HomeMy Public PortalAboutCanyon Springs EIR Scoping - 13.pdf05/13!2011 16:23 5305442271
LAHONTAN
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California Regional Water Quality Control Board
Lahontan Region
Lindn S. Adams 2501 Lakc Tahoe Bvj1c,a *d, Sou Lake 7ahnc, Cdilomia 46130 tidmundG• Brown 3r-
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May 18, 2011
Denyelle Nishimori
Truckee Community Development Departmen
10183 Truckee Airport Road
Truckee, CA 96161
COMMENTS REGARDING THE NOTICE OF PREPARATION OF A DRAFT
ENVIRONMENTAL IMPACT REPORT FOR THE CANYON SPRINGS SUBDIVISION
PROJECT, NEVADA COUNTY (STATE CLEARINGHOUSE NO. 2004052060)
California Regional Water Quality Control Board, Lahontan Region (Lahontan Water
Board) staff received the Notice of Preparation (NOP) of an environmental document for
the above - referenced project (Project) on April 19, 2011. The proposed project involves
developing 177 market -rate single family lots and 8 affordable housing lots on 283.76
acres within the north - eastern comer of the Town of Truckee's boundaries.
Our comments are submitted in compliance with Califomia Environmental Quality Act
(CEQA) Guidelines, California Code of Regulations, title 14, section 15096, which
requires responsible agencies to specify the scope and content of the environmental
information germane to their statutory responsibilities, and lead agencies to include that
information in their Environmental Impact Report (EIR).
The State Water Resources Control Board (State Water Board) and the Lahontan Water
Board regulate discharges of waste to protect the quality of waters of the State, broadly
defined as "the chemical, physical, biological, bacteriological, radiological, and other
properties and characteristics of water which affects its use" ( Califomia Water Code
§13050). The Lahontan Water Board implements the Water Quality Control Plan for the
Lahontan Region (Basin Plan) and is a responsible agency pursuant to CEQA for the
proposed project. As such, the Water Board must ensure compliance with CEQA when
taking discretionary actions on this project.
Water Board staff, acting as a responsible agency, has reviewed the information
provided in the NOP in context to the proposed Project's potential impacts to water
quality and beneficial uses of Waters of the State. There a number of potentially
significant impacts to water quality and water resources that must be adequately
addressed in the environmental review. Without adequate mitigation, Project
implementation could result in significant adverse impacts to water quality and may
result in cumulative impacts that have the potential to permanently alter the hydrological
and ecological function of the aquatic water resources within the Project area, thereby
adversely affecting beneficial uses of waters of the State.
California Eiwironmental,Protection Agency
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AUTHORITY
State law assigns responsibility for protection of water quality in the Lahontan region to
the Lahontan Water Board. The Basin Plan contains policies that the Water Board uses
with other laws and regulations to protect water quality within the region. All surface
waters and ground waters are considered waters of the State. Surface waters include,
but are not limited to, drainages, streams, washes, ponds, pools, or wetlands, and may
be permanent or intermittent. All waters of the State are protected for beneficial uses
under California law. Additional protection may be provided for waters of the United
States (U.S.) under the Federal Clean Water Act (CWA) if the waters in the area are
federally jurisdictional. Based on our review of the NOP, project components may
involve alteration, dredging, filling, and /or excavating activities in waters of the State.
Such activities constitute a discharge of waste', as defined in California Water Code
(CWC), section 13050, and could affect the quality of waters of the State.
The State Water Resources Control Board (State Water Board) and the Lahontan Water
Board regulate discharges in order to protect the water quality for beneficial uses of
waters of the State. The Basin Plan provides guidance regarding water quality and how
the Lahontan Water Board may regulate activities that have the potential to affect water
quality within the region. The Basin Plan includes prohibitions, water quality standards,
and policies for implementation of standards. The. Basin Plan can be accessed via the
Water Board's web site at
We request that the environmental document analyze compliance with policies in the
Basin Plan in the hydrology, biological resources, and water quality analyses and
require that the Project proponent comply with all applicable water. quality standards and
prohibitions, including provisions of the Basin Plan concerning industrial wastes,
wetlands, floodplains, construction activities, and land development.
PERMITS
A number of activities associated with the Project may require permits or other orders
issued by either the State Water Board or Lahontan Water Board because they have
the potential to impact water's of the State. The requirements may include the following:
• Discharge of fill or dredge material to a surface water may require a CWA section
401 water quality certification (WQC) order for impacts to federal waters (waters
of the U S.), or dredge and fill Waste Discharge Requirements (WDRs) for
impacts to non- federal waters.
' "waste" is defined it the Basin Plan to include any Ndste or ce'eterious mate64 including, but not'iMlled to, waste
earthen materials (such as soil, silt, sand, clay, rock, . or other organic or minerei material) and any other waste as
defined in the California water Code, section 13050(d).
California Environmental Protective: Agenep
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• Discharge of any waste material andlor permanent or Temporary disturbance
within the 100 -year floodplain of the Truckee River or ¢ ny tributary to the Truckee
River may require an exemption to the 100 -year floods lain discharge prohibition
in the Basin Plan (project must meet all exemption criOria specified in the Basin
Plan). See section 8 below for additional comments.
• Land (upland) disturbance of one acre or more may require a CWA, section
402(p) stormwater permit, including a National Pollutant Discharge Elimination
System (NPDES) General Construction Stonnwater Permit obtained from the
State Water Board, or an individual stormwater perm t obtained from the
Lahontan Water Board.
• Coverage under the Lahontan Water Board's Small ' onstruction Permit Order
No. R6T -2003 -0004 may be required if upland disturbance is between 10,000
square feet and one acre. See
2003 D0Q4 attach.shtml for a copy of this Order and its attachments. Note, this
permit may be used to authorize two kinds of activites: (1) upland impacts
between 10,000 square feet and one acre, (2) dredge and fill activities to waters
of the State that are not also waters of the U.S.
• Discharge of low threat wastes to a surface water, including, but not limited to,
diverted stream flows, construction and /or dredge spoils dewatering, and well
construction and hydrostatic testing discharge, may require an NPDES permit for
Limited Threat Discharges to Surface Waters issued by the Water Board.
• Discharge of low threat wastes to land, including clear water discharges, small
dewatering projects, and inert wastes, may require General Waste Discharge
Requirements (WDRs) for Discharges to Land with a low Threat to Water
Quality issued by the Water Board.
Some -waters of the State are "isolated" from waters of the U.S.; determinations of the
jurisdictional extent of the waters of the U.S. are made by the United States Army Corps
of Engineers (USAGE). Projects that have the potential to impact surface waters will
require the appropriate jurisdictional determinations. Water 3oard analyses typically
follow on determinations by the USAGE and /or sometimes the California Department of
Fish and Game (CDFG) concerning aquatic habitats. These determinations are
necessary to discern if the proposed surface water impacts will be regulated under
section 401 of the CWA or through WDRs issued by the Water Board. The Lahontan
Water Board may require hydrologic analysis to determine 1 30 -year floodplain
boundaries in watersheds where floodplain maps are not avaiiabie (e.g., for federal
flood insurance).
We request that Project proponent consult with the USAGE ,,nd CDFG and perform the
necessary jurisdictional determinations for surface waters w bin the Project area. in
California Environmental Protection A. eney
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addition, we request that the environmental documeri list the permits that may be
required, as outlined above, and identify the specifir. operations, maintenance, and /or
minor construction activities and their impact mitigation measures that will he employed
under these permitting actions in the appropriate sections of the environmental
document Information regarding these permits including application forms, can be
downloaded from our web site at http: /Iv✓ww.w, ierboards.ca.gov /lahontan.
POTENTIAL IMPACTS TO SURFACE WATERS
Surface waters perform a variety of impotant hydrologic and biogeochemical functions
that affect water quality. In particular, stream channel corridors and riparian areas
associated with both perennial streams and ephemeral drainages provide a natural
buffer and help mitigate and control % ater quality impacts by removing pollutants and
sediment from surface runoff. Alihor,gn the proposed development layout appears to
avoid wetlands and drainages (excer�t for one road crossing and several trail crossings)
an increase in impervious surface vtith the development of roads and structures could
change the hydrology of these nearby water resources by increasing water flow velocity,
which in turn leads to increaseF in the severity of peak discharges. These hydrologic
changes tend to exacerbate f..)oding, erosion, scouring, sedimentation and loss of
natural functions and values of creeks and wetlands. The EIR must address the above -
cited potential impacts, which are considered significant.
BENEFICIAL USES O'; WATER
Beneficial uses associated with Hydrologic Area of Juniper Creek, in which the Project
is located, include municipal and domestic supply (MUN); agricultural supply (AGR);
groundwater rec +large (GWR); water contact recreation (REC -1); non - contact water
recreation (REC -2); commercial and sport- fishing (COMM); cold freshwater habitat
(COLD); wi"aiife habitat (WILD); rare. threatened, or endangered species (RARE); and
spawning reproduction, and development (SPWN). The EIR must identify the
prescrib, i beneficial uses of surface waters within the Project area, evaluate the
PrCjeof�, potential impacts to water quality with respect to those beneficial uses, and
provid _ alternatives to avoid those impacts or describe specific mitigation measures
that, when implemented, will minimize unavoidable impacts to a less than significant
levy -:1.
Se.ope and Level of Analyses Needed, Urban development degrades water quality
ti,rough a complex of interrelated causes and effects, which if unmanaged, ultimately
nab destroy the physical, chemical, and biological integrity of the watersheds in which
th, r occur. The primary adverse impacts of poorly planned development projects on
w -iter quality are:
• The direct physical impacts to aquatic, wetland, and riparian habitat and other
beneficial uses;
Generation of construction- related and post - construction urban pollutants;
Alteration of flow regimes and groundwater recharge as a result of impervious
surfaces and storm drain collector systems;
California Environmental Protection Agency
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• Disruption of watershed level aquatic functions, including pollutant removal,
floodwater retention, and habitat connectivity.
These factors have historically resulted in a cycle of destabilized stream channels, poor
water quality. and engineered solutions to disrupted flow patterns, culminating in loss of
natural functions and societal values in the affected basins.
The number and variability of the pathways through which water quality degradation can
occur complicates analysis, but understanding how these pathways operate within the
speck circumstances of this project is essential to effectively mitigating the adverse
effects. Fortunately, avoidance or minimization of any causal link will obviate or reduce
subsequent effects and needed analyses, and a relatively small number of key variables
mediate most of the pathways causing water quality degradation.
To fulfill our statutory responsibilities, the Water Board needs to understand how this
project will avoid or minimize each potential cause of water quality degradation, what
effects will remain unmitigated through project design, and the magnitude of the
remaining adverse effects. Quantification should be as definitive as possible, using
appropriate modeling and adequate data. Modeling approaches should be documented
and data deficiencies or other factors affecting the reliability of the results identified and
characterized. Cumulative impacts must also be addressed.
specific Comments
1. Low Impact Development: Reducing hydrologic disruption from land development
or redevelopment is often referred to as "Low Impact Development" (LID). It results
in less surface runoff and less pollution routed to receiving waters. Principles of LID
include:
Maintaining natural drainage paths and landscape features to slow and filter
runoff and maximize groundwater recharge,
ReAueing and disconnecting the impervious cover created by development and
the associated transportation network, and
Managing runoff as close to the source as possible.
LID development practices that would maintain aquatic values could also reduce
local infrastructure requirements and could benefit energy conservation, air quality.
open space, and habitat. Many planning tools exist to implement the above
principles, and a number of recent reports and manuals provide specific guidance
regarding LID. Water Board staff recommend the use of LID development practices.
and many of our comments are based on this principle. Additional resource
information may be obtained from the Low Impact Development Center's website
located at www.lid- stormwAter.net.
2. Identification of Affected Waters: Map all waters potentially affected by this
project and list them in appropriate tabular format, organized by waterbody type and
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sub- basin. For each waterbody directly affected, for example for proposed dredge
and fill activity, identify the acreage and (for drainage features) the number of linear
feet directly impacted. Sum the total affected acres and linear feet by waterbody
type, within Water Board jurisdiction, and as project total. Identify any "isolated"
wetlands or other waters not subject to federal jurisdiction.
3. Avoidance, Minimization, and Mitigation: The Project has the potential for major
water quality impacts. However, it also has the possibility of implementing an
integrated watershed planning approach using Low Impact Development (LID)
principles to minimize those impacts. Most construction- related direct impacts to
surface waters will likely require either individual WDRs or coverage under General
WDRs for impacts to waters of the State, and /or CWA §401 water quality
certification from the Water Board and CWA §404 permits from the U.S. Army Corps
of Engineers (USAGE) if the waters of the State are also waters of the U.S. The
project proponent is advised to conduct an alternatives analysis consistent with the
requirements of the federal CWA §404(b)(1) Guidelines. While these Guidelines are
most directly incumbent on the USAGE, the principals of avoidance, which they
articulate, are directly relevant to the Water Board's mandate to protect water
quality. Include a CWA §404(b)(1) Guidelines -like alternative analysis in the EIR.
The Water Board regulates all wetland areas including, but not limited to, seasonal
alpine wetlands. All wetlands (defined by U.S. Army Corps of Engineers 1987
Wetlands Delineation Manual) are waters of the State as well as waters of the U.S.,
and the Water Board's Basin Plan prohibits any discharge of waste earthen
materials or other project- related pollutants to all surface waters (including isolated
wetlands). Violating this prohibition would create a significant water quality impact. It
should be noted that water quality impacts associated with avoiding wetland impacts
are substantially different than those associated, with minimizing impacts. The final
EIR document should include an approved wetland delineation (with data sheets and
accompanying map of data points) and must identify measures to prevent the
discharge of pollutants to wetland areas prior to determining the level of impact that
will be created by the proposed project. Any proposed wetland encroachment must
be identified in the final EIR and must be accompanied with appropriate information
for the Water Board to evaluate whether or not such an impact would qualify for an
exemption to a prohibition.
It may be necessary to obtain a Clean Water Act Section 404 permit from the Army
Corps of Engineers (Army Corps) for proposed discharges of dredged and fill
materials to waters of the United States. If the Army Corps determines that it is
necessary to regulate the project under Section 404, then the project applicant may
be required to obtain Clean Water Act Section 401 Water Quality Certification (401
WQC) from the Regional Board. The project applicant should contact the Army
Corps' Sacramento District Office and determine if the project is subject to Clean
Water Act Section 404 and if so, under which Section 404 permit. The project
proponent should contact Water Board staff to determine if It is necessary to obtain
Clean Water Act Section 401 Water Quality Certification from the Water Board.
California Environmental Protection Agency
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4. Hydrologic Disruption: Because increased runoff from developed areas is the key
variable driving a number of other adverse effects, attention to maintaining the pre -
project hydrograph will prevent or minimize other problems and will limit the need for
other analyses and mitigation to be included in the EIR. We strongly encourage the
use of LID principles and practices (see http.16MO waterboards.ca.gov /water issues
/pro men#findex . shtmlo )
A National Pollutant Discharge Elimination System (NPDES) general permit for
storm water discharges will be required due to construction activities resulting in a
land disturbance of one acre or more. The applicant can obtain a Notice of Intent
(NPDES general permit application) for storm water discharges associated with
construction activities on the web at
itttp: /,rv,NA% waterboards.ce.aoy /water issues/ rog rams/ storrnwater /constructior.,shtml.
As part of the NPDES Permit, the applicant is required to develop and implement a
Storm Water Pollution Prevention Plan (SWPPP). The SWPPP is subject to review
by the Water Board. The Water Board will require submittal cif grading /drainage and
erosion control plans as part of the SWPPP, in addition to the other required
SWPPP elements. Include measures to maintain the pre - project hydrograph in the
alternatives analyses in the EIR (see below). Also, the draft EIR must document
potential cumulative impacts to watershed hydrology from existing and any other
planned development in the area. Attention to maintaining the pre - project
hydrograph is also required under the State Board's General Permit for Discharges
of Storm Water from Small MS4s (WQ Order No. 2003- 0005 -DWQ) and under the
State Board's General Permit for Discharges of Storm Water Associated with
Construction Activity (WQ Order No- 2009 -0009 -DWQ); the project will be required
to obtain coverage under the latter Order. Again, cumulative impacts must also be
addressed.
The Project will need to include appropriate LID features and /or best management
practices (BMPs) that at a minimum treat or retain storm water runoff from
imperious surfaces generated by the 20 -year, 1 -hour storm event (0.7 inches of
rain). BMPs designed to retain storm water runoff are intended to avoid or reduce
adverse effects to surface water hydrology (e.g. increasing peak flows, increasing
flow velocities, flooding, etc.), which generally lead to adverse effects on water
quality and the aquatic environment (e.g. increased channel instability, bank erosion,
channel scour, increased sedimentation, increased pollutant loading, etc.). Such
BMPs rnay include, but not be limited to, infiltration trenches, infiltration galleries.
and infiltration basins.
In adVion tc managing the storm water runoff volume generated by the above -
referenred storm, it is equally important to ensure that the storm water is adequately
treated prior to disposal. Storm water runoff contains sediment, petroleum products
and ogler vehicular fluids, metals, nutrients from fertilizers and other sources,
pesticides, and roadway deicing and traction products. These products can
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adversely affect both surface and ground water quality. Staff recommends that a
combination of source control and treatment BMPs be used during and following
construction. Such BMPs included but are not limited to:
• Phasing construction to minimize
Permanent sediment traps such as
areas of unstable soil conditions
sump areas within drop iniets,
vegetated basins, filtration systems
_ __
• Minimizing the area of total
Using petroleum absorbing products
disturbance
within storm water
conveyanceltreatment system
• Stabilized areas of ingress and
Develop and implement a
egress
Revegetation Plan that facilitates
effective soil stabilization with
vegetation __��
■ Temporary sediment traps such as
■ Developing and implement a
siltation fencing, fiber rolls, gravel
Chemical/Irrigation Management Plan
L bag berms and check dams
for landsca areas
• Develop and Implement a
■ Maintain buffers between
Construction Waste Management
development and existing surface
Plan (concrete waste, trash,
I waters
construction equipment waste
products
a) The proposed project should provide both adequate storm water treatment and
retention. The Draft EIR should identify the probable treatment and retention
BMPs and discuss the pollutants that the identified BMPs will address. The Draft
EIR should also include a discussion regarding the quantity of storm water runoff
these BMPs will need to accommodate. Such information could be included in a
"Conceptual" SWPPP. The Conceptual SWPPP would also provide additional
information on other elements (e.g. construction waste management, BMP
maintenance; training, dewatering operations, pollutant source identification) that
the NPDES Storm Water Construction General Permit requires being included in
a SWPPP. Such information will assist staff In determining if water quality wil! be
adequately protected.
b) The DER should include any storm water runoff conveyance or drainage
analysis reports that have been or are required to be prepared prior to
implementing the project.
c) The DER should discuss if fertilizers and other chemicals will be used on
landscaped areas. If chemicals will be used to maintain landscaped areas, the
DER should identify the measures (e.g. irrigation practices, chemical application
practices) that will be implemented to prevent landscape maintenance activities
from adversely affecting water quality.
California Environmental Protectian Agency
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d) If the project will be relying upon a revegetation effc rt to restabilize areas of
disturbed soil, the DEIR should discuss what measures (seeding, planting,
temporary soil stabilization such as mulching, temporary irrigation, monitoring,
interim and final success criteria) will be implemented to ensure that vegetation is
reestablished in a manner that effectively and permanently stabilizes disturbed
soils.
5. Clean Water Act section 303(d) list: Closely related to storm water
controVireatment is erosion control. The Truckee River has been placed on the
Clean Water Act Section 303(d) List, as being wa!ar quality impaired due to
excessive sedimentation. Water Board staff com iders increases in sediment
loading to the Truckee River and its tributaries a s a potentially significant impact.
The DEIR should identity probable erosion control BMPs and locations where they
would likely be deployed. The Conceptual SWPPP could be used to provide such
information as the final SWPPP will need to identify the specific erosion controi
BMPs that will be used at the project Site and their locations. Staff recommends that
the erosion control BMPs focus on source control with treatment -based BMPs
providing a second line of defense. Minimizing and stabilizing areas of disturbed
soil, stockpile management/protection, dust suppression, temporary and permanent
stabilized storm water conveyance features, and sediment tracking controls are
some of the source - control measures that can be incorporated into project design
and construction. If proposed dust control measures include the use of dust
palliatives in addition to or in lieu of water, then staff recommends that the DEIR
includes Material Safety Data Sheets for selected dust palliatives so that staff can
better evaluate if the proposed products present potential water quality threats.
Staffs experiences indicate that it is more effective to ki:ep the soil in place (source
control), rather than trying to remove it by treatment or :e it has been mobilized by
storm water runoff or snow melt. This is why staff recuminends using LID and
source - control measures as the primary line of defense with treatment measures in
redundancy as the second line of defense.
6. Snow Storage Areas,. The information provided does not indicate potential
locations for snow storage. Snow removed from areas associated with
developments of the proposed project's nature often contains sediments, oils,
greases, petroleum products, and other constitue! its that would normally be
collected and treated through various BMPs.
The DEIR should discuss probable methods V rat will be employed to protect both
surface and ground water quality from pollutants associated with snow removal and
disposal activities. The DEIR should also c',sviss proposed deicing methods for
road and parking areas, deicing material storage and handling areas, and
associated BMPs.
California Envitonmenral.Protectian Agency
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7. Habitat Connectivity: T. ie Project is proposed for an open space area and may
pose a significant disrup:len to habitat connectivity. Riparian corridors and other
waters within the regulrltor; purview of the Water Board can play important roles in
maintaining habitat cc inealvity. Enclosure 3, Terrestrial Habitat Connectivity
Related To Wetland, Ripa ian and Other Aquatic Resources, provides information
and references on tl.is subject. Aquatic habitat may also be fragmented by impacts
to streams or other wate,00dies.
The EIR should anGlyzf the regional importance of movement corridors in and along
waterbodies, the potential r ifect of disrupting such corridors, and the potential for
enhanang such condors t: provide project mitigation. include information regarding
any sensitive plan'_ and an mai species that likely utilize the corridors. Identify any
project impacts +j rparian or other waters that could compromise future remediation
of existing connectivity ban iers. To further inform these analyses, consider the
information z id literature referenced in Enclosure 2. including data on the role of
riparian car Idors as movement corridors in California.
100 -year Floodpiain Prohibition: The Lahontan Water Board prohibits waste
dische ges due to disturbance of surface waters and their 100 -year flood plains in
the T uckee River Hydrologic Unit. These prohibitions are contained in the Water
Bor rd's Basin Plan and can be viewed on our website located at
h +p // www .waterboards.ce.dov/lahontan /, under Chapter 4.1 of the Basin Plan The
17,asin Plan prohibitions apply in part to drainage swales and wetlands, in addition to
larger surface waters. The Basin Plan also contains exemption criteria for
prohibition 4(c) addressing waste discharges to the 100 -year floodplain of the
Truckee River and its tributaries. The project proponent will have to demonstrate that
any proposed disturbance to surface waters and /or their 100 -year floodplains satisfy
the exemption criteria. However, no exemption criteria exists for isolated surface
waters (including isolated wetlands). If the proposed project includes discharges of
waste, including but not limited to earthen materials, to isolated surface waters,
ien more than likely, such a discharge will be prohibited and the project will need to
.a redesigned to avoid such discharges.
,s important that the DEIR identifies all surface waters (ephemeral and perennial
:hannels /creeks /streams. wetlands, ponds, lakes, etc.) and associated 100 -year
loodpiains located on the proposed project site. It is also imperative that the DEIR
dentify each known surface water as "isolated" or "tributary to the Truckee River." If
Lhe project proposal includes discharge of waste, including but not limited to earthen
materials, to a surface water that is a tributary of the Truckee River, then the
DEIR needs to include information demonstrating how the proposed project
complies with the prohibition exemption criteria contained in the Basin Plan. If such
information is not provided in the DEIR, it will be difficult at best to determine if the
proposed project complies with the Basin Plan. Please be aware that a Basin Plan
violation is considered a significant impact.
California Eavironrnentai.Protecdon Agency
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Water Supply: The proposed project will create additional demand upon the existing
water supply system. Pumping ground water provides the majority of water supply
within the Truckee area. Staff is concerned that increases in ground water pumping
from this Project may begin to adversely affect surface water resources and the
beneficial resources associated with those resources. Staff would consider it to be a
significant impact if ground water withdrawals began to decrease surface water
resources due to indirect impacts such as desiccating wetlands.
The DEIR should provide information that demonstrates that the proposed project,
individually and cumulatively with other existing and proposed development will not
adversely impact surface water resources. If the information and conclusions
provided in the DEIR rely upon regional ground water studies, then staff requests
that site.-specific information is also provided to support any regional -based
conclusions that the DEIR relies upon.
Again, thank you for this opportunity to comment. Attempts to manage the adverse
effects of urban development form a large part of the workload of the State and
Lahontan Water Board non -point source, stormwater, and water quality certification
programs, as well as our efforts to establish total maximum daily loads for impaired
water bodies. Many of the water bodies currently on the State's list of impaired water
bodies are affected by conditions within the purview of local agency planning. However,
after - the -fact regulatory control is at best a partial substitute for planning which avoids
water quality degradation. We therefore welcome the opportunity to work with the Town
of Truckee to make the Project development an example of environmentally - appropriate
planning in California.
We look forward to working with you in your efforts to protect water quality. If you have
any questions, please contact Tobi Tyler at (530) 542 -5435.
Al.,_ / 144
Alan Miller, P.E.
Chief, North Basin Regulatory Unit
Enclosure: Terrestrial Habitat Connectivity Re:ated to iNetland, Riparian and Other
Aquatic Resources
cc: State Clearinghouse
TT'T /Canyon Springs Subdivision Nop comments 5 -1d -11 Tr dcc
Plln' Penyilg / Nevada County! Canyon Springs Subdivisior Prclect
California Environmental Protection Agency
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