO COMMENTS
applicant shall provide documentation of the permit to the Town of
Truckee.
Timing /Implementation: Prior to construction of the service station.
Enforcement /Monitoring: Town of Truckee Development
Department /Building Division /NSAQMD.
In addition, the last bullet point on the bulleted list found on page 3 -48 of the Draft EIR is
amended to read:
• The project may require service agreements or permits with utilities providers,
including the Truckee Donner Public Utility District, Truckee Sanitary District, Tahoe
Truckee Sanitation Agency, Truckee Fire Protection District, Northern Sierra Air
Quality Management District, and Nevada County Department of Environmental
Health.
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Town of Truckee Final Environmental Impact Report
September 2003 2 -135 Gray's Crossing Specific Plan Project
' _ \Iti� LETTER 18
o
M f r t'T E ���..
' August 8, 2003
Town of Truckee
Community Development Department
1 Attn.: Heidi Scoble
Assistant Planner
10183 Truckee Airport Road
' Truckee, CA 96161
' Re: Gray's Crossing EIR Comments
Dear Heidi:
We are pleased to offer the following comments on the Gray's Crossing Environmental Impact
Report.
2.0 EXECUTIVE SUMMARY
2.5 Summary of Environmental Impacts
' Table 2 -1, Summary of Impacts and Mitigation Measures
4.1 Land Use
Impact 4.1.4; MM 4.1.4
The Gray's Crossing project has been designed consistent with the direction of the Truckee
General Plan. The General Plan anticipates and the project is designed as a destination
residential community with various recreational amenities. A variety of technical analyses and
surveys reveal that golf, particularly membership golf, is an integral part of a resort experience.
One need only look at various resort areas (i.e., Bend, Oregon; Steamboat Springs, Colorado;
Squaw Valley, California; Sun Valley, Utah; Whitefish, Montana; and other like resort areas) to
realize that membership golf is a desired and needed resort amenity. Membership golf expands,
' rather than contracts, a resort market appeal. The Gray's Crossing project is linked with the 18-1
Tahoe Mountain Club, a recreational umbrella that offers a variety of recreational amenities,
which provides a full destination resort experience. These amenities include public golf,
' semi- public golf, membership golf, skiing, hiking and an array of other activities. When viewed
within the context of the Tahoe Mountain Club, the membership golf option is only one
component of the overall plan. Property owners and users of Gray's Crossing will have access to
1 different levels of Tahoe Mountain Club amenities. Requiring mitigation that mandates specific
P. 0. Box 2537, Truckee, CA 96160 • 10164 Donner Pass Road, Suite 3, Truckee, CA 96161
T (530) 587 -2222 / F (530) 587 -2228
Town of Truckee •
Re: Gray's Crossing EIR Comments
August 8, 2003
Page 2
hours of public play undermines the economic viability of the project and eliminates the variety
of resort opportunities. In addition, membership courses usually generate less play than public
1
facilities, thereby resulting in less environmental impact. We respectfully request this mitigation
measure be•eliminated, as it does not result in mitigating a direct or indirect environmental
impact associated with development of this project.
1
4.2 Transportation and Circulation
Impact 4.2.1; MM 4.2.1 1
The project's fair -share contribution to regional impacts should be viewed in context with the
fair -share contribution of other projects in the area. Therefore, if it is found that there are
potential impacts to the intersections identified, the Town should incorporate these project •
improvements into their development fee program and apply mitigation measures equitably 18 -1
across the board to all future development projects. Singling out the Gray's Crossing project for
mitigation fees without having a comprehensive plan puts an increased burden on the project that
is not equitably distributed to other development. Therefore, we suggest this mitigation measure
. be re- written to require Gray's Crossing to pay development fees if the Development Fee
program is amended to recognize the improvements identified in this mitigation measure. •
Impact 4.2.7; MM 4.2.7 • 1
18 -3
This mitigation measure should be clarified to read that the $1,926,821 payment of impact fees
will be incrementally applied to the phases of development when building permits are issued.
4.7 Biological Resources
Impact 4.7.2; MM 4.7.2
This mitigation should be modified to reflect that the applicant shall pursue Audubon
International Sustainable Development at the Gold Seal level or equivalent. We do not disagree •
with the intent of the mitigation measure, but we have concerns about conditioning the project to
a private organization over which we have no control. Issues such as future changes, funding, 18-1
obligations or business practices may affect the intent of the regulations as we understand them
today. The basic concept as set forth under Audubon International Sustainable Development has
been applied to the project design. Modifying this mitigation to provide the language of
"equivalent" would solve the potential problem.
Impact 4.7.8; MM 4.7.8b, MM 4.7.8c and MM 4.7.8d
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These mitigation measures should be clarified to reflect permits applicable "if required" by these 18-5
agencies.
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C:ID000MENTS AND SETTINGS\RMCCONN.TMCLLOCAL SEITINGSTEMPORARY INTERNET FILES IOLK29\EOCCOMMENTSOI.DOC
'' Town of Truckee
Re: Gray's Crossing EIR Comments
August 8, 2003
Page 3
1
Impact 4.9.2; MM 4.9.2a
We believe the 300 -foot setback is not applicable to the SR267 bypass. The Town has not taken
official action to establish a 300 foot setback in the area that has been altered as a result of the 18.6
SR267 bypass. The General Plan Policies regarding protection of the view shed should be the
guiding factors here. This project has complied with the General Plan Policies by designing •
development so that it is not highly visible from SR267, SR89 and 1-80. The project has
' complied with 300 foot setbacks in the area north of Prosser Dam Road and Alder Drive.
' 6.0 Alternatives To The Project •
6.3 Project Alternatives Discussion / Analysis
' Alternative 2 — Reduced Development
•
We believe Alternative 2 - Reduced Development as referenced in Section 6.2 is not viable. This
alternative suggests that the golf course be redesigned to a 9 -hole facility, that the residential
development be clustered to the south of Prosser Dam Road, and that the commercial area be
reduced. This alternative is not viable for the following reasons:
1 1. Truckee's General Plan designates this land as Planned Community 2 (PC -2). It offers •
•
specific development criteria in the General Plan Goals and Policies. PC -2 was an integral
part of Truckee's General Plan. The Gray's Crossing project complies with the General
Plan Policies. The property was purchased under the expectations, as outlined in the
General Plan. Requiring reduced density would significantly alter the economic value of
' the property, as well as significantly reduce the development expectation.
2. Reducing the proposed 18 -hole golf course to nine (9) holes for the purposes of making a
' lesser project is simply not economically viable. Economic Research & Associates (ERA)
has outlined a variety of reasons that demonstrate the vulnerabilities and economic 18
disadvantages of a 9 -hole course. Those comments are found in the August 6
' memorandum attached and hereby incorporated by reference.
3. The project description compared to the PC -2 policies in the General Plan demonstrates
' that the project has already been reduced in size from the land use allocations provided for
in the General Plan. These reductions, particularly the commercial reductions, have been
the result of detailed market and economic feasibility studies. Further reduction would
seriously undermine the economic viability of the project.
4. Clustering lots south of Prosser Dam Road. The unique characteristics of the Gray's
Crossing project are that the land plan site has been designed to fit the existing terrain.
Thus, significant alteration of existing land features has been avoided. The project has
incorporated the clustering criteria as outlined in Truckee's Development Code.
C:\DOCUMENTS AND SETTINGS\RMCCONN.TMC\LOCAL SETTINGS \TEMPORARY INTERNET FILES \OLK29\EIRCOMMENTS01 DOC
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• Re: Gray's Crossing EIR Comments
August 8, 2003
Page 4
1
Development has been designed to avoid resources, such as drainage swales, scenic vistas,
and existing utility easements. ' In doing so, the primary resource features on the site have
been maintained and will continue to be maintained as shown by the various visual and
aerial exhibits contained in the Specific Plan. Redirecting the development to be clustered
in the south portion of the site would result in a mass grading of the site, therefore 1
depleting all resources in this area. In addition, the restructured lot sizes would not be
consistent with market demand and would result in a product unable to compete in the
existing market place. 1
Considering the components outlined above, Alternative 2 - Reduced Development 1
recommendation seriously impacts the economic viability of the project and significantly
compromises the fiscal integrity of the project.
Sincerely, 1
EAST WEST PARTNERS
Rick McConn
Project Manager
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1 Memo on Niue Hole Courses
1
1 E con omics'Research Associates
1 MEMORANDUM
To: Rick McConn, East West Partners
From: Greg Cory
Subject: Comments on 9 hole course viability
i
Date: August 6, 2003
1
CC: Nadine Fogarty
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To further elaborate on the vulnerabilities of nine -hole facilities, there are several reasons not to
build them in conjunction with a real estate oriented development.
1 1. Nine -hole facilities operate best in urban locations as teaching facilities and impromptu play
experiences. They need a high density, permanent surrounding population, good exposure to
the market, and a long play season.
2. Because of the play experience they offer they tend to be very price sensitive, yet the cost of
construction per hole is not significantly different than a full- length course. Thus, they need
to generate a great deal of rounds at reasonable fees in order to recover operating costs, let
alone debt.
' 3. Nine -hole facilities have operating inefficiencies relative to 18 hole courses. They still
require the core management and operating staff that a full length facility requires, they still
need a maintenance barn and related equipment, and they still require some form of
' clubhouse. The only operating savings relative to a full - length facility is in relatively
inexpensive maintenance labor. Thus, there are core costs that are disproportionately higher
relative to the fee structure that can be supported. When complicated by a short play season
(as would be the case at. Gray's Crossing elevation), it is our opinion that such a course
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Memo on Nine Hole Courses
would be very difficult to make viable given current construction costs, operating budgets, '
and fair allocation for land value.
4. A significant issue for Gray's Crossing, as it would be for any of the other communities East
West Partners is planning in the Tahoe market, is the impact on real estate values. There is
no evidence that we have found nationally where a nine -hole golf course creates any
significant real estate premiums. Given the cost of development of a course in an alpine R.
setting, it is critical to extract as much value as possible in order to recapture the
development risk. As illustrated in the 2001 book published by the Urban Land Institute,
Developing Golf Courses in Residential Communities, real estate inside a golf course
community (with full length courses) commands between a 10 and 50 percent premium over
similar property without a golf course. Depending on the orientation of particular lots, this
premium can exceed 200 percent. These premiums, and ergo taxable values, would not be
achieved with a nine hole facility.
5. Finally, a nine -hole. golf course does not contribute to a destination resort experience. The
consumer, when choosing a location for a vacation (or second home purchase), carefully
evaluates the extent and variety of recreational attributes offered by competing' destinations.
The knowledgeable consumer, if golf is a significant part of the decision making process,
will always choose a location with a full length, championship rated course over a destination
without equivalent facilities.
We hope this has been helpful. Should you need additional information, please do hesitate to
call.
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2.0 RESPONSE TO COMMENTS
1
LETTER 18 RICK MCCONN, EAST WEST PARTNERS
1
Response to Comment 18 -1
The commentor requests the elimination of MM 4.1.4, which requires specific hours of
public play on the golf course. This comment is provided here for the consideration of
' the Town Council.
Response to Comment 18 -2
The commentor states that the project's fair -share contribution to regional impacts
should be viewed in context with fair -share contribution of other projects in the area.
The commentor requests that the mitigation measure be re- written to require Gray's
Crossing to pay development fees if the Development Fee program is amended to
. recognize the improvements identified in this mitigation. This comment has been noted
and the Draft EIR has been changed accordingly - see Response to Comment 2 -3.
Response to Comment 18 -3
1 The commentor states that MM 4.2.7 should be clarified to read "the $1,926,821
payment of impact fees will be incrementally applied to all phases of development
when building permits are issued."
' This has been changed on page 4.2 -56 of the Draft EIR as follows:
Mitigation Measure
MM 4.2.7 As shown in Table 4.2 -19, a draft calculation of the Town of Truckee
' traffic mitigation fee estimates the project applicant will be
required to pay approximately $1,926,821 to the Town of Truckee in
the form of a Traffic Mitigation Fee prior to the completion of the
project. However, this fee is subject to change and shall be
collected prior to or in conjunction with the issuance of building
permits or the recordation of final subdivision maps. Therefore,
these fees will be incrementally applied to the phases of
development when building permits are issued.
' Timing /Implementation: Prior to or in conjunction with the
issuance of building permits or the recordation of final subdivision
maps.
' Enforcement /Monitoring: Town of Truckee Community
Development Department /Planning Division.
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Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -136 September 2003
2.0 RESPONSE TO COMMENTS
Response to Comment 18 -4 1
The commentor requests modification of MM 4.7.2 to state that the applicant shall
pursue the Audubon International Sustainable Development of the golf course at the
Gold Seal Level or the equivalent.
MM 4.7.2 on pages 4.7 -24 and 4.7 -25 of the Draft EIR is amended to read: 1
MM 4.7.2 The project applicant shall obtain the following two designations: 1)
Audubon International (Al) Approved Land Plan, and 2) the Gold
Seal of Sustainability, or the equivalent. Only after successful
completion of final Al audits will the golf course receive a Gold '
Signature designation. The applicant must successfully complete
and implement a Natural Resource Management Plan to Al
specifications, host site visits during the construction of the project,
and successfully pass an on -site environmental audit after the
project is completed. The Natural Resource Management Plan will
achieve natural resource sustainability through incorporation of
Integrated Pest Management, Best Management Practices, an
assessment of environmentally sensitive areas, and a monitoring
program for the golf course. The golf course must retain the Gold '
Seal designation through submission of annual reports,
documentation of environmental issues, hosting of annual audits by
Al scientist, and maintenance of annual membership dues.
• The project applicant shall provide annually to the Town proof of
certification of the project's golf course with the Gold Seal of
Sustainability, or the equivalent, designation.
Response to Comment 18 -5 1
The commentor requests modification to MMs 4.7.8b, 4.7.8c, and 4.7.8d to contain the
language "if required" with regard to receipt of permits. MM 4.7.8b requires the
applicant to submit its wetland delineation and map to the U.S. Army Corps for review
and verification. This is a requirement in light of the proximity of the proposed
development to waters of the U.S. MM 4.7.8b continues "(tlhe appropriate Section 404
CWA permit shall be acquired if impacts to waters of the U.S. cannot be avoided." In
other words additional permitting will be necessary "if required" - as the commentor
has requested. Therefore, no changes are necessary to MM 4.7.8b. In addition, as the
applicant anticipates constructing a series of bridge structures that span the two
intermittent drainages on site, these activities would require obtaining a water quality
certification /waiver from the Lahontan RWQCB and a Streambed Alteration
Agreement from CDFG.
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Town of Truckee Final Environmental Impact Report
September 2003 2 -137 Gray's Crossing Specific Plan Project
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2.O RESPONSE TO COMMENTS
Response to Comment 18 -6
The commentor does not believe the 300 -foot set back is applicable to the SR 267
Bypass area. See Master Response 2.4.5 General Plan Consistency and Response to
Comment 6 -17. This comment is provided here for the consideration of the Town
Council.
Response to Comment 18 -7
The commentor does not believe that Alternative 2 - Reduced Development is viable.
This comment is provided here for the consideration of the Town Council.
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Final Environmental impact Report Town of Truckee
1 Gray's Crossing Specific Plan Project 2 -138 September2003
LETTER 19
P.O. Box 1703
Truckee, CA 96160
1 (530) 587-4317
' The Town of Truckee
10183 Truckee Airport Road
Truckee, CA 96161
August 6, 2003
Dear Truckee Town Council Members,
The current town council has the overwhelming task of
approving, denying or altering the Gray's Crossing land use
1
plan and draft EIR. The citizens and future generations will
be forever affected by the council's decisions in this matter.
With the input of paid town staff, the five current council
members will make assessment for all of us.
Pressure to develop this piece of property as it is proposed
will come from the developer East West Partners and other
entities and individuals who will financially benefit from the 19 - j
approval of this project.
1 Careful persuasion of the community has occurred in
significant ways. Scholarships to local students and firework
displays have been provided to the community.
Neighborhood meetings have been held along with fancy
1 mailers sharing the intentions of East West Partners. The
developer has circumspectly communicated their intents
regarding the development of PC -2. Being a good neighbor
seems of great concern to East West Partners.
1 With development comes a profound cost to our
environment. The draft EIR states clearly on. page 4.7 -35 19 -2
under Cumulative Impact 4.7.11
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Implementation of the proposed project will result in
the loss of open space, removal of habitat for native
plants and wildlife, removal of forest resources, and
the fragmentation of existing movement corridors for
resident and migratory wildlife. .
Further discussion under this impact clearly states how .
devastating this will be to our environment. The EIR at the
end of this section makes reference to General Plan goals
and policies which when followed they believe will reduce the
negative impact to less than significant.
The EIR refers to Open Space Goal 1, Policy 2S. as
supporting documentation. Under Table 4:7 =2 on pages 4.7-
17 -20. Policy 2.3 is not included in the DEIR. The
document uses it as supporting evidence for the position it
upholds of less - than :significant - impact. The. DEIRis. - -.
incomplete. ._It_does:.not_. address ..the policy o.r any mitigation,
regarding this policy.
Conservation and Open Space Policy 2.3 states:
Work. with the U.S. - Forest. Service and California Department
of Forestry, to review timberland harvest and conversion
plans for compliance with the intent of the above goal. The
goal under the General Plan is:
Conservation and Open. Space Goal 1
Protect areas of - significant wildlife habitat, fisheries
and biological resources. Several policies carefully explain 19 -3 1
the meaning of this goal.
The DEIR under Impact 4.7.11 disputes this severe
environmental impact by stating no mitigation is needed
because the degradation of the land is less than
significant. The document continues to uphold that the
project has 417.6 acres of open space, which justify its
findings.
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1 Of the 417.6 acres of identified open space within the
project 193.1 acres occur in or around the developed golf
1 course. Four acres occur within the church site, 1.9 acres
are contained within the cottage development, 5.5 acres are
1 enclosed within the Tots included in Phase 1 on the west side
of Hwy 89N, 7.5 acres of open space are enclosed within the
Phase 3 & 4 developments and 10 acres are enclosed and
around various portions of the Phase 2 development.
' The above - mentioned open space equals to 222 acres that
cannot be considered wildlife movement corridors or habitat
1 for special status plant or animal species. This leaves 195.6
acres of open space where wildlife may possibly live and
exist in peace.
The entire Grays Crossing project consists of 757 acres. The
conservation of 195.6 acres of true undisturbed open space
is significantly less than the 290 acres envisioned by the
Town's General Plan. It is also worthy to note that the
1 195.6 acres of open space is not located in the probable
natural wildlife movement corridor of the Truckee- Loyalton
deer herd.
1 The DEIR determination of Tess than significant impact on
Impact 4.7.11 under Table 2 -1 is inaccurate. Mitigation
must be made to preserve a true deer migration /wildlife
movement corridor under General Plan
Conservation Open Space Policy 1.3. which states:
Provide for the integrity and continuity of wildlife
1 habitat, support the permanent protection and
restoration of sensitive wildlife habitat and wildlife
1 movement corridors through a variety tools, including
preservation in open space and the use of planning
fee waivers for projects that provide permanent
protection of such areas.
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Sensitive wildlife habitat includes the following: 1
Meadows, wetlands, and riparian corridors 1
Deer migration /wildlife movement corridors 1
Deer fawning areas 1
Habitat for State and Federally listed plant and animal
species 1
Large blocks of undeveloped forest
As a concerned citizen of this community for 26 years and 1
an advocate of protecting the natural environment that
exists in the Sierra Nevada Mountain Range, I ask that the
current Town Council insist that the proposed DEIR be
altered in a significant way which will allow for the natural
deer and wildlife movement corridors that exists on the PC -2
property. I ask that the Town Council uphold Conservation
Open Space Policy 1.3. by requiring the developer to
create honest mitigation regarding the above stated 1
Cumulative Impact 4.7.11.
1
Sincerely,
t.s2 1
Jule Cooley - Rieders
Cc: Town of Truckee Planning Commissioners
California Department of Fish and Game
Northern Sierra Air Quality Management District
Mountain Area Preservation Foundation 1
United States Department Of Forestry
California Regional Water Quality Control Board 1
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2.0 RESPONSE TO COMMENTS
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LETTER 19 JULIE COOLEY - RIEDERS, AREA RESIDENT
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Response to Comment 19 -1
This comment describes the Council's role with respect to the project and generally
compliments East West Partners. Since this comment does not address the adequacy
of the Draft EIR, no further response is required.
Response to Comment 19 -2
The commentor states that this development profoundly affects the environment. See
Master Response 2.4.4 Biological Resources and Master Response 2.4.5 General Plan
1 Consistency.
Response to Comment 19 -3
The commentor believes that impacts to open space are significant, particularly with
regards to General Plan Conservation and Open Space Policy 2.3. See Master
Response 2.4.4 Biological Resources and Master Response 2.4.5 General Plan
Consistency.
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Town of Truckee Final Environmental Impact Report
September 2003 2 -139 Gray's Crossing Specific Plan Project
LETTER 20
Re:
Gray's Crossing — DEIR comments - .
• To : T ruckee C ity Planning Staff , Planning Commission, City Council
From: Miles Huber, 12053 Rainbow Drive, Prosser Lakeview, Truckee, CA
Date: August 7, 2003. .
Those of us with homes located on the south side of Rainbow Drive immediately adjacent to the Gray's
I Crossing project site are focused on the development impacts on the north end of the project. While I am
officially speaking for myself in this letter; I assure you that my comments are based on many
conversations with neighbors in the same situation. 20-1
I In general, I first should state that overall I have reviewed the Master and Specific Plans and feel that East
West has provided Truckee with a well thought out general plan and its staff should be commended. My
comments are geared for the maintenance of several concepts relating to the north edge of the development
I and concerns and suggestions to improve the trail system north of Prosser Dam Road (which causes
unintended safety and security impacts currently).
•
I North End Area Setbacks, Open Space, Design Standards, Timber Harvest Sr Circulation
- Maintain the total open space area and setbacks from Prosser Lakeview homes on the North end. In
20-2
general, the setbacks have been improved from previous plans. There still is one area of fairly high ` I
I impact at the northwest comer where 3 to 4 planned homes are within 225 feet of existing Prosser homes.
Consider transferring these homes to another section of the project.
I - Implement the design standard requirement that all Gray Crossing buildings use natural colors and l 20 -3
materials plus use minimal rear yard lighting on the north edge to reduce impact to Prosser Lakeview
homes. t
I - Timber Harvest - Protect wooded views and privacy for existing and new owners at Gray's Crossing, 20-4
by adding a clause that no discretionary additional thinning (beyond required fire standards and for trails)
of live trees (over say 4 inches) in the North open space area will be allowed.
N - Maintain the concept that vehicular traffic from Gray's Crossing should be I 20-5
discouraged on Rainbow Drive (i.e. no internal vehicular connection to Rainbow Drive.)
I North of Prosser Dam Road Trail Impacts, Safety and Improvements
- Improve the public trail system on the north of Prosser Darn Road and east of 89 to both
I loop internally and discourage crossing the dangerous highway 89 (currently two uncontrolled areas.
This can easily be achieved at little cost by:
I) Create a north/south earthen trail on the east side of 89 (can use existing dirt road trail to save costs)
I 2) Create an east /west earthen trail through the middle of the open space on the north end back to the
planned trail on the east side of the project (a partial road / cleared path exists - to save costs) 20-6
I • - Change Trail plan to discourage use of the existing power line easement road at the north property line.
This current element will occur without the above implementations. The current plans would encourage
this use on this easement as users would follow the fire access road at the end of the cul de sac north to
I the easement, then follow it east seeking a loop. This would force users onto an easement not meant as a
trail that has slopes of over 25% (not bike or cross country usable) at the east end. Immediate rear lot
line trails also encourage vandalism (here to homes on the south side Rainbow Drive.)
1 - Maintain the concept that all trails are open to the public and should connect to desirable trails
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2.0 RESPONSE TO COMMENTS
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LETTER 20 MILES HUBER, AREA RESIDENT
Response to Comment 20 -1
This comment describes the commentor's position as a neighbor to the project and
• generally compliments the project Specific Plan. Since this comment does not address
the adequacy of the Draft EIR, no further response is required.
Response to Comment 20 -2
This comment expresses some concern over the proximity to Prosser Lakeview to three
to four lots located in the northwest corner of Unit 4 of the project as depicted in Figure
3 -10 in the Draft EIR. This comment notes that these planned homes are within
approximately 225 feet of existing Prosser Lakeview homes. The Draft EIR acknowledges
that implementation of the proposed project may alter the views from existing
residences adjacent to the project site (Draft EIR, Impact 4.9.5). The EIR determined
that based on the steep topography and vegetation to be retained, land uses north of
the project site, including Prosser Lakeview, would not have views of the project (see
Draft EIR, Figure 4.9 -1, page 4.9 -19). Thus, this spacing, which does not account for the
additional buffering provided by required rear yard setbacks, causes no significant
aesthetic impacts to the adjacent Prosser Lakeview community. The project's Specific
Plan mandates rear yard setbacks of 20 feet for single - family residential units and
provides design guidelines and restrictions that address screening, design, setbacks and
each lot's natural constraints (Specific Plan, Figure 2 page 50). The commentor's .
concerns as to the adequacy of these provisions and the project's site design are noted
and are included for the Town Council's Consideration.
Response to Comment 20 -3
This comment suggests the project implement design standards using natural colors and
materials and requiring minimal rear yard lighting. The project's Specific Plan includes
site development standards, development guidelines, and landscape and lighting
programs that minimize potential visual impacts associated with project
' implementation (Draft EIR pages 4.9 -20 to 23). Design standards provide that lighting
levels should be compatible with neighborhood ambient light levels and encourage
the use of a "few well placed low intensity lights-' (Specific Plan page 104). The Specific
Plan's Design Guidelines also stress harmony with the natural environment and the use
r . of natural materials (see Specific Plan, Ch. VI and pages 104, 112). The EIR determined
that based on the steep topography and vegetation to be retained, land uses north of
1 the project site would not have views of the project (see Draft EIR, Figure 4.9 -1, page
4.9 -19).
Response to Comment 20 -4
This comment stresses the importance of protecting wooded areas for visual screening
and suggests that discretionary thinning of live trees be limited to fire safety and trail
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Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -140 September2003
2.0 RESPONSE TO COMMENTS
maintenance. The project protects wooded areas in a number of ways. As explained 1
in Section 3 of the Draft EIR, the Specific Plan Development Guidelines identify the use
of a building envelope for individual residential lots within which grading and
construction would occur. The building envelope is the portion of each lot within the
developable area, within which all improvements must be built and the only area within
which alterations to the existing landscape may occur (Draft EIR page 3 -31). The
Specific Plan also provides that existing trees and natural features should be
incorporated into site design (Specific Plan page 93). With respect to more stringent
requirements for thinning open space wooded areas, this comment's suggestion to
disallow discretionary thinning is noted and is included for the Town Council's
consideration.
Response to Comment 20 -5 1
This comment suggests that use of Rainbow Drive should be discouraged. This
comment is noted and is included for the Town Council's Consideration. The project's
traffic analysis, however, evaluated Rainbow Drive and no significant traffic impacts are
anticipated (see Draft EIR pages 4.2 -5, 9, 24, 46, 52 to 53, 76 to 77, and 88). Gray's
Crossing residents are not expected to access the site via Rainbow Drive as it provides
longer travel times than access via Prosser Dam Road. Further, the only direct access
from the project site to Rainbow Drive is an emergency access.
Response to Comment 20 -6
The commentor offers suggestions for improvements to the public trail system. The
proposed Specific Plan includes trails and bikeway facilities within the Specific Plan
area, and provides for future connections to offsite facilities as designated in the
General Plan's Open Space, Natural /Scenic Resources, and Trails Map and the
Downtown Truckee Specific Plan Pedestrian and Bicycle Circulation Map. The Specific
Plan includes no provisions that would restrict these facilities from public usage (Draft EIR
page 4.1 -20). This comment's additional suggestions regarding improvements to the
trails system are noted and are included for the Town Council's consideration.
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Town of Truckee Final Environmental Impact Report
September 2003 2 -141 Gray's Crossing Specific Plan Project s
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I LETTER 21
Dennis A Dickinson
II 10579 Rosa Court
Truckee, Ca 96161
e -mail echosdad @thegrid.net
I Phone (530) 587 -1420
Fax (530) 587 -3204
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August 08, 2003
1 Town of Truckee Community Development Department
Tony Lashbrook
10183 Truckee Airport Road 41,./e. 2003
1 Truckee, California 96161 RLC)C�
I Subject: Gray's Crossing EIR
Dear Tony,
' Please consider this letter to be a written response concerning Gray's Crossing EIR. I have
not reviewed this document. I am just going on what I heard at the Town of Truckee Council
I - Meeting on August 7th.
The Town of Truckee has experienced phenomenal growth rate over the past few years. In
I my humble opinion, the retail and commercial building growth has not kept pace with the
residential growth. A very large company is now going to build a 47,000 square foot complex in
Placer County. My question is very simple. Where will that tax base go?
I It is time that the Town of Truckee do something about this. The General Plan calls for retail
and commercial space at Gray's Crossing. East West Partners have scaled down considerably the 21 -1
1 amount called for by the Plan. I would like to know why this has happened?
This Town needs more retail outlets. There is absolutly no reason why the "People of
1 Truckee" should be leaving their tax dollars in another state because there is no place to shop.
Historic Downtown Trukee is a nice place to have for the tourist, but it does not meet the needs
I of the average person who lives here.
Frankly, Wall Mart and Home Depot are coming. Like it or not. Either the Town of Truckee .
I finds a home for these companies, or Placer County / Nevada County will. This Town will need
a tax base after build out. Now is the time to plan for that future. Gray's Crossing is a start.
Please reconsider the amount of retail and commercial space that this development should be
1 offering.
1 Sincerely,
CJLL --,./
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2.0 RESPONSE TO COMMENTS
1 LETTER 21 DENNIS A. DICKENSON, AREA RESIDENT
1
Response to Comment 21 -1
The commentor indicates that additional retail and commercial space should be
included as part of the project approval. The comment is noted and included here for
consideration of the Town Council.
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1 Final Environmental impact Report Town of Truckee
Gray's Crossing Specific Plan Project 2 -142 ' September2003
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3.O ERRATA TO THE DRAFT El R
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3.0 ERRATA TO THE DRAFT EIR
Listed below are the complete changes, additions, and deletions that have been
made to the text of the Draft EIR as a result of public and staff review. Changes to the
text are shown as additions and d'a l s.
1.0 INTRODUCTION
No changes were made to this section of the Draft EIR. •
1
2.0 EXECUTIVE SUMMARY
No changes were made to this section of the Draft EIR.
3.0 PROJECT DESCRIPTION
1 The last bullet point on the bulleted list found on page 3 -48 of the Draft EIR is amended
to read:
' • The project may require service agreements or permits with utilities providers,
including the Truckee Donner Public Utility District, Truckee Sanitary District, Tahoe
Truckee Sanitation Agency, Truckee Fire Protection District, Northern Sierra Air
Quality Management District, and Nevada County Department of Environmental
Health.
4.0 INTRODUCTION TO THE ENVIRONMENTAL IMPACT ANALYSIS
No changes were made to this section of the Draft EIR.
4.1 LAND USE
No changes were made to this section of the Draft EIR.
4.2 TRANSPORTATION AND CIRCULATION
' Page 4.2 -3 of the Draft EIR has been amended to read:
Pioneer Trail
This roadway begins at Donner Pass Road on the east and continues in a
westerly direction. It serves a mixture of residential, industrial and commercial
uses. At its intersection with Donner Pass Road, Pioneer Trail is controlled by a
Stop sign. This roadway is planned to be a part of the Third Tahoe- Donner
Town of Truckee Final Environmental Impact Report
September 2003 3 -1 Gray's Crossing Specific Plan Project
3.0 ERRATA TO THE DRAFT EIR
Connection if built and would provide the first segment of the connection of the
roadway to SR 89. The exact alignment of this connection has not been
determined.
•
Comstock Drive (Formerly Thayer Drive)
This roadway is currently under construction as a part of the Pineforest 1
Subdivision construction. It will connect Alder Drive to the north to Pioneer Trail to
the south west of SR 89. When completed, it will be controlled by a stop sign at
both its intersection with Alder Drive and Pioneer Trail.
Table 4.2 -14 on pages 4.2 -46 and 4.2 -47 of the Draft EIR is amended to read: 1
TABLE 4.2 -14
2005 No PROJECT AND PLUS PROJECT WEEKDAY ADT AND PEAK -HOUR PEAK - DIRECTION VOLUMES
F i ` - � u ` Place
- r Couniy/TOwn-
Er � Protect ' oUTruckee�
? +. ; -r_ :Generated = -..v. . ,' , . �. No Project ; `_.Generated 1, Plus Pr6ject . " ° TFieshold� __
`` Peak Peak `Peak Peak
6: r Hour Hour t Hour .. Hourf
F[ a S 3 A { Y t ' iY3. 9 C' A.
e �, s n , - Peak ' ,,Peak k xPeak ` Peak
s . r` Direction Direction Direction `- Directio
?Alit Volume. ;ADT..VolumeH ADT Volume:
SR 89 North 1 -80 to Donner Pass Road 6,754 644 320 5,403 236 12,157 882 556 NA 1,891
SR 89 - Donner Pass Road to Alder Drive 9,265 4 -025 590 4,504 228 13,769 1 -253 818 NA 1,891 f
SR 89 - Alder Drive to Rainbow Drive 5,947 42 405 493 22 6,440 64 NA 1,891 1 '
SR 89 - Rainbow Drive to Alder Creek Road 4,628 32290 245 12 4,873 44 302 NA 1,891 1
R 267 - 1 -80 to Brockway Road 12,585 305 775 1,644 82 14,229 387 857 NA 1,891
SR 267 - Brockway Road to Airport Road /Schaffer Mill Road 13,776 251 1 025 1,161 58 14,937 309 1 083 25,000 NA
SR 267 - Airport Road /Schaffer Mill Road to Northstar Drive 12,538 4-94 765 840 41 13,378 237 806 25,000 NA
. SR 267 - Northstar Drive to Brockway Summit 8,976 152 680 647 31 9,623 483 71 t 16,200 NA
Bridge Street - Donner Pass Road to West River Street 10,413 76 605 399 21 10,812 97 626 NA 1,891 1
Brockway Road Immediately South of West River Sheet 8,749 54 515 278 15 9,027 69 530 NA 1,891
Brockway Road Immediately West of SR 267 8,234 34 480 482 24 8,716 78 504 NA 1,891
Donner Pass Road Immediately South of 1 -80 12,041 494 585 1,609 96 13,650 290 681 NA 1,891.
Donner Pass Road - Bridge Street to Glenshire'Drive 12,000 483 685 899 72 12,899 255 757 NA 1,891 1
( Prosser Darn Road Immediately East of SR 89 1,333 40 80 1,351 199 2,684 209 279 NA 1,891
(Alder Drive Immediately East of SR 89 3,283 4-078 1854,206 77 7,489 4 2 .,,62 6 NA 1,891
Pioneer Trail Immediately West of Donner Pass Road 8,656 54 515 322 16 8,978 79 531 NA 1,891 l 1
I Glenshire Drive Immediately South of Donner Pass Road 9,310 40 515 651 26 9,961 .34 541 NA . 1,891
(Airport Road Immediately East of SR 267 3,208 32 275 201 10 3,409 42_28 16,200 NA . I
Schaffer Mill Road Immediately West of SR 267 1,596 22 220 120 6 1,716 28 226 16,200 NA
Northstar Drive Immediately West of SR 267 7,308 44 325 193 10 7,501 54 335 16,200 NA
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Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 3 -2 September 2003
3.0 ERRATA TO THE DRAFT EIR
•
1 Page 4.2 -24 of the Draft EIR is amended to read: • - TABLE 4.2 -
2005 WEEKEND NO PROJECT PEAK -HOUR TRAFFIC VOLUMES
m N N&thbound r Southbound ° WeEastbound EaWestbound
1 nfe
Intersection� -,. n�-,��i,.c LT, T(-- .K RTni;LT > %_T RTi4 n TIDt RT.'? •
SR 89 / Rainbow Dr 0 199 90 16 364 0 0 0 0 53 0 14
SR 89 / Prosser Dam Rd / Alder Dr59 262 55 11 390 16 5 136 60 7 11 11
SR 89 North / Donner Pass Rd 189 229 0 0 265 321 147 129 0 0 0 0
SR 267 /1-80 WB 421 165 0 0 248 146 0 0 0 263 0 253
SR 267 /1-80 EB 0 511 76 392 183 0 75 0 382 0 0 0
I Donner Pass Rd / Pioneer Trail 191 179 0 0 358 106 103 0 200 0 0 0
Donner Pass Rd /1-80 WB 160 364 0 0 305 253 0 0 0 0 0 0
Doriner Pass Rd /1-80 EB 0 450 0 0 305 0 74 0 280 0 0 0
Page 4.2 - 39 of the Draft EIR is amended to read:
TABLE 4.2 -10
' 2005 SUMMER WEEKEND PEAK HOUR PROJECT GENERATED TRIPS
Northbound Southbound , WeEastbound r EaWestbound ;
LT _ T.a RT.„ir.
SR 89 / Rainbow Dr 0 12 11 0 13 0 0 0 0 13 0 0
SR 89 / Prosser Dam Rd / Alder Dr 78 3 175 18 3 5 3 17 52 171 18 17
' SR 89 North / Donner Pass Rd 0 145 120 12 162 52 94 41 0 119 27 3
13R 267 /1-80 WB 0 228 0 0 119 171 0 0 0 0 0 37
SR 267 /1-80 EB 0 90 0 35 84 0 138 0 0 0 0 0
1 Donner Pass Rd / Pioneer Trail
Donner Pass Rd / -80 WB 0 117 0 0 63 17 18 0 0 0 0 0
0 117 0 0 54 9 0 0 0 0 0 0
Donner Pass Rd /1-80 EB 0 107 0 0 54 0 10 0 0 0 0 0
1 TABLE 4.2 -11
2005 SUMMER WEEKEND PLUS PROJECT PEAK -HOUR VOLUMES
9n° {n - t
��rr � � � $ a { Northboun So uthboun d k VlteEastbound €a Westbound°
Intersection.1 .. �. z.L ,,ITdc T ; RT,tiLT T-* RT .;: LT, T RL .
' SR 89 / Rainbow Dr 0 211 101 16 377 0 0 0 0 66 0 14
SR 89 / Prosser Dam Rd / Alder Dr 137 265 230 29 393 21 19 22 188 231 25 28
SR 89 North / Donner Pass Rd 189 374 120 12 427 373 241 41 129 128 27 17
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SR 267 /1-80 WB
SR 267 /1-80 EB 421 393 0 0 367 317 0 0 0 263 0 290
0 601 76 427 267 0 213 0 382 0 0 0
Donner Pass Rd / Pioneer Trail 191 296 0 0 421 123 121 0 200 0 0 0
' Donner Pass Rd /1-80 WB
Donner Pass Rd / -80 EB 160 481 0 0 359 262 0 0 0 0 0 0
0 557 0 0 359 0 84 0 280 0 0 0
Town of Truckee Final Environmental Impact Report
September • 3 -3 Gray's Crossing Specific Plan Project
3.0 ERRATA TO THE DRAFT EIR '
On page 4.2 -47 of the Draft EIR the following is added between Table 4.2 -14 and II
Impact Statement 4.2.1.
Construction Traffic 1
It is important to analyze traffic generated by construction activities in addition to '
the traffic generated by the project land uses. Traffic generated by employees,
truck hauling, materials delivery, and concrete pours under Phase 11 has been
estimated by SCO Engineering, as the most intense construction traffic would '
occur under this phase (see • y` ®- ndix N in the Final EIR for estimated
construction traffic). The traffic generated by Phase 1 would be negligible as it
would primarily consist of the construction of single- family dwelling units over a '
longer period of time. The results of the analysis are summarized in Table 4.2-
14A. The construction activities are split into two categories: roadway and utility
construction and building /concrete construction. As these two types of activities '
would not occur concurrently they are analyzed separately.
TABLE 4.2 -14A ,
ESTIMATED TRAFFIC GENERATED BY PHASE 11 CONSTRUCTION ACTIVITIES
'Maternal
1
_ ' �` ` s ° 7 D e li very ; = M a f er�a l ti
, 4- it ' ° ^ .-` 'Roadway Delivery= i TAL
r a.. Ci ce v�'' 'v. r sx ,z a . . F ` t =r :.a
{: , t + ' 2 > f au
t p Of Hl a n° er
d V Concrete j9 ,,,'12 ,
....wt .r ;: xis Sa,Employees Trucking .',;.Gradm_g _ c.Consfr`uchon . -- ,: _ -'
Roadway and Utility
Construction
Number of Vehicles on 50 1 5 0 0 56 '
Site per Day (I)
Maximum Number of
One -way Trips 100 2 10 0 0 112
Generated. per Day (2) '
Percentage of Trips
Expected to Exit the 75% 10% 10% 10% 10% --
Site During P.M. Peak
Hour '
P.M. Peak-Hour
Generated Exiting 38 0 1 0 0 39
Traffic '
Building and Concrete
Construction
Number of Vehicles on 30 0 0 3 6 39
Site per Day (1) '
Maximum Number of
One -way Trips 60 2 0 6 12 80
Generated per Day (2)
Percentage of Trips ,
Expected to Exit the 75% 10% 10% --
Site During P.M. Peak 10% 10%
Hour '
P.M. Peak-Hour
Generated Exiting 23 0 0 0 1 24
Traffic
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 3 - September 2003 ,
1 3.0 ERRATA TO THE DRAFT EIR
Note 1: Assumes one person per vehicle occupancy.
Note 2: Assumes two one -way trips per person per day.
As the table indicates, during peak construction activities, the project will
generate a maximum of 112 daily one -way construction - related trips and 39 P.M.
' peak -hour trips. In addition, most of these trips will be distributed to 1 -80 to the
east or west. This trip generation is less than 35 percent of the trips generated by
Phase 1. As indicated in the Draft EIR the critical intersections, or the intersections
1 that will most likely exceed LOS standards with increased traffic are the SR
89 /Alder Drive /Prosser Dam Road and SR 89 /Donner Pass Road intersections.
Adding 39 PM peak -hour to either of these intersections would result in an
increase in total peak -hour traffic volumes of 3 percent. Weekday LOS with this
additional traffic was analyzed at these two intersections to see the impact the
construction traffic would have on intersection LOS. The LOS calculations may be
found in Appendix N.
At the SR 89 /Donner Pass Road intersection, the construction traffic would
' exacerbate the no- project LOS F condition. However, as this would be an
existing deficiency the following Town of Truckee thresholds of significance
would apply:
1 For intersections with an unacceptable level of service, the project
increases the total traffic volumes of the intersection 5% or more above
existing traffic volumes. The significant impact may be reduced to a less
1
than significant level by incorporating intersection improvements and
other mitigation into the project, which maintains the level of service of
the intersection at pre - project levels.
'
As the construction traffic would not increase traffic volumes through the SR
89 /Donner Pass Road intersection by more than 5 percent under Phase 1
1 construction, this would not result in a significant impact. However, the impact of
Phase 1 land uses and Phase 2 construction traffic would result in an increase in
traffic volumes through this intersection of more than 5 percent.
The construction traffic at the SR 89 /Alder Drive /Prosser Dam Road intersection
generated by Phase 11 and after the completion of Phase 1 would increase the
' average intersection delay at the intersection from 11.7 (LOS B) to 36.8 (LOS E),
which would exceed the Town of Truckee LOS thresholds.
MM 4.2.1 on page 4.2 -48 has been changed as follows:
' MM 4.2.1 Prior to the issuance of the first building permit for the project or the
recordation of final subdivision maps (whichever comes first), the
project applicant shall pay its fair share cost of improvements at the
t SR 267 /Northstar Drive and Donner Pass Road /Bridge Street
intersections as described in Table 4.2 -15. Prior to issuance of the
first Certificate of Occupancy or recordation of the Phase I Final
1 Subdivision Map (whichever comes first), the project applicant shall
Town of Truckee Final Environmental Impact Report
September 2003 3 -5 Gray's Crossing Specific Plan Project
3.0 ERRATA TO THE DRAFT EIR 1
conduct a signal warrant analysis at the SR 89 / Donner Pass Road 1
intersection. If found by Caltrans to warrant improvement, the
project applicant shall construct a signal or roundabout at this ,
location as described in Table 4.2 -15. If a signal warrant is not met
prior to Phase 1 construction, at the Town's discretion, the project
applicant shall be responsible for preparing a roundabout or signal
design acceptable to Caltrans, posting a bond with the Town of
Truckee equal to 125 percent of the construction cost of the
improvement, conducting a signal warrant analysis on an annual
basis, as well as for construction of a signal or roundabout when
warrants are determined by Caltrans to be met. These signal
warrant analyses will need to consider construction traffic impacts. '
Finally, if a signal or roundabout is not warranted prior to Phase 2
construction, the applicant will be required to provide traffic
management at the intersection during those construction traffic
periods at which average delay exceeds 50 seconds per vehicle, or
provide a construction traffic management plan that avoids this
level of delay.
In addition, prior to issuance of the first Certificate of Occupancy or
recordation of the Phase 1 Final Subdivision Map for Grays Crossing
Phase 1, the applicant shall construct a northbound left -turn lane at
the SR 89 /Alder Drive /Prosser Dam Road intersection. The applicant
can alternatively construct a signal or roundabout at this location '
prior to recordation of subdivision maps or building permits for Phase
1, if identified as appropriate by Caltrans based upon a signal
warrant analysis. If approval of a signal or roundabout is not '
granted by Caltrans, the project applicant shall be responsible for
preparing a roundabout or signal design acceptable to Caltrans,
posting a bond with the Town of Truckee equal to 125 percent of the
construction cost of the improvement, conducting a signal warrant
analysis on an annual basis, as well as for construction of a signal or
roundabout when warrants are determined by Caltrans to be met. '
The applicant would have the opportunity to recover a portion of
costs from fees collected in the future from projects also contributing
to future traffic growth at this intersection, as required by the Town of
Truckee. Finally, all construction traffic shall be prohibited from
entering SR 89 from Prosser Dam Road when exiting the Phase II '
construction areas (exiting via the Donner Pass Road access point),
unless a signal or roundabout is in place.
also construct tho improvomcnts to tho SR 89 North / Donnor Pass 1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 3 -6 September 2003
3.0 ERRATA TO THE DRAFT EIR
1 - - - - - - ?• - - �= -=-
intersection. If found by Caltrans to meet warrants, the project
' described in Table 4.2 15, prior to issuance of tho first Certificate of
• en. z e _
Final Subdivision Map (whichever comes first). If not found by
1 bond with the Town of Truckee equal to 125 percent of the
construction cost of the improvement, conducting a signal warrant
1 analysis on an annual basis, as well as • for construction of a signal or
1 construct a roundabout as part of Phase I, thereby avoiding the
projects also contributing to future traffic growth at this intersection,
' as required by the Town of Truckee.
Please note that the SR 89 North /Prosser Dam Road intersection and
' SR 89 / Alder Drive / Prosser Dam Road intersection were analyzed
as both signalized intersections and as roundabouts, as shown in the
site plan. In 2005 with a roundabout, both intersections are
expected to operate at a LOS B or better for both the weekend and
weekday plus project conditions.
' For the purposes of determining the project's fair share cost, the
percentage the Gray's Crossing project contributes to the total
future growth in PM peak -hour total intersection volume at each
intersection requiring mitigation is presented in Table 4.2 -16. None
'. of the improvements identified above are included in the existing
Placer County or Town of Truckee Traffic Fee Programs. The fair
' share cost to improvements within the Town of Truckee shall be paid
to the Town of Truckee. Similarly, the fair share cost to improvements
within Placer County shall be paid to Placer County.
1 However, please note that the Town of Truckee and Placer County
are currently conducting a joint study of a potential joint regional
' traffic impact mitigation program, which could mitigate the impact
of planned growth on these regional facilities. The timing of this
project may provide an opportunity to mitigate identified impacts to
regional transportation facilities through a larger coordinated
program. Therefore, if a regional traffic impact fee program is
• implemented by the Town of Truckee and Placer County and all the
intersections identified as requiring mitigation in this EIR are
Town of Truckee Final Environmental Impact Report
September2003 3 -7 Gray's Crossing Specific Plan Project
3.0 ERRATA TO THE DRAFT EIR
contained in this fee program, the project applicant shall pay the
appropriate amount into this fee program prior to the issuance of the
first building permit for the project or the recordation of final
• subdivision maps. The project applicant's fee will be determined by
the methodologies adopted as a part of the regional fee program.
If some of the roadways or intersections identified above are not
contained in the fee program, the project applicant shall pay its fair
share to the additional improvements.
Timing /Implementation: Prior to recordation of subdivision maps or the 1
issuance of initial building permit or the recordation of the final subdivision
map, except that construction of the SR 89 / Alder Drive roundabout or
signal shall be required prior to issuance of the first Phase II building permit
or the recordation of Phase 2 final subdivision maps, as this improvement is
not required to accommodate Phase I traffic.
Enforcement /Monitoring: Town of Truckee, Placer County Department of
Public Works, Caltrans.
1
Page 4.2 -56 of the Draft EIR is amended to read:
Mitigation Measure
MM 4.2.7 As shown in Table 4.2 -19, a draft calculation of the Town of Truckee
1 traffic mitigation fee estimates the project applicant will be
required to pay approximately $1,926,821 to the Town of Truckee in
the form of a Traffic Mitigation Fee prior to the completion of the
project. However, this fee is subject to change and shall be
collected prior to or in conjunction with the issuance of building
permits or the recordation of final subdivision maps. Therefore,
these fees will be incrementally applied to the phases of
development when building permits are issued.
Timing /Implementation: Prior to or in conjunction with the
issuance of building permits or the recordation of final subdivision
maps.
Enforcement /Monitoring: Town of Truckee Community
Development Department /Planning Division.
Page 4.2 -57 of the Draft EIR is amended to read:
1
1
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 3 -8 September 2003
3.0 ERRATA TO THE DRAFT EIR
' TABLE 4.2 -21
2023 No THIRD TAHOE DONNER CONNECTOR SUMMER WEEKEND NO PROJECT PEAK -HOUR VOLUMES
N orthbou n d , Southbound WeEastbound ' €e Westbound •
Intersectwn ••:•N ., ..,`.;, a ���. licit RiLT... T ' RT_, LT`r._ ten.; RT.*a
SR 89 / Rainbow Dr 0 320 195 20 405 0 0 0 0 130 0 15
1 SR 89 / Prosser Dam Rd / Alder Dr 120 480 105 10 510 10 25 10 150 80 10 10
SR 89 North / Donner Pass Rd 325 430 0 0 275 465 275 0 180 0 0 0
. SR 267 /1-80 WB 820 375 0 0 445 15 0 0 0 755 0 380
1 SR 267 /1-80 EB 0 1 170 500 435 765 0 25 0 810 0 0 0
Donner Pass Rd / Pioneer Trail 350 315 0 0 545 125 120 0 270 0 0 0
1 Donner Pass Rd /1-80 WB — 200 665 0 ' 0 450 365 0 0 — 0 0 — 0 0
Donner Pass Rd / 1 -80 EB 0 640 0 0 450 0 225 0 365 0 0 0
I TABLE 4.2 -22
2023 WITH THIRD TAHOE DONNER CONNECTOR SUMMER WEEKEND NO PROJECT PEAK -HOUR VOLUMES
Northbound Southbound WeEastbound €aWestbound
Iniersectron:';' _ . _ . L T , T a , RT' i LT.. T,. s RT�_ LT ;� , T� RTr LT -'' T ° RT '-;
SR 89 / Rainbow Dr 0 290 195 20 415 0 0 0 0 130 0 15
SR 89 / Prosser Dam Rd / Alder Dr 120 445 110 10 520 10 25 10 155 80 10 10
SR 89 NORTH / Donner Pass Rd 365 415 0 0 285 475 260 0 210 0 0 0
SR 267 / -80 WB 815 .375 0 0 485 15 0 0 0 755 0 405
SR 267 /1-80 EB 0 1 165 500 475 765 0 25 0 775 0 0 0
1 Donner Pass Rd / Pioneer Trail 345 305 0 0 545 160 145 0 265 0 0 0
Donner Pass Rd /1-80 WB 185 655 0 0 455 355 0 0 0 0 0 0
+Donner Pass Rd /1-80 EB 0 620 0 0 455 0 220 0 350 0 0 0
I Pages 4.2 -60 and 4.2 -61 of the Draft EIR are amended to read: • TABLE 4.2 -23
' 2023 SUMMER WEEKEND PEAK HOUR PROJECT GENERATED TRIPS
NO THIRD TAHOE DONNER CONNECTION
3 ;1 z C,r 'v . y ns.' 1 •.'d^vcrYix ._,.. X.
N orthbound
Intersection .Southbound YVeEastbound E Westbountl
; ,. ,' c57.;.::- , .>, r4 LT'S Ti r- a , LT T , RT .. Ltr'b734 T _.; RTC Lt . T` RT ty
SR 89 / Rainbow Dr 0 12. 11 0 13 0 0 0 0 13 0 0
SR 89 / Prosser Dam Rd / Alder Dr 78 3 175 18 3 5 3 17 52 171 18 17
' SR 89 North / Donner Pass Rd 0 135 120 12 162 52 94 41 0 128 27 17
SR 267 /1-80 WB 0 228 0 0 119 171 0 0 0 0 0 37
SR 267 /1-80 EB 0 90 0 35 84 0 138 0 0 0 0 0
1 Donner Pass Rd / Pioneer Trail 0 117 0 0 63 17 18 0 0 0 0 0
Donner Pass Rd /1-80 WB 0 117 0 0 54 9 0 0 0 0 0 0
Donner Pass Rd /1-80 EB 0 107 0 0 54 0 10 0 0 13 0 0
- Town of Truckee Final Environmental Impact Report
September 2003 3 -9 Gray's Crossing Specific Plan Project
3.0 ERRATA TO THE DRAFT EIR
TABLE 4.2 - 24 1
2023 SUMMER WEEKEND PEAK -HOUR PROJECT - GENERATED TRIPS
WITH THIRD TAHOE-DONNER CONNECTION
t r, Northbound - Southbound WeEastbound ' EaWestbound `,
Intersection . ._ .3" a ' , J.Lt& T . 2RT- 41T. T RT,,.,,1T.?,4 T.1 WU L17 ..., RL,
SR89 /Rainbow Dr 0 12 11 0 13 0 0 0 0 13 0 0
SR 89 / Prosser Dam Rd / Alder Dr 78 3 177 18 3 5 3 17 52 173 18 17
SR 89 North / Donner Pass Rd 0 133 104 12 153 62 108 55 0 104 40 17
SR 267 /1-80 WB 0 200 0 0 119 148 0 0 0 0 0 37
SR 267 /1-80 EB 0 90 0 35 84 0 110 0 0 0 0 0
Donner Pass Rd / Pioneer Trail 0 117 0 0 62 40. 45 0 0 0 0 0
Donner Pass Rd /1-80 WB 0 117 0 0 54 8 0 0 0 0 0 0
Donner Pass Rd /1-80 EB 0 107 0 0 54 0 10 0 0 0 0 0
TABLE 4.2 -25 1
2023 SUMMER WEEKEND PLUS PROJECT PEAK -HOUR TRAFFIC VOLUMES
NO THIRD TAHOE-DONNER CONNECTION
Northbound,'-. Southbound `.. WeEastbou`n'd EatNe'sfbound
L-T T! i4 RT :I LT ' T ,.` RT, LT ° Tr . RT<, 3i2'
SR 89 / Rainbow Dr 0 332 206 20 418 0 0 0 0 143 0 15
SR 89 / Prosser Dam Rd / Alder Dr 198 483 280 28 513 15 28 27 202 251 28 27
SR 89 North / Donner Pass Rd 325 575 120 12 437 517 369 41 180 128 27 17
SR 267 /1-80 WB 820 603 0 0 564 186 0 0 0 755 0 417
SR 267 /1-80 EB 0 1260 500 470 849 0 163 0 810 0 0 0
Donner Pass Rd / Pioneer Trail 350 432 0 0 608 142 138 0 270 0 0 0
Donner Pass Rd /1-80 WB 200 782 0 0 504 374 18 0 0 0 0 0
Donner Pass Rd /1-80 EB • 0 747 0 0 504 0 235 0 365 0 0 0
TABLE 4.2 -26 1
2023 SUMMER WEEKEND PLUS PROJECT PEAK -HOUR TRAFFIC VOLUMES
WITH THIRD TAHOE-DONNER CONNECTION ,
• r • r s Northbound ,- Southbound WeEastbounth EaWestbound
Intersect�onct,._,., �LT...TL k.RTr =Lt4 T.T;4RT.v+ ,T;t2.RT` LT._ „T'"'RT-
SR 89 / Rainbow Dr 0 302 206 20 248 0 0 0 0 143 0 15
SR 89 / Prosser Dam Rd / Alder Dr 198 448. 287 28 523 15 28 27 207 253 28 27
SR 89 North / Donner Pass Rd 365 548 104 12 438 537 368 55 210 113 40 17
SR 267 /1-80 WB 815 575 0 0 604 163 0 0 0 755 0 442
SR 267 /1-80 EB 00 1,255 500 510 849 0 135 0 775 0 0 0
Donner Pass Rd / Pioneer Trail 345 422 0 0 607 200 190 0 265 0 0 0 1
Donner Pass Rd /1-80 WB 185 772 0 0 509 363 0 0 0 0 0 0
Donner Pass Rd /1-80 EB 0 727 0 0 509 0 230 0 350 0 0 0
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 3 -10 September 2003
3.0 ERRATA TO THE DRAFT EIR
•
MM 4.2.9 on page 4.2 -87 of the Draft EIR is amended to read:
Mitigation Measures
MM 4.2.9 Prior to the first building permit or recordation of Final Subdivision Map
under Phase II, the project applicant shall prepare a transit plan
identifying methods and equipment necessary to provide transit
services for project residents, guests and employees. The plan shall
also identify onsite improvements required to facilitate efficient transit
operations. Transit services shall provide transportation to downtown
Truckee and provide connections to private and public transit
providers. The transit plan shall be reviewed and approved by the
Town of Truckee Public Works Director, and may consider programs
that serve other existing and planned developments in the northeast
portion of Truckee. In addition, the plan shall accomplish the
following:
' a) Identify the future transit demand that will result along the SR 89
North corridor upon build out of the area and determine
whether transit service is warranted based upon the level of
demand.
b) Identify the level of service (frequency, days and hours of
service) needed to meet the warranted demand.
c) Identify the project's fair share cost of providing the required
transit service. This shall include both capital and operating
costs of the service.
d) Identify the period (number of years) that the project will be
required to partially fund the transit service operation, which
sh all be used to calculate the present value
The pro ject will be required to pay 5 pe rce nt of the present value of
1
shall be used to calculate the present value. In addition, the project
owners shall become members of the Truckee —North Tahoe
Transportation Management Association.
Timing /Implementation: Prior to issuance of building permits or the
recordation of final subdivision maps.
Enforcement /Monitoring: Town of Truckee
Implementation of MM 4.2.9 will reduce the project's impacts to transit to a Tess
than significant level.
1
1
Town of Truckee Final Environmental Impact Report
September 2003 3 - 1 Gray's Crossing Specific Plan Project
3.0 ERRATA TO THE DRAFT EIR
4.3 NOISE
No changes were made to this section of the Draft EIR. 1
4.4 AIR QUALITY
The first paragraph on page 4.4 -4 is amended to read:
The Northern Sierra Air. Quality Management District (NSAQMD) maintains
ambient air quality monitoring stations in the Truckee area. Ozone and PM2.s are
currently monitored at the Truckee -Fire Station site and PMio
to 2001 was continually monitored between July 2000 and May 2002 via a TEOM
monitor, also located at the Truckee Fire station. PMio was also monitored in the
Glenshire subdivision prior to 2001. In the five -year period between 1997 and
• 2001, no exceedance of national or state standards for ozone were recorded
(CARB; 2003).
MM 4.4.5 on page 4.4 -18 of the Draft EIR is amended to read:
Mitigation Measure ••
MM4.4.5 e e e e ' - - - e -- - e 'ea -
.
guidelines and risk acceptability criteria of the NSAQMD at the
Prior to construction of the service station, the project applicant shall 1
obtain a permit from the NSAQMD. Prior to commencing
construction of the fueling station, the NSAQMD will calculate risk
assessment based on throughput and proximity to receptors. The
applicant shall provide documentation of the permit to the Town of
Truckee.
Timing /Implementation: Prior to construction of the service station.
Enforcement /Monitoring: Town of Truckee Development
1
Department /Building Division /NSAQMD.
4.5 GEOLOGY, SOILS, AND HAZARDOUS MATERIALS
No changes were made to this section of the Draft EIR. 1
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 3 -12 September 2003
1 3.0 ERRATA TO THE DRAFT EIR
4.6 WATER QUALITY AND SURFACE HYDROLOGY
1 Pages 4.6 -16 through 4.6 -17 of the Draft EIR are amended to read:
Surface Runoff and Ground Water Contaminants from Urban Uses
1 Impact 4.6.3 Development and operation of the proposed project may
increase surface runoff from the project, which may contain
contaminants that could enter surface waters and possibly ground
water. [6SPSM]
' Contaminants in runoff from residential and commercial areas are likely to
consist primarily of motor vehicle fluids such as fuels, oil and radiator coolant.
Also typically found in urban runoff are trace metals such as copper, lead, zinc,
I cadmium, chromium, arsenic and nickel. Landscaping may contribute fertilizers,
pesticides and herbicides and other potential contaminants, which may include
nutrients, organic compounds and sediments. The potential for pollution is
' typically highest during late summer and fall when pollutants are bound to
particulates in the sediments and then released during the first large rainfall
event of the season. Since pollutants are typically concentrated in the
environment after the long dry season, increased levels of contaminants is most
likely during the first flush event because the dilution factor is relatively low.
Increased levels of contaminants in surface runoff has the potential to exceed
water quality standards and can detrimentally affect aquatic and wildlife
' resources.
The Gray's Crossing project is within the Norfh Lahontan Basin, specifically the
Truckee River Hydrological Unit (TRHU). The TRHU has several prohibitions for
discharge. Chapter 4.1 (Waste Discharge Prohibition) of the Basin Plan describes
the many prohibitions for all the different basins (attached as Appendix El). The
prohibitions that apply to the TRHU are listed in Figure 4.1 -1 and pertain to areas
as indicated in Figures 4.1 -7 and 4.1 -8 in the Water Quality Control Plan for the
Lahontan Region (these figures are also attached as part of Appendix El).
•
The Gray's Crossing project would be subject to the Water Quality Standards
described in Chapter 3 (Water Quality Objectives) of the Basin Plan for the TRHU.
Figure 3 -5 from this section of the Basin Plan is entitled Water Quality Objectives
for Certain Water Bodies and .the specific water quality objectives are listed in
Table 3 -11 (attached together as Appendix E2). In particular, Objectives 3
applies to the proposed Gray's Crossing project. Minimal surface waters from
the project site may reach the Truckee River between Objective Locations 4 and
3, but the majority of site runoff flows to a tributary that feeds Prosser Creek,
which flows into the Truckee River at Objective Location 3. Chapter 2 (Present
and Potential Beneficial Uses) of the Basin Plan describes several beneficial uses
of the Truckee River, including agricultural supply, aquaculture, preservation of
biological habitats of special significance, cold freshwater habitat, ground water
recharge, in addition to others.
Town of Truckee Final Environmental Impact Report
September 2003 3 -13 Gray's Crossing .Specific Plan Project
. 3.0 ERRATA TO THE DRAFT EIR 1
Prior to construction of a• project greater than one acre, the Regional Water 1
Quality Control Board (RWQCB) currently requires the owner to file for a National
Pollution Discharge Elimination System (NPDES) General Permit. The Lahontan
RWQCB's General Permit process requires the project applicant to 1) notify the
State, 2) prepare and implement a Storm Water Pollution Prevention Plan
(SWPPP), and 3) to monitor the effectiveness of the plan.
The RWQCB Storm Water Quality Task Force has prepared Best Management
Practice (BMP) Handbooks for Construction Activities, Commercial /Industrial
Facilities, and Municipalities. Each BMP listed in the handbooks has an outline for
maintenance requirements of the BMP. As part of the SWPPP, temporary BMP
maintenance requirements are required of the project applicant. The applicant
is responsible for verifying that proper methods are being implemented
according to the approved SWPPP. Each BMP listed in the SWPPP must address
proper maintenance of that BMP (i.e., a stabilized construction entrance shall be
inspected monthly and after each rainfall and . gravel shall be placed where
voids are visible).
When a BMP evolves from a temporary to a permanent BMP, such as sediment 1
basins, they are initially to be maintained by the applicant until such a time that
the Town accepts the roads and drainage facilities into their system. At that time
the maintenance of certain sediment basins may become the responsibility of
the Town. In this instance, a signed agreement shall be provided to the RWQCB
notifying them of the responsible party for that structure.
Maintenance of BMPs under the jurisdiction of the Town shall be maintained
according to the Town's approved NPDES permit. Maintenance of permanent
BMPs under the applicant's ownership shall be in accordance with the NPDES
permit or the Waste Discharge Requirement (WDR) permit for that system. In
general, inspections shall occur prior to and immediately after each significant
storm event. Cleaning and maintenance shall be as needed to ensure proper
operation of each BMP. Once yearly, prior to the wet season, each facility shall
be inspected and a report generated outlining the condition of the BMP. The
BMP shall be maintained to a maximum level of effectiveness. The report shall
be forwarded to the Regional Board requesting the report.
A recent study provides evidence that well - planned development within the
Martis Valley, along with implementing the Lahontan RWQCB's BMPs, can
effectively protect water quality. The study completed by Huffman & Carpenter
Inc. (2003), entitled Cumulative Wafer Quality Analyses Report for Lahontan
Development 1996 -2002, assessed the effectiveness of the Lahontan I
development project design, including the use of RWQCB BMPs and discharge
restrictions, on meeting Lahontan RWQCB Basin Plan water quality objectives.
Water quality data collected between 1996 and 2002 were analyzed to assess
whether there were project - related impacts to Martis Creek. Through a six -year
monitoring program, Huffman & Carpenter concluded that water quality
objectives set by the Lahontan RWQCB for Martis Creek at its confluence with
the Truckee River (downstream of the proposed project) were being met, and
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 3 - 14 September
3.0 ERRATA TO THE DRAFT EIR
1 that based on the analysis, the golf course and project does not appear to
adversely impact water quality in Martis Creek.
•
1 Regardless of the above discussion, Ppotential impacts to water quality as a
result of the proposed project are considered potentially significant and subject
' to mitigation. would be mitigated to a Icss than significant level through The
project will be subject to the generail ^ epted BMP design elements of the
NPDES permit process, which is required as part of standard Town of Truckee
conditions of approval. Resepdiess, To ensure contaminated surface runoff from
the proposed project does not enter surface and ground waters and to ensure
applicant adherence to the NPDES regulatory framework and to ensure
adherence Lahontan • RWQCB water quality standards, the following
mitigation measures are recommended.
• •
Pages 4.6 -18 through 4.6 -19 of the Draft EIR are amended to read:
' MM 4.6.3b In compliance with the requirements of the State General
Construction Activity Storm Water Permit as well as the Water
Quality Control Plan for the Lahontan Region (Basin Plan), the
' applicant shall prepare a Stormwater Pollution Prevention Plan
(SWPPP) which describes the site, erosion and sediment controls,
means of waste disposal, implementation of approved local plans,
control of post- construction sediment and erosion control measures
and maintenance responsibilities, and non -storm water
management controls. This plan shall cover the entire Gray's
Crossing Specific Plan site. The SWPPP shall also be submitted to
Town of Truckee Department of Public Works and the Lahontan
Regional Water Quality Control Board for review and approval.
' The applicant shall require all construction contractors to retain a
copy of the approved SWPPP on each construction site. Water
quality controls shall be consistent with the Town's Grading
Ordinance and the Lahontan Regional Water Quality Control
Board's Truckee Rivor Hydrologic Unit North Lahontan Region
Project Guidelines for Erosion Control and will demonstrate that the
' • water quality controls will ensure no increase in turbidity, sediment
or other pollutant loads in Prosser Creek and the Truckee River and
that storm water discharges are in compliance with all current
requirements of the Lahontan Regional Water Quality Control
Board. Water quality controls may include, but are not limited to,
the following:
1 • Prohibit placement of surplus or waste materials within the 100 -
year floodplain of onsite intermittent drainages.
•
• Stabilize all disturbed areas by October 15th of each year.
•
• Install temporary gravel dikes, earthen dikes or sand bag dikes
• to prevent the discharge of pollutants.
Town of Truckee Final Environmental Impact Report
September 2003 3 -15 Gray's Crossing Specific Plan Project
3.0 ERRATA TO THE DRAFT EIR
• Install infiltration trenches or other protection facilities.
•
• Revegetate disturbed areas and maintain vegetation. 1
• Compliance with Lahontan Regional Water Quality Control
Board NPDES No. CAG996001 (National Pollutant Discharge
Elimination System General Permit for Limited Threat Discharges
to Surface Waters) for construction dewatering activities.
Timing /Implementation: Prior to Improvement Plan approval.
Enforcement /Monitoring: Town of Truckee Public Works, Lahontan
Regional Water Quality Control Board.
MM 4.6.3c During the long -term operational phase of the project, a
permanent erosion and water quality control plan consisting of
• BMPs (attached as Appendix E3 in the technical appendices) shall
be built into the infrastructure of the project's improvements and
operational activities. It shall conform to requirements of the
Lahontan RWQCB and the Truckee Development Code.
Timing /Implementation: Prior to issuance of a grading permit.
Enforcement /Monitoring: Lahontan Regional Water Quality Control
Board, Town of Truckee Community Development
Department /Planning Division.
Implementation of the above mitigation measures will ensure that water quality 1
controls shall be consistent with Lahontan RWQCB's North Lahontan Region
guidelines for erosion control and will demonstrate that the water quality controls will
ensure no increase in turbidity, sediment or other pollutant loads in Prosser Creek
and the Truckee River and that storm water discharges are in compliance with all
current requirements of the Lahontan RWQCB. Impacts after implementation of this
mitigation will be Tess than significant.
MM 4.6.7, found on page 4,6 -28 of the Draft EIR, is revised as follows: 1
MM 4.6.7 The applicant shall develop a Master Drainage Plan in accordance
with the requirements of Section 18.30.050 of the Town of Truckee
Development Code and the Truckee Public Improvement and
Engineering Standards (except as modified by this mitigation
measure), which demonstrates how the proposed drainage
improvements shall accommodate the additional runoff and limit
the cumulative effects of runoff from development areas. The Plan
shall contain an estimate of the amount of surface runoff that will
be generated by the proposed development. The applicant shall
pregrarx�s —t calculate flows, size culverts, and size ditches 1
consistent with surface runoff estimations. Detention ponds shall be
designed -
•
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 3 -16 September 2003
3.0 ERRATA TO THE DRAFT El R
• shall be sized using tho SCS TR 20 method along with the Typo 1A
1
l ianhall be and sized to a 20 -year, one -hour storm event prior to
implementation of proposed construction activities. The applicant
shall ensure that existing drainage systems are utilized to their fullest
extent possible when designing stormwater drainage systems. The
plan shall be consistent with standards and guidelines established
by the Lahontan Regional Water Quality Control Board (RWQCB )
and CalTrans. Both the Lahontan RWQCB and CalTrans shall be
' given an opportunity to review the final design and make a
determination of the effectiveness of the proposed drainage
facilities. If the facilities do not meet Lahontan RWQCB or CalTrans
requirements, they may require changes and re- submittal of the
drainage documentation.
1 4.7 BIOLOGICAL RESOURCES
' MM 4.7.2 on pages 4.7 -24 and 4.7 -25 of the Draft EIR is amended to read:
MM 4.7.2 The project applicant shall obtain the following two designations: 1)
Audubon International (Al) Approved Land Plan, and 2) the Gold
Seal of Sustainability, or the equivalent. Only after successful
completion of final Al audits will the golf course receive a Gold
Signature designation. The applicant must successfully complete
and implement a Natural Resource Management Plan to Al
specifications, host site visits during the construction of the project,
and successfully pass an on -site environmental audit after the
project is completed. The Natural Resource Management Plan will
achieve natural resource sustainability through incorporation of
Integrated Pest Management, Best Management Practices, an
assessment of environmentally sensitive areas, and a monitoring
program for the golf course. The golf course must retain the Gold
' Seal designation through submission of annual reports,
documentation of environmental issues, hosting of annual audits by
Al scientist, and maintenance of annual membership dues.
The project applicant shall provide annually to the Town proof of
certification of the project's golf course with the Gold Seal of
1 Sustainability, or the equivalent, designation.
4.8 HISTORIC AND CULTURAL RESOURCES
• No changes were made to this section of the Draft EIR.
Town of Truckee Final Environmental Impact Report
September 2003 3 -17 Gray's Crossing Specific Plan Project
3.0 ERRATA TO THE DRAFT EIR
4.9 VISUAL RESOURCES /LIGHT AND GLARE 1
No changes were made to this section of the Draft EIR. 1
4.10 COMMUNITY SERVICES
No changes were made to this section of the Draft EIR.
1
4.11 UTILITIES AND SERVICE SYSTEMS
The second paragraph of Section 4.11.2, page 4.11 -5 of the Draft EIR, second
paragraph under Truckee Sanitary District Code is amended to read:
Typically, the TSD requires large developments to design, fund, and install the
sanitary sewer system necessary to service the proposed development in
accordance with the TSD Code. If the installed sanitary sewer system meets TSD
specifications, -- e- - -- a •ee - e e -_ • e - _ •_ e - _ -- e,
whereupon th TSD the developer may petition the TSD Board of Directors to
dedicate said facilities to the TSD, whereupon the TSD Board reviews the request 1
and votes to accept the dedication and ultimately takes over the responsibility
for operation and maintenance of the system.
The paragraph numbered 2 on page 4.11 -16 of the Draft EIR is amended to read:
2. For the area of the project site east of the SR 89, sewage would be
transferred to a sewage lift station at the northeast portion of the property. 1
From that point a force main would be constructed along the easterly
property boundary, crossing under the Fibreboard Undercrossing, and
connecting to the golf maintenance facility at Old Greenwood. From 1
that point sewage would be transferred through the sewer lines being
constructed at the Old Greenwood development to the Glenshire Outfall
which crosses Glenshire Road and then crosses underneath the Truckee
River to the waste treatment facility. This facility is known as the SAD Six
Outfall Crossing and is recognized as the primary routc for sewage flow
from the PC 2 project The Glenshire Outfall is proposed as the primary 1
route for sewage flow from the PC -2 and Old Greenwood projects as a
result of annexation of that property to the Truckee Sanitary District in the
early 1990's.
• 1
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 3 -18 September 2003
3.0 ERRATA TO THE DRAFT EIR
1 MM 4.1 1.1 found on page 4.11 -11 of the Draft EIR is revised as follows:
1 Mitigation Measure
MM 4.11.1 Prior to approval of the first phase of development, the project
applicant shall prepare, for review and approval by the Truckee
Donner Public Utilities District (TDPUD), a Water Distribution System
Facilities Report for the proposed project. The report shall address
the expansion of the water supply facilities and the specific
requirements for all phases of the project. Further, the report shall
incorporate the general guidelines for the water distribution system
identified in the Gray's Crossing Specific Plan, Chapter VII,
Programs, in addition to those identified below.
• The water distribution system for the Specific Plan area shall be
designed in conformance with the provisions of the TDPUD
Water System Master Plan.
1 • The water distribution system for the project area will be
designed to be compatible with the future regional distribution
' facilities as depicted within the Town's General Plan for the
project area. Each phase of development within the project
area shall size and construct that portion of the system as
' determined by the TDPUD. Reimbursement agreements may be
considered subject to TDPUD Standards.
• To supply water service to the Specific Plan area will require
approximately 400,000 gallons of storage capacity. A
combination of on- and /or off -site wells as determined by the
TDPUD will provide the water source. Service to the individual
development components within the project area will be via
water distribution lines in various sizes located within the
roadway right -of -ways.
• Water hook -up fees established by TDPUD for the purpose of
capital improvements shall be paid. These fees shall be used
for the purpose of making capital improvements (e.g.,
developing groundwater supply wells, increasing storage
capacity) to serve the project and other projected
development within TDPUD's service area. In accordance with
TDPUD requirements, these fees shall be paid as a condition of
1 issuance of building permits, and shall be based on the
project's fair share for the cost of such improvements_
Timing /Implementation: Prior to approval of the first phase of
1
development. Water hook -up fees shall be paid prior to the
issuance of building permits, and shall be assessed on a per -unit
basis in accordance with TDPUD policy regarding such fees.
•
Town of Truckee • Final Environmental Impact Report
September 2003 3 -19 Gray's Crossing Specific Plan Project
!.
•
3.0 ERRATA TO THE DRAFT EIR
Enforcement /Monitoring: Truckee Donner Public Utilities District, and 1
Truckee Fire Protection District (fire flow requirements).
1
The first sentence on Page 4.11-13 of the Draft EIR is amended to read:
The Tahoe - Truckee Sanitation Agency (T -TSA) _ e - - _ _ - _ 1
services to Truckee and convoys it to the treatment facilities located cast of the
Town Tewci-ef4cuakee treats and disposes of the sewage delivered to its facilities by
the Truckee Sanitary District.
Page 4.11 -13 of the Draft EIR, last paragraph, is amended to read: 1
TTSA uses a wastewater generation rate of 200 gallons per day (gpd) per single-
family residential dwelling unit or single - family units ( sfu's). Rates for commercial
and other land uses are based on equivalent sfu's. One sfu is equivalent to ten
(10) business plumbing fixture units. Lodging units arc each equivalent to 1/3 sfu
with kitchens are 35% of an sfu, lodging units without kitchens are 30% of an sfu,
swimming pools are equal to 1/2 sfu, and 10 restaurant seats are equal to 1 sfu.
Wastewater volumes produced by non - residential land uses are calculated by
multiplying the equivalent sfu by the 200 gallon per day rate. TTSA's service
charges are based upon the sewer flows and the strength of the sewage
generated from the user categories (Beals, 2001).
The last paragraph on page 4.11 -16 of the Draft EIR is amended to read:
Environmental review for the off -site sewer infrastructure which will serve the
Gray's Crossing project has previously been prepared in conjunction with the
Old Greenwood project and the new middle school and is sized to
accommodate the uses proposed by the Gray's Crossing project (Town of
Truckee, 2002). Further, prior to area connection into the TSD wastewater
collection system, the applicant will be required to prepare a comprehensive
collection system design, including appropriate line sizing to accommodate
flows onsite. The Preliminary Utility Plan (see Figure 3 -15) depicts the location of
on -site lines. Again, all facilities must be approved in size and location by the TSD
prior to construction. For these reasons, impacts to wastewater conveyance are
considered less than significant, and no mitigation is required.
4.12 POPULATION, HOUSING, AND SOCIOECONOMICS
No changes were made to this section of the Draft EIR.
1
1
Final Environmental Impact Report Town of Truckee
Gray's Crossing Specific Plan Project 3 -20 September 2003
3.0 ERRATA TO THE DRAFT EIR
5.0 CUMULATIVE IMPACTS SUMMARY
No changes were made to this section of the Draft EIR.
6.0 ALTERNATIVES
No changes were made to this section of the Draft EIR.
1
7.0 OTHER SECTIONS REQUIRED BY CEQA
' No changes were made to this section of the Draft EIR.
8.0 REPORT PREPARERS AND REFERENCES
No changes were made to this section of the Draft EIR.
1
1
1
1
1
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1
Town of Truckee Final Environmental Impact Report
September 2003 3 - Gray's Crossing Specific Plan Project
1
S W A
Concept Statement
Gray's Crossing— Clustered Alternative Concept'
Truckee, California
August 6, 2003
The Clustered Alternative Concept illustrates a development pattern that minimizes the
project footprint in an effort to achieve three important planning goals for the Town and
the region:
1. Provide a contiguous pattern of unfragmented open space suitable for wildlife
habitat and movement;
2. Provide much needed housing in neighborhoods affordable to local residents and
employees; and
3. Create a clustered community that provides easy access from all new housing to
open space as well as to goods and services located at the village center and in
downtown Truckee.
The proposed development protects wetlands and the drainages integrates these 1
natural features into the Concept Plan as an organizing element for the community.
Protecting this linear open space as a "Community Greenway" will reduce urban
stormwater runoff, provide a place for recreation and limited wildlife movement. It
should be noted that the large unfragmented open space areas located outside of the
development areas, provide more suitable movement corridors and habitat for wildlife.
1
1
This Concept was created to illustrate how the site could be more efficiently developed. It is a Concept
only at this point and will be further modified as information is developed concerning any impacts the
Concept would generate or new information is brought forward about site attributes that should be avoided
(e.g. superior wetland mapping, noise issues; etc.).
2 This Concept Plan has been forwarded to biological resource experts to be sure that the development
footprints respect areas of high habitat value and wildlife movement. The Concept Plan was based on the
best available information concerning these resource values. Because the site is extensive, development
could be relocated to respect biological values on the site, if information is forthcoming that development
areas would impact these values.
3 These natural features have been located on the site using the information provided in the EIR. We are
currently seeking additional information to verify the location of these features.
1
1
' S W A
' The community includes a mix of lot sizes as a way to encourage housing diversity. This
Concept Plan could be modified further to include a different mix of lot sizes within the
neighborhoods as the project evolves in the environmental review and hearing processes.
The following lot sizes provided in the concept plan add to the unique character of the
area:
Unit Type Units
Affordable/Employee 100
Attached Units: 120
45x100 SF 207
60x100 SF 64
80x100 SF 52
75x150 SF 93
Total 636 Units
Finally, the design and planning goal for the community is to provide each resident with a
sense of the great open space value that Truckee has to offer. This is achieved through
the combination of paseos that create the "green" front lawn of the 45x100 lots and the
• traditional pocket parks that form the core of each neighborhood.
1
1
1
1
1
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•
Exhibit 2
1
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MONDAY, JULY 28, 2003
BARRON'S COVER
1 A Rough Round
Why golfs prospects are dimming
By JONATHAN R. LAING
1 The Great Investment Sand Trap
1 THE NEW MILLENNIUM WAS WIDELY expected to usher in a new golden era for golf. First, it had a genuine
media star in Tiger Woods, the most charismatic player since golf greats Arnold Palmer and Jack Nicklaus
electrified the U.S. sports scene in the 'Fifties and 'Sixties, when golf last enjoyed a surge in popularity.
1 And there were the perfect duffer demographics. Aging baby boomers, sliding into their 50s and 60s, would have
the time and money to play more rounds, what with their children grown and their professional status secured.
Finally, the game that came of age in the swell of post -World War II prosperity — only 3.5 million Americans golfed
in 1950, compared with 26 million last year — seemed destined to find new devotees in the New Economy's dot-
com millionaires. After all, few sports have the snob appeal of golf, and few allow for the indulgence of so much
conspicuous consumption — of $500 titanium -shaft drivers, extravagant trips to the celebrated links of Ireland and
1 Scotland, and multi - million - dollar homes in swank communities built around courses designed by Jack, Tom and
Rees.
Yet a funny thing happened on the way to nirvana. The golf boom has fizzled unambiguously in the past few
' years, and threatens to become a king -sized bust. Take the number of rounds played in the U.S., which dropped
to 502.4 million last year from 518.4 million in 2000, according to the National Golf Foundation. This year
threatens a third consecutive decline. Florida -based Golf Data recorded a 2.7% drop year -to- date in rounds
' played through May, the latest figures it has compiled.
After decades of fevered growth, the number of golfers also has flattened, stabilizing around 25 million to 26
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million for the past six years. Memories of the sudden decline in national tennis participation — between 1987 and
'97, the tennis - playing portion of the U.S. population shrank to 11% from 17% — haunt golfs boosters and industry
insiders. A 1999 study by the National Golf Foundation and consultant McKinsey & Co. showed that golf was
losing about as many players each year as the three million or so it managed to attract. In the industry, this has
been dubbed the "commitment" problem. ,
Likewise, new golf- course openings have fallen precipitously in the past two years, after a steady climb through
the 1990s. Openings jumped to 398.5 in 2000 (a nine -hole course equals half a course) from 224 in 1990, only to
fall to 220 in 2002. The data fairly neatly track the trajectory of the stock market over the same span, which may
not be coincidental.
The pell-mell construction of U.S. gon
courses peaked in 2000, abng with the
stock market, but excess capacity
continues to plague the sport...
New U.S. Goff Course Canstructlon 1 .
400 7- 2000
1
t r
300 p r s , 1500
•
200 `' s 1000 1
€ r K r
sok
100 t ` 500
4 f pa g bt ! th )
0t A t..F r ) 'r F. z 0
'se 02 'e4 roe IS D0 0203E
,.. meanwhile, demand S falling, as
emdenoed by the recent drop in annual
rounds played.
600
Rounds Played
(in millions) ■
r
s k' 400
■
1, j • r- a ` 300
10 %A 050607 'Ye IN MO V1 12
Sourtss. Thomson Financ+avSaseitne
Last year, a record 50 golf courses suffered severe financial distress, resulting in their foreclosure, conversion to
other use or fire sale. There are no figures available yet for 2003, but there are plenty of horror stories. Barron's
has learned, for example, that in June a high -end, daily -fee course in Houston, the Fish Creek Golf Club, was
handed over to lender Woodforest National Bank, which had a $6.5 million loan on the year -old, $14.5 million
property. Among the equity holders who took a bath on the course were golf nut and entrepreneur Charles
Schwab, and the Australian -born touring golf pro Steve Elkington, designer of the course's 27 holes. A
spokesman for Schwab had no comment, and Barron's couldn't reach Elkington or a Woodforest spokesman.
Early this year, the Thunderbirds Golf Club in Phoenix was bought out of foreclosure by a group of local investors
for $4.8 million. The previous owners had plowed nearly $15 million into the complete refurbishment of the course
just a few years before but never could garner sufficient revenues to make a go of it.
Then there are the trials and tribulations of golf- course real- estate investment trusts, which grossly overpaid for
properties during the 1990s. The biggest — National Golf Properties — was taken private late last year by an
investment group led by a Goldman Sachs affiliate, after running into income problems and suspending its
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' dividend. Golf. Trust of America, a onetime highflier, has been liquidating its portfolio of-courses after severe
operating shortfalls. Gotham Partners, a New York hedge fund, is in the process of closing two of its principal
investment vehicles, in large part because of its troubled golf-course operating unit, Gotham Golf.
A hedge -fund manager who was once a College All- American golfer and follows the sport closely, estimates that
more than 400 courses currently are for sale at prices sharply under their construction costs or recent sale prices.
Nearly all are "daily fee" courses, which accounted for the majority of new construction in the past two decades.
Today privately owned courses that charge daily fees account for more than 9,000 of the nearly 16,000 golf
' facilities in the U.S.
The story is much the same in the golf equipment and apparel industries, though the carnage hit earlier than in
' golf real estate. Zany expansion in the mid -1990s quickly sated the market for titanium drivers, fancy golf duds
and the like. Apparel brands such as Carlyle Golf and Glengate Apparel are now but distant memories, as are
equipment makers Black Rock, Snake Eyes, Coyote Sports, TearDrops and Arnold Palmer Golf. All either filed for
Chapter 11 bankruptcy protection, were sold for peanuts or survive as zombie companies in the pink - sheets stock
market.
The latest equipment company to hit the skids is Top -Flite Golf, once known by the iconic name of Spalding. A
onetime leader in golf balls, the company filed for Chapter 11 protection last month, laid low by savage
competition in the ball market, an ill- starred expansion into premium-golf-club manufacturing and a heavy debt
burden that dated to Spalding's leveraged buyout by Kohlberg Kravis Roberts in 1996. KKR eventually wrote off
more than $400 million in equity it had injected into Spalding. Callaway Golf has bid $125 million for Top- Flite's
golf -ball operations, though Germany's adidas - Salomon topped that offer by $1 million last week (see story
below).
The reasons for the current slump in golf are myriad, and both obvious and subtle. For one thing, the golf
' "industry" in the 1990s enjoyed an explosion in revenues, and the prices of courses and club memberships to a
degree mimicked the stock markets breathtaking lift -off. Greens fees at daily -fee courses tripled to $60 or more
by the end of the decade, even after adjusting for inflation. At the most exclusive clubs, greens fees of more than
$200 a round became common. For non - high - rollers, MGM Mirage's Shadow Creek course in Las Vegas charges
1 $500 a round.
•
Initiation or membership fees at many private clubs went on a similar tear. Memberships in the Bridge, in tony
' Bridgehampton, N.Y., went for $500,000 apiece last year, when designer Rees Jones finished the stunning
course overlooking Long Island Sound. The club has 80 members. Dues and other charges at Jack Nicklaus' The
Bear's Club in Jupiter, Fla., are nearly $20,000 per annum. Members get to rub shoulders with Jack and his
family, who live nearby, and enjoy the Lucullian splendors of the 35,000- square -foot, Tuscan -style clubhouse,
' replete with Nicklaus memorabilia and a giant stuffed polar bear.
As a result of the sour economy, however, many golfers, and would -be golfers, no longer are in a position to
shoulder golfs inflated costs. Stock- market losses have crimped the incomes of many seniors, which means the
demographic cohort best known for its "frequency" of play has had to cut back.
Corporations, a key market for country clubs and high -end daily -fee play, likewise have pulled in their horns.
Companies are slashing expense accounts and have been more reluctant these days to hand out free country-
club memberships and sponsor client golf outings and meetings at fancy clubs. Destination -resort areas such as
Phoenix, San Diego and Orlando have suffered mightily as a result.
' Tougher times have bolstered the work ethic, too. "In today's economy, people are genuinely worried about
. keeping their jobs and far less likely to slip out of the office early to sneak in a round of golf," says Terry
McAndrew of Phoenix -based Golfbiz.net. •
' As a result, price cutting has become rampant in the golf business, which has only exacerbated the industry's
revenue woes. Many clubs have chopped their greens fees, though the reductions often are disguised by a welter
of sub rosa discounting schemes such as "play three rounds and get one for free."
' "As in the hotel business, almost nobody pays the rack rate to play golf these days," says Jim Koppenhaver of
Pellucidcorp.Com, a golf- information service based in suburban Chicago. "Rates at many courses are being
discounted as much as 35 %." j
1 Tom Patrick, a golf vice president of SunCor, an Arizona development company, and head of the Golf Industry
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Association of Arizona, estimates that the Phoenix area's golf revenues are down by 25% to 35% from peak
levels hit in 2000. Much of this shortfall is a result of price- cutting to attract local golfers to replace business from
corporations and leisure travelers, Patrick says.
INITIATION PRICES AT MANY PRIVATE CLUBS also have been dropping, in an effort to attract new members
and allow existing members to exit at will. (At many but not all clubs, members can sell their memberships and get
back their initial outlays minus, say, a 10% or $25,000 transfer fee that goes to the club.) Golf - industry sources
• say that some members seeking to sell their memberships in Nicklaus' Bear's Club have requested that the club
drop its initiation fee from $350,000 to $250,000. Club officials wouldn't confirm this. Club memberships are a
prototypical insiders' market.
Meanwhile,.some newer clubs are having a tough time selling their full quota of memberships. Silverleaf, an '
acclaimed course designed by Tom Weiskopf in North Scottsdale, Ariz., which features special Augusta, Ga.,
sand in its traps and Amish rakes to pamper them, has been able to sell only 80 of 350 memberships that it is
offering at $145,000 each. The net number of new members likely is far lower, since some new members
apparently have exercised a six -month right of rescission and sold their memberships back to the club at full
price.
Golfs problems aren't only on the demand side. During the 1990s a surge in golf- course construction created an
oversupply. According to Pellucid's Koppenhaver, around the middle of the decade the rate of new capacity
additions began to outpace the rise in rounds played. For a time, the economic boom disguised the growing
disequilibrium. Golfers, Flush from rising real incomes and stock - market gains, willingly fattened the coffers of
course owners by paying ever - higher greens and guest fees and golf -cart rental charges. Then the post - bubble
slowdown exposed the tenuous fundamentals of U.S. golf.
According to Koppenhaver, last year's total of 220 new courses, though materially below the 2000 record of nearly
400 new courses, still exceeds golfs annual absorption rate by a goodly measure. This year's expected addition
of 237 new courses will only make matters worse. Yet he doubts the golf industry will exercise requisite self -
control anytime soon.
For one thing, the glamor of building and owning your own golf course can lead to the same suspension of sound
business practices as financing a Hollywood movie. Also, more than three quarters of the courses under
construction today are part of larger real- estate projects. The golf course is an "amenity" that is supposed to sell
the residential lots and homes surrounding it at a premium price. And with residential real estate hot, developers
are making so much money from lot sales that they can more than cover the costs of a money - losing golf
operation.
"Developers don't have the same economic incentives as builders and owners of stand -alone golf courses," says
golf consultant Gene Krekorian of the Los Angeles office of Economics Research Associates. 'They don't care if .
they lose money on the golf course because the higher prices they garner from lot sales more than subsidize the
loss. What is irrational for the golf- course owner — operating at a loss — is rational for the developer."
Once a developer completes a golf- course community, it often dumps the course and club house on the residents
of the community or an outside management company. Then the golf operation deteriorates when the club loses
its original benefactor. The beautiful tableau of green sward, amply fertilized and watered and mowed daily,
becomes punishingly costly to maintain. Yet golf remains the amenity of choice, though some developers are
starting to embrace more environmentally friendly and cheaper alternatives, like nature preserves and wetlands.
This transition is likely to be slow, however.
Bank financing for new courses is fast drying up, particularly for stand -alone units. Many in the golf industry blame '
the bank - credit freeze on a front -page story in July 2001 in the New York Times. It described a wave of golf -
course bankruptcies at golf -crazy Myrtle Beach, S.C. But the article was only the proverbial messenger of bad
1 news. It's the wave of golf- course loan defaults that since has spooked many lenders.
Horror stories abound. This spring, Las Vegas gambler and sports- betting operator Bill Waiters was informed by
Wells Fargo Bank that it plans to call a $32 million loan early next year. The loan stemmed from his purchase of
the Stallion Mountain Country Club in the late 'Nineties, and he'd never missed a payment. Wells Fargo declined
to comment.
Unable to find alternative financing, Walters now is trying to self two of the three golf courses in the Stallion
Mountain community to developers to cover the loan. Residents are balking at the increase in population density
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that the sales could engender.
1
Would a pick -up in economic activity revive the golf industry's fortunes? Some golf experts, like John Rooney, a
professor of geography at Oklahoma State University, aren't so sure. Rooney has written extensively on golf
' history and current developments in the sport, and runs his own golf - consulting service, Longitudes Group LLC.
IN HIS COURSE "The Geography of Sport," Rooney has noted a societal change: the increasing amount of time
that parents and even grandparents spend watching the sports and cultural activities of their children. According
to Rooney, playing Soccer Mom or Dance - Recital Dad saps as much as 25% of adult recreational time that might
otherwise be devoted to golf. "When I was growing up in Kankakee, III., my father rarely attended any sporting
event I played in, because it would have cut into his golf and fishing," says Rooney, 63. "These days, however,
1 time- stressed parents increasingly are devoting their weekends to their children, which doesn't bode well for golf. •
At five to six hours a round, golf involves a time commitment many folks are no longer willing to make."
Despite the swell of aging boomers, other U.S. demographics might not favor the sport. Golf has made little
' headway in the black and Hispanic communities, notwithstanding Tiger Woods' celebrity or the Professional Golf
Association's First Tee program, designed to expose minority youth to golf. Rooney and other experts blame
several factors for this failure, including the paucity of available courses near major cities and, for many, golfs
prohibitive costs.
1 One can't help but wonder, too, whether golf increasingly is out of step with today's decidedly unleisurely lifestyle.
"Golf doesn't lend itself to PDAs, 24/7 connectivity and long to-do lists," says Mike Turnbull, a former golf pro and
vice president of Tee Master, a phone and on -line tee -time booking service for more than 80 golf courses in
Minnesota. Business is down some 25% from peak levels of several years ago, in a state that boasts the most
courses per capita in the U.S., Turnbull notes.
Golf has always had its critics, yet succeeded spectacularly. In the late nineteenth century, during the Gilded Age,
when the first spasm of golf- course construction began in the U.S., Mark Twain sourly dismissed the sport as "a
good walk spoiled? Yet that building boom lasted, with a short hiatus during World War I, all the way to the onset
of the Depression.
The current decline could prove cyclical, as well. But ifs apt to be a long, lugubrious cycle. If you enjoy the game,
by all means play. But beware the sand traps if you invest.
1 The Great Investment Sand Trap
IN THE 19905, STOCK ANALYST Bud Leedom published a newsletter called Golf Insight & Investing, which
tracked about 50 publicly traded companies, most riding the hot IPO market and hype surrounding golf phenom
Tiger Woods. But he folded the endeavor three years ago, as the number of investment -grade stocks still trading
dwindled to five or so. "It's been a complete disaster," says Leedom, who now works at Wells Fargo Securities.
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Sales of golf equipment peaked several
years before the decline in new-course
construction-
. Chubs In Sets 70
(theesa
50
Utility Clubs 80
(tbouaanaa) 60 1
40
20 .
Bab (dozen) 60
(tb0.1448de) 50
1
'90 '94 '98 '02
Total Sales (mil)
Product 2002 1990
Clubs (sets) $1,563.8 S1,363.5
Clubs (indiv.) 476.3 149.5
Golf Balls 693.3 615.1
Source' Nartonel Sporting Goods Aosn. '
While Fortune Brands' golf sales am .
growing. Callaway is tadng rougher times.
GOLF STOCKS
$60
Fortune Brands 40 1
30
20
1 Callaway Golf 10
'98 '99 '00 '01 '02 ° •
Source" Thomson Fincl)Bssesne '
Just ask shareholders of Callaway Golf, the No. 1 seller of golf clubs, which in its day was the Tiger Woods of golf '
stocks. After soaring 600% from its 1992 IPO through 1997, the stock lost about 50% of its value. These days it
changes hands at 15, roughly half its all -time high.
Callaway, at least, is among the quick, which is more than you can say for Family Golf Centers, a driving -range
owner that filed for bankruptcy protection in 2000 and now is liquidating. Golf Trust of America, a former real -
estate investment trust, also has been selling its tony courses and plans to dissolve.
Why has the world of golf investing grown narrower than a fairway at the U.S. Open? Chiefly, the industry's 1
growth prospects fail to impress. In 2002, retail sales of golf balls and clubs totaled about $3 billion, according to
the National Sporting Goods Association. Double -digit gains seem unlikely right now.
For one thing, golfers aren't hitting the links as much as they did a few years ago. Rounds played in the U.S. fell
3% last year and are expected to fall again in 2003. Plus, golfs an expensive sport; with top -of- the -line drivers .
fetching around $400, it's easy to hold on to clubs for an extra year or two. '
In the early to mid- 1990s, Callaway's Big Bertha and other oversize woods revolutionized the sport. But there
hasn't been a major technological breakthrough since. Only golf balls have benefited from cutting -edge
. technology, and now fly farther but are easier to control. Yet U.S. ball sales totaled less than $900 million last
1
year, according to the National Sporting Goods Association — the smallest tally since 1998.
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These grim statistics haven't hurt one golf - related company, however. Fortune Brands, a Lincolnshire,
conglomerate, makes Titleist balls and clubs, Cobra clubs and FootJoy shoes and gloves, which chipped in 18 %,
or $1 billion, of '02 revenues. (Fortune's other divisions are spirits and wine, home and hardware, and office
products.)
Fortune earned $526 million, or $3.19 a share, on $5.7 billion of revenues in 2002. This year analysts expect the
company to net $3.63, while CEO Norman Wesley is targeting low- to mid - single -digit profit growth for the golf
' division. In the second quarter, sales of golf merchandise rose 11%, to $372 million.
Fortune's Titleist and Pinnacle golf -ball brands boosted their market share in dollars to a combined 57.7% in May,
five points higher than a year ago, according to Golf Datatech, a research firm in Kissimmee, Fla. Cobra, too,
made significant market -share gains in the past year, thanks partly to the brand's SS Titanium driver.
Long -time holders of Fortune Brands have made a tidy fortune. The stock has been climbing, with few setbacks,
' for 25 years. At a recent $57 the shares still look reasonable, however, selling for 15.7 times this year's estimated
net. Kevin Grant, co- manager of the Oakmark Fund, thinks there is "too much of a conglomerate discount in the
shares." The fund holds 1.75 million shares.
' Callaway, like Fortune, trades near a 52 -week high. But its shares aren't particularly cheap at 14.4 times next
year's expected earnings, given the challenges facing the company's golf -ball business. Launched in February
2000, the ball venture has been a steady drain on profits, and cost Callaway 24 cents a share in profits last year.
The company earned $69.4 million, or $1.11 a share, in 2002, on revenues of $792 million. Management is
1 forecasting 95 cents in earnings this year on flat revenues.
Callaway, which boasts endorsement deals with Arnold Palmer and Annika Sorenstam, last month announced a
tentative deal to acquire Top- Rite, a maker of clubs and balls, out of bankruptcy, for $125 million. The move
would put Callaway on a par with Fortune Brands in golf revenues and catapult it into second place in the
competitive golf -ball market. CEO Ronald A. Drapeau says a Top - Flite deal would be accretive next year, thanks
to projected cost savings.
Even if the Top -Flite deal doesn't proceed — adidas- Salomon last week offered $126 million — Drapeau believes
there are "other viable ways "to cut losses in the golf -ball business. But he declined to elaborate.
With $137 million in cash and no long -term debt, Callaway has ample funds to pay for Top-Fhte. But concerns
remain. Leedom, who rates the stock a Hold, noted recently that "the integration and restoration of growth will be
highly challenging."
1 Our scorecard: Put Fortune Brands in your bag, but pass on Callaway for this round.
— Lawrence Strauss
1 Lawrence Strauss is a senior editor at Barron's Online.
•
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1 8/1/03
Exhibit 3 •
STATE OF CALIFORNIA
F nit l Governor's Office of Planning and Research 1
'e
1400 TENTH STREET SACRAMENTO, CALIFORNIA 95812 .
1
1
Message from the Director
The 1998 Edition of the General Plan Guidelines constitutes the most complete discussion of '
California's land use planning statutes that the Governor's Office of Planning and Research has ever
published. It has been comprehensively updated, with new information on topics ranging from air
quality to zoning, and new references to agencies and their internet sites. In this edition, the Guide-
lines is a. comprehensive guide for preparing a practical and useful general plan.
Over the years, the plannine staffs of cities, counties, and other planning agencies, as well as '
elected officials, planning consultants, and interested residents have relied upon the General Plan
Guidelines for advice when preparing their local general plans. I ani confident that the 1998 edition
will be the most useful yet.
1
Paul F Miner '
Director
1
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1
1
1
1
1
1
1
Chapter 3: The Required Elements of the General Plan
C. Building Intensity However, because the purpose of the land use element is
I The Camp decision also held that an adequate gen- to designate "the proposed genera' distribution and
eral plan must contain standards for building intensity. general location and extent" of land uses, the element
Again, the Twain Harte court has provided the most must identify future sites.
complete interpretation of building intensity available to The identification of future solid waste disposal
I date. These are its major points: intensity should be sites is particularly important when preparing or imple-
defined for each of the various land use categories in the mentinglnlegrated Waste Management Plans (1WMPs).
plan; general use captions such as "neighborhood com- Public Resources Code §41720 now requires that the
I mercial" and "service industrial" are insufficient mea- 1WMP's countywide siting element, including any areas •
sures of intensity by themselves; and, building intensity identified for the location of a new or expanded solid
is not synonymous with population density. Intensity waste transformation or disposal facility, be consistent
I will be dependent upon the local plan's context and may with the applicable general plan.
be based upon a combination of variables such as maxi-
mum dwelling units per acre, height and size limitations, E. Circulation
and use restrictions. Unfortunately, the court stopped The Twain Halle and Concerned Citizens decisions
I short of defining what are proper measures of building also discussed the close relationship between the land
intensity. use and circulation elements. Pursuant to the decisions
Local general plans must contain quantifiable scan- of the Concerned Citizens, Twain Harte, and Camp v.
dards of building intensity for each land use designation. Mendocino courts, the general plan must reflect both the
I These standards should define the most intensive use anticipated level of land development (represented in
that will be allowed under each designation. While the the land use element) and the road system necessary to
I land use designation identifies the type of allowable serve that level (represented in the circulation element).
uses, the building intensity standard will define the The road system proposed in the circulation element
concentration of use. Intensity standards can include must be "closely, systematically, and reciprocally re-
provisions for flexibility such as density bonuses, clus- fated to the land use element of the plan." (Concerned
I ter zoning, planned unity developments, and the like. Citizens, supra, at p. 100)
OPR recommends that each intensity standard in-
elude these variables: (1) permitted lands uses or build- F. Noise
I ing types; and (2) concentration of use. Permitted uses According to §65302(f), the noise element is to be
and building types is a qualitative measure of the uses used as "a guide for establishing a pattern of land uses in
that will be allowable in each land use designation. The the land use element that minimizes the exposure of
I concentration of use can be defined by one or more community residents to excessive noise." When the
quantitative measures that relate directly to the amount noise element is inadequate ,tlielanduseelementmaybe
of physical developmentthat will be allowed. Maximum invalid, as in the Camp case.
dwelling units per acre is a good residential standard.
I Floor area ratio (the ratio of building floor area to the Relevant Issues
total site area) is a useful measure of commercial and This discussion offers a general guide to the con -
industrial intensity. The dual standard of maximum lot tents of the land use element. Note that while the focus
I coverage and maximum building height is suitable for ' is on the minimum requirements for an adequate land
agricultural, open- space, and recreational designations use element, an effective general plan will focus on those
. where development is being limited. On the other hand, issues of greatest relevance to the community.
lot size, which has been widely used for agricultural and The purpose of the land use element is to designate
open -space designations, is an inadequate standard of "the proposed general distribution and general location
building intensity because although it regulates lot area, and extent of uses of the land." The land use element
I it does not quantify the allowable concentration of should focus on the future growth and physical develop -
development on each lot. ment of the community and planning area.
A land use element should contain a sufficient
U. Solid Waste Sites number of land use categories to conveniently classify
I Concerned Citizens v. Calaveras County (1985) the various land uses identified by the plan. Land use
166 Cal.App.3d 90, held that the general plan is not categories should he descriptive enough to distinguish
required to identify existing solid waste disposal sites. between levels of intensity and allowable uses and there
' General Plan Guidelines 39
0I -0T -2003 03:45P31 FROM-Shute. Mihaly 4 Weinberger UP. +4155525816 T -021 P.004 /00T F -571
ACTON • Exhibit 4 '
MICKELSON •
ENVIRONMENTAL, INC. '
Consulting Scientists, Engineers, and Geologists
September 5, 2001 '
Ms. Stefani Olivieri '
Mountain Area Preservation Foundation
P.O. Box 971
Truckee, California 96160 90048.01 1
Subject: Document Review: Ground Water Availability
in the Martis Valley Ground Water Basin '
•
Dear Ms. Olivieri:
Acton • Mickelson • Environmental, Inc., has reviewed at your request the document entitled t
Ground Water Availability in the Martin Valley Ground Water Basin (Nimbus Engineers, 2001)
[Basin Study]. This letter provides our comments on the review of the document. '
Two approaches to estimating safe yields from ground water basins are the use of a hydrological
budget model and the use of a calibrated numerical model. The use of the hydrologic budget '
approach to estimate safe yields from a basin, as was done in the Basin Study, is "fraught with
problems" (Freeze and Cherry, 1979 [page 207]). As discussed in the ensuing comments, there
is much uncertainty in many of the budget inputs, and in this case, the budget inputs seem to rely
considerably upon the judgment of personnel at Nimbus Engineers (Nimbus) rather than on '
•
objective data or information available in published literature.
The ground water in the Basin was assumed to be in a steady state condition (Basin Study, 1
page 14). As such, recharge equals discharge in Equation 1 (Basin Study, page 13) because in
long-term, steady state conditions, the water in storage is constant (i.e., changes in storage are
zero). Observed changes in storage are in response to short-term deviations from average 1
conditions. Increased discharge through increased ground water extraction will result in a
lowering of the water table.
The safe yield of a basin is the amount of ground water that can be withdrawn without causing 1
the following:
• Depletion of ground water reserves '
• • Contravention of existing water rights
• Deterioration of economical advantages of pumping
• Excessive depletion of streamflow '
• Land subsidence
• Intrusion of water of undesirable quality
5050 Robert J. Mathews Parkway Oi.20o'd°`
Et f)orado Hilts, California 95762 (916) 939 ,
Fax (916) 939.. 7570
1
1
OT- 0T-2003 03:47PM FROM -Shun, Mihaly i %inbrrar LLP. •4155525616 T -621 P.005 /007 F5T1
Ms. Stefini Oliurieri
September 5, 2001
1 Page 2 •
The development of a calibrated numeric model to simulate the ground water Basin is a better
approach to managing the Basin than the water balance approach, especially in light of plans to
rely on increased use of ground water to supply to growing. water needs for Truckee and
' elsewhere in the region.
Specific comments regarding the Basin Study's estimation of recharge and safe yield are
enumerated below:
'
• Page 11, last sentence. Hydro - Search, Inc. designated ten zones (A through J) that
were estimated to have similar ground water recharge and movement. The Zones are
1 shown on Nimbus Figure 3. The text (Basin Study, page 11) indicates that Bennett
Flat and Juniper Flat were "...underlain by predominantly volcanic rocks with
•
significantly less storage potential than the deep alluvial Basin and are not included in
this ground water storage calculation." Bennett Flat is in Zone F and Juniper Flat in
Zone E. Table 2 and Figures 17 and 18 indicate Zones E and F were indeed included
in the ground water storage calculation.
1 • Page 13, last full paragraph. This paragraph seems to imply that the lower water table
resulting from increased ground water extraction is only temporary, and that the
change in storage will recover once the system re- establishes equilibrium. This is not
correct. The rate of change of storage will recover, but the water table will remain
depressed as long as the increased pumping continues.
1 • Page 17, 2• Paragraph. This paragraph classifies the four hydrologic soil types (A,
B, C, D) into three categories (favorable, moderate, and not favorable)_ Type A soil
has the most rapid infiltration rates, Type D the slowest. Types A and B were
classified as favorable, Type C moderate, and Type D unfavorable. Types B and C
may be more appropriately classified as moderate, since these values lie between the
upper and lower values. Figure 8 shows most of the soils in the Basin are Type B. If
1 the Type B soils are improperly classified as favorable, then the estimate of the
amount of ground water recharge and the estimate of water available for extraction
could be overestimated.
1 • Page 17, 3` Paragraph. Classifying the Basin fill volcanic unit as moderate may •
result in an overestimation of recharge. The volcanic rocks are shown on Figure 4 as
being aquitards. These aquitards were noted on page 11 as being relatively competent
in limiting the transfer of shallow ground water to the middle/lower aquifer system.
The volcanic rocks were also described on page 11 as having "significantly less
storage potential" than the alluvium. These data suggest that the permeability of the
volcanic rocks is much lower than the alluvium, probably on the order of one to
several orders of magnitude. However, the recharge difference between favorable
1 ACTON •
MICKELSON •
ENVIRONMENTAL, INC. of -204 doe
Consulting Scientists, Engineers, and Geologists
1
1
07 -01 -2003 03:I7PM FROM - Shute, Mihaly & Weinberger LLP +4155525116 T121 P.006100? F-571
Ms. Stefan Olivieri '
September 5, 2001 '
Page 3
and moderate was only 22 to 26 percent (Table 1). The much lower permeability 1
associated with the volcanic rocks may warrant classification as not favorable.
• Page 17, 5'h Paragraph. It is suspected that precipitation recharge efficiencies are ,
seldom as high as 65 percent and can be less than 11 percent (e.g., over bedrock). In
Table 1, the assignment of recharge efficiencies appears to be overly judgmental.
Under the least favorable conditions, a recharge efficiency of' 15 percent was used ,
(Table 1), and over the entire Basin, a recharge efficiency of 25.3 percent was used
(Table 2). A Basin -wide recharge efficiency of 25.3 percent is greater than the
11 percent value referenced in literature (Berger, 2000). (Eleven percent was likely '
for the Basin as a whole, not just the most unfavorable portions since the (Berger,
2000] study was titled "Water Budget Estimates _for the 14 Hydrographic Areas in the
Middle-Humboldt River Basin ") Four out of five of the assigned recharge '
efficiencies in the Basin Study exceed 33 percent (Table I). Therefore, the one
literature attained value of 65 percent, which does not appear to be published or peer -
reviewed. unlike the other references cited, was used to adjust recharge efficiencies '
upward. Because the literature attained values are so highly variable, assessing the
amount and spatial distribution of recharge may best be accomplished via calibration
of a numeric model.
• Page 18, last paragraph. The uplifted basement rocks to the south were estimated to
contribute 5,336 acre feet per year (AF /yr) of ground water (Tables 7 and 8). Ground
water recharge from the watershed upgradient of the Basin was included in the water ' 1
balance. These aspects of the Basin Study are inconsistent with other statements in
the study. On page 7, it was stated that "Basement rocks in the Truckee Area
typically contain, transmit, and yield relatively small quantities of ground water." '
The basement rocks are not anticipated to contribute significant ground water to the
Basin for the reasons stated on the first paragraph of Section 7.11.2. It is not clear
why ground water recharge from the watershed upgradient of the Basin was included '
in the water balance when, as stated on page 23, "No ground water transfer into the
basin was included from these areas."
• Page 21, Section 7.9.1. Literature presented values of ground water contributions to 1
the Truckee River ranged from 8;180 to 12,000 AF /yr, but the water balance used a
much greater value of 20,207 AF /yr (Table 8). Nimbus then used this value as part of
the ground water that is available for extraction (Table 12). The greater Truckee 1
River ground water discharge value was calculated by balancing inputs and outputs.
As discussed above, the inputs may be artificially inflated by • and Y precipitation recharge
possibly by the ground water transfers into the Basin. Therefore, the ,
amount of water available for extraction, assuming it is acceptable to stop all ground
water discharge to the Truckee River, would also be inflated.
ACTON - 1
MICKELSON -
ENVIRONMF.NTAL, INC. e1-20e.doc •
Consulting Scientists, Engineers, and Geologists 1
1
1
01 -0t -2003 03:47PM FROM - Shute. Mihaly i Weinberger LLP. X4155525316 T -OZI P007/OD7 F -571
Ms. Stefan Olivier' •
September 5, 2001
Page 4
' • Table 7 and Figure 11. There are some discrepancies between Table 7 and Figure 11.
For example, on Figure 11, Zone A is noted to loose 854 AF /yr to Zone B, and
977 AF /yr to Zone D for a total of 1,831 (the value in Intrabasin GW Transfer Out
' [Table 7]). Figure 11 indicates Zone B only receives lntrabasin GW transfers from
Zone A, yet the Intrabasin GW transfer into Zone B is 1,981 AF /yr, not the 854 AF /yr
provided by Zone A. An explanation for the difference is not provided.
• Table 12. The volume of ground water available for extraction (24,701 AF /yr) was
calculated using all of the ground water that was estimated to provide flow to the
' Truckee River, Prosser Creek, and contribute to Prosser Creek Reservoir. For this
approach to work, the water table would uniformly have to be lowered to the thalweg
elevation of these current ground water discharge points. In reality, pumping will
create cones of depression that will create an uneven water table surface. Portions of
the streams that were ground water discharge reaches will become ground water
recharge reaches.
1 Please call should you have any questions regarding the information presented.
Very truly yours,
1 ACTON • MICKELSON • ENVIRONMENTAL, INC.
a cAs
Walter D. Floyd, R.G., C.HG.
California Registered Geologist #6092 Michael A. Acton, R.E.A.
California Certified Hydrogeologist #493 Vice President
1 WDF:MAA:ddb
cc: Mr. Richard S. Taylor, Shute, Mihaly & Weinberger LLP
1
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1 ACTON •
MICKELSON -
ENVIRONMENTAL, INC. or- roa.Ox
Consulting Scientists, Engineers, and Geologists
1
1
__ Exhibit 5 1
GRAY OAYIS Canal 6 '
wir- oESAuroRN,N..TH�S °i EiAGEtICY _a
DEPARTMENT OF FISH AND GAME
SACRAMENTO VALLEY AND CENTRAL SIERRA REGION _ '�
1701 NIMBUS ROAD. SURE A _ , - '
RANCHO CORDOVA. CALIFORNIA 96670 i.3
Tehplwne 19161 369.2900 ,, ,i 7,
` :
itlinm
July 15, 2003
Ms. Heidi Scoble, Associate Planner
Town of Truckee '
10183 Truckee Airport Road
Truckee, CA 96161
Dear Ms. Scoble:
The Department of Fish and Game (DFG) has reviewed the Draft Environmental ,
Impact Report (DEIR) for Gray's Crossing Specific Plan/Tentative Map
(SCH# 2002072115). The project proposes development of a 757 -acre site into a
planned development comprised of commercial and residential uses including a golf '
course. The site is located just north of Interstate 80 and is bisected by
State Highway 89 in the Town of Truckee, Nevada County.
Significant resources of the project site include habitat for sensitive species and
movement areas for local resident wildlife. Habitats of the project site, dominated by an
overstay of pine with an understory of sagebrush bitterbrush and grasses, although not
unique, are locally and regionally significant and further loss of these habitats is viewed ,
by the DFG as a significant impact. The DEIR has identified a series of mitigation
measures designed to reduce project impacts to vegetation and wildlife and the
document further concludes that project impacts to vegetation and wildlife, with
incorporation of the identified mitigation measures, will be reduced to levels of less than
1
significant.
Mitigation measures for project impacts to vegetation and wildlife as identified in '
the DEIR reflect measures designed solely to avoid direct impacts to special status
species during project construction. Alternatively, mitigation measures for impacts to '
the habitats of the project site are deemed not to be warranted due to the common
nature of the habitat. We disagree with conclusions and mitigation measures identified
in this DEIR for vegetation and wildlife and find the document inadequate and '
incomplete. While identified mitigation measures may reduce direct project impacts
during project construction the value of retained areas subsequent to project
construction, due to indirect impacts and the direct loss of habitat currently occupied by
both sensitive and local endemic wildlife will be irretrievably lost. The document has
failed to identify any measures designed to mitigate direct, indirect, and cumulative
project impacts to the Many hundreds of acres of native habitat and associated wildlife 1
species directly, indirectly, and cumulatively impacted as a result of project
implementation.
1
z d aoeaLLtrOCS z uoi908 ees.o1 co az Inc 1
Ms. Scoble
July 15, 2003
Page 2
1
We believe that the failure of this DEIR to identify additional reasonable and
1 feasible mitigation measures for project impacts to native habitat and sensitive species
results in direct, indirect and cumulative project impacts to native habitat and associated
species and movement corridors for local resident species to remain significant.
1 We suggest development of a mitigation measure that allows for the creation of a
land acquisition /easement program and the creation of a mechanism by which land is
acquired via developer fees and other funding sources. This can be a parcel or acre
based program. This program would focus on acquisition (fee title or easement) and
management in perpetuity of adequately sized and suitable habitat areas for all wildlife
species within a reasonable distance from the project site. The DFG believes this to be
1 a reasonable and feasible mitigation measure.
Additionally, we suggest that acres of Open Space be recalculated to reflect
those sites potentially available and useful to the array of wildlife using the site, such as
those open space areas situated on the perimeter of the project, and those open space
areas that will be significantly compromised, such as those open space areas
intermingled with urban uses including the golf course- This type of accounting will
allow for a more reasonable measurement of project impacts to both sensitive and more
common wildlife within the project site.
1 Thank you for the opportunity to review this project. If we can be of further
assistance, please contact Mr. Jeff Finn at (530) 477 -0308 or Ms. Terry Roscoe, Habitat
I Conservation Planning Supervisor at (916) 358 -2382.
SincereQ; ,
1 Larry - Ph.D.
Deputy 'egional Manager
cc: Ms. Terry Roscoe -
1. -Mr. Jeff Finn
Mr. Jim Lidberg
Department of Fish and Game
Sacramento Valley - Central Sierra Region
1701 Nimbus Road, Suite A
Rancho Cordova, California 95670
State Clearinghouse
1400 Tenth Street
Post Office Box 3044
Sacramento, CA 95812 -3044 (only if came from clearinghouse)
1
E' 60 oLE LI'OES 2 uoi2ad e6S :01 CO ea Int