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HomeMy Public PortalAboutCanyon Springs EIR Scoping - 13.pdf05/13!2011 16:23 5305442271 LAHONTAN FA,- 01/11 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- 9ctfngSecrelanyra+ (330) 542.54X0 • Fax (530) 541.2271 CrOwmor Fmmonrr!enlaf Pmlteinn NNW.Pe[CfIM]rdS.Fa. �S��ahOn!an 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 0 Rv:ycledpaper 05/13,'^1.•.1 16:22 5305742271 LAHWTAN PAGE 02,111 Denyeile Nishimori - 2 - 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 0 Rec•c1en Paper 05!18(2011 7.6:23 530344227. LAHUJAH PAGE 03/1! Oenyelle Nishimoh - 3 - • 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 ea nac;.rradPaper �+ 05!13/2011 16:23 5305442271 LAWNTAII PAGE 04111 Denyelle Nishimod -4- 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 05/1,312001 16:23 5305442271 LAHRJTAIJ PAGE 0511 Denyelle Nishimori - 5 - • 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 California Environmental Protection Agencv V5* Re,ycfedpnpor -- 05/13:'2011 16:23 5305442271 LAWNTAH PAGE 06/11 Denyelle Nishimori 6 - 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 Ceti /15/' =01.1 16:23 5305442271 LAHCNTAN PAGc 67/11 Denyelle Nishimori .7- 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 California Environmental Protection Agency 0 RceycleAAOper 6;/19/2[11 1E: 23 5305442271 LAHCBJTAN PAGE 08/11 Denyelle Nishirnori - 8 - 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 yy' R•=n Jed Parer 05!13/2011 15:23 5305442271 _ LAW]NTAN PAGE 09"11 Denyelle Nishimori 9- 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 7„ ..Rryaed Pair H5.'18i 2 @11 16: 2J 530544227'. LAHO 11-AN PAGE _ 0;11 Denyelle Nishimori - 10 - 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 Z� Ratyciea'Axpe� GSil : "2011 16:23 530544-227: LAHUATAH PAGE Denyelle Nishimori - 11 - 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 yd .4ecyled Pop,,