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HomeMy Public PortalAboutCanyon Springs EIR Scoping - 46.pdfSOSGIenshire Saving Open Space around Glenshire John McLaughlin Town of Truckee Planning Department 10183 Airport Rd. Truckee CA 96161 May 23rd, 2011 Re: Scoping for Canyon Springs DEIR Dear John, The proposed Canyon Springs project is among the few remaining major development projects in Truckee. Its scale and location at the edge of the Town and on land that provides an important buffer between open space lands and rural and suburban development increases the importance of a thorough analysis of impacts and alternatives. We appreciate this opportunity to comment on the scope of the DEIR. Our recommendations are as follows: Traffic: Canyon Springs is going to bring suburban development to the eastern border of Truckee, requiring the people living there to make long trips to jobs, services, schools and recreation. Traffic and vehicle miles traveled are a very important issue, We have attached an article from calpa.org ( http: / /www.yolocounty.org /Index.aspx ?page =1965) entitled: "What is VMT Threshold and why Do I Want it in My General Plan ". We strongly recommend this for consideration by Council, Planning Commission, Town Staff and consultants when they review this and other projects. The most recent estimate of trips per day in this region was made on a holiday weekend. Traffic varies with time and with seasons and therefore should be measured in a variety of times and seasons. We believe additional and more recent trip estimates should be included in the environmental setting section to provide a basis for analyzing project - related and cumulative impacts. The geographic study area for circulation related impacts should be the entire Town of Truckee and major roads between Truckee and Reno where new residents are likely to travel regularly for shopping, employment, and other reasons. Specifically the DEIR should analyze the impact of the project and cumulative development on the agricultural station on westbound 1 -80. At a minimum, the following intersections should be studied in detail for all key times (a.m. and p.m. weekday and weekend and holiday peaks): • Glenshire Dr/Whitehorse /Martis Peak Drive. In addition, safety impacts should be analyzed because sight distance is limited at this intersection — e.g. How far can you see in each direction from this intersection? • Glenshire Dr. /Dorchester (at both ends) • Glenshire Dr./ Somerset • Glenshire Dr. / The Strand • Glenshire Dr./ Donner Pass Road • Donner Pass Rd./ Bridge Street • If, as proposed by the developer, primary ingress and egress relies on 1 -80, the DEIR must analyze how the above intersections will be affected when 1-80 is closed. For example, when 1 -80 is closed, 18 wheel trucks use Glenshire Dr. How will this affect the above intersections? • What are alternatives to the Martis Peak Road and Devonshire access routes? • What percent of total project Greenhouse gas emissions will be generated by traffic to and from Canyon Springs as a result of the project? What is the cumulative development? • How will the transportation needs of low income residents be met? • Does the trails network cover the entire development in a way that would promote alternative forms of transportation? If so, what percent of trips to jobs /services /other destinations will trails account for and why? • Developers plan to preserve existing trails, many of which go down fall lines and cross ephemeral streams. How can the trails be designed so as to prevent erosion and water contamination? • Mitigation measures including but not limited to the following should be required and provide a pre- requisite to project development: 1) Yolo County General Plan like maximum household VMT) based on at least a minimum reduction in per capita VMT of 20% over existing average per capita VMT for Town; 3) minimum mode share by alternatives to the single occupancy vehicle as a result of incorporating community car share program; shuttles; household concierge services to trip link/carpool as well as trails; 4) reduced project footprint/project size /project type. • The DEIR should describe how the project is or is not consistent with all applicable transportation - related general plan policies as well as other regulations and ordinances applicable to the project. flydrology: The project borders a wet meadow and proposed roads cross ephemeral streams going down to Glenshire Pond. Questions that should be addressed by the DEIR include the following: • How much sediment will these road crossings generate? • What and how much pollutants will wash off the roads into waterways? " What will be the effects on Glenshire Pond and the intervening ephemeral streambeds, Glenshire Pond, and the Truckee River? " How will the pollutants affect the Truckee River? " Will pesticides and fertilizers used by residents make their way to the ephemeral streams? " What is the 100 year flood plain for the wet meadow abutting the southern border of the project? How will the flood plain be affected by global warming? Can we be sure that the houses on the southern margin of Canyon Spring are safe from flooding? " The same questions apply to all the other wetlands throughout the project. " Will there be a new Wetland delineation done in the springtime rather than a dryer season? " Does the project have a certified Wetland Determination from the National resource Conservation Service, with a current up to date mapping of the wetlands? " What is the evidence that simply following standard BMPs will be sufficient to preserve water quality? " What additional mitigation measures beyond standard BMPs could be incorporated to ensure no water quality impacts? " The DEIR should describe in detail how the project is or is not consistent with all applicable General Plan policies as well as other regulations and ordinances. Biological Resources: Canyon Springs is located on a known deer migration corridor vital to deer traveling from Nevada to their fawning grounds in Waddle Ranch. " What will be the effect of this development on the deer migration route? " What will be the effects of lights and noise on deer and other wildlife? How large a corridor is necessary to accommodate the deer population and migration? " The California Department of Fish and Game, in collaboration with the Nevada Dept of Wildlife is conducting a 3 year comprehensive, objective, and independent survey of deer migration in the entire Martis Valley. Why does a decision have to be made on this development before this important information is available? " What other wildlife is present, and how will it be affected by the development? " What botanic species of interest are present, and how will they be protected? " Are there invasive species that need to be removed? " What mitigation will be included for loss of habitat and forage? (The Tahoe - Donner, Glenshire, and Martis Valley subdivisions have removed many thousands of acres of high quality habitat from deer production.) Mitigation measures recommended during the planning process for these developments have been generally inadequate, not truly meaningful and not carried out. " What is being done to protect/create deer movement opportunity, avoid road collision, protect fawning does, and reduce disturbance to deer and fawns? How much of a buffer will be needed to separate deer and human interactions as to not disturb the deer, especially by domesticated dogs? " What will the fencing restrictions be and what effects will they have on " deer and other wildlife? " Will animals be directed towards roads, increasing the likelihood of being hit? " What is being considered in terms of bear management and attractants from all the new garbage that will be created and the loss of foraging ground? " Will surveys be done to make sure nest trees are not removed? Will the timing of development coincide with nesting and affect ground or tree nesters? " How will large trees ( >20 "dbh) be protected? " What would be the effects of mandatory defensible space measures on wildlife habitat within the project? " Development is proposed over 8 phases over a period as long as 20 years. What will be the effects on wildlife (and humans too) of the noise, dust, air pollution, tree removal, and traffic over this prolonged period of time? " The project description indicates that "over 65 %" of the site will be in open space  the DER should provide a detailed breakdown of the character of the open space areas. It appears that the project will fragment much of this so- called open space acreage. The DER should analyze the impacts of fragmentation on the quality of this open space (e.g. as a result of roads and other developed areas). " "Buffer" lands, such as this proposed development site, can be essential to the functioning of habitat lands. The DER should also include a detailed description of how the loss of this "buffer' land between open space /habitat areas and development will impact the adjacent habitat areas. Alternatives to the project that provide a larger buffer and /or permanent edge to the Town have the potential to mitigate some of the project's likely significant impacts. As such, careful attention to should made to developing those alternatives and describing them in some detail (e.g. alternative site plan). " How will this project "Protect areas of significant wildlife habitat and sensitive biological resources" as required on page 7 -31 of the General Plan Public Safety: This development is at the extreme edge of Truckee on the wildland- suburban interface, far from many essential services. " The only routes in and out of the Glenshire /Canyon Springs /Martis Peak /Juniper/ Meadows region are the east and west ends of Glenshire Drive. Can this development, along with all of the other development inside and outside Truckee served by this route be evacuated safely in the case of a catastrophic wildfire? " How can evacuation plans for Canyon Springs be coordinated with other neighborhoods inside and outside Truckee Town boundaries " What would be the response time for a 911 call? " How long would it take to get a Canyon Springs resident to the hospital? How long would it take if 1 -80 were closed? " Affordable housing is proposed for condos near an electrical substation. What will be the health effects of living next to a substation? " The area has long been used for motorized recreation. What hazardous materials are present? " This development places 185 dwelling units on the wild land - suburban interface. Does this subject residents to a fire or other hazard? Should there be a buffer? How big should that buffer be? " The development is primarily north facing. Does this create icing hazards for the residents during the winter? " What are the safety implications of no streetlights? Water: • Where will water for the project come from? • What effect will withdrawal of this water have on wells surrounding Canyon Springs? How will this be monitored? • Recent studies have shown more and more contaminants in ground water. What contaminants are present in this water supply? What is their concentration? • How will the physical connection to water be made? • Is there adequate quantity and pressure for both drinking water and fire suppression? • Will a tank be necessary? If so, what will be its environmental effects? • Some water in the Glenshire area is known to be contaminated with arsenic. What would be the environmental consequences of using this water for landscaping? • The DEIR should include mitigation measures to achieve a 20% reduction or more in potable water consumption over existing average in Truckee. Other Utilities: • What effect will utilities have on the designated open space? • What is the sewer access? Will it have to be pumped? If so, where will the pumping stations be? How will sewer pipes affect wetlands? • How will natural gas be provided? • How will providing utility services and road plowing and maintenance to this remote location affect the cost of those services in Truckee as a whole? • Does this development present an opportunity for renewable power? Viewshed: Some of the development is proposed to be on the tops of steep ridges. The DEIR should analyze: • The visual impact of these houses on views from Glenshire, Juniper Hill residents, and any protected open space areas or planned and existing trails • Even with no streetlights, will light pollution from houses affect the views from this, and neighboring developments? Geology: • Will the soils support construction on the above steep ridges • Earthquake faults are known to be present in the Martis Dam area. What will be the impact of those faults on this development? • Are there more faults near Canyon Springs? • Is there any evidence of landslides or slumps in the steeper ridges? • Are any soils subject to liquefaction? Land Use Planning: Truckee already has a large inventory of unsold and foreclosed houses. The DER should address the following questions concerning potential for urban decay and blight should the project be partially developed but remain unsold or only partially sold. • How can we be sure these new units do not sit unused on the market and promote blight? • Will these units make it more difficult to sell existing homes in Glenshire, causing blight to spread beyond Canyon Springs? • What is the evidence that these additional units are needed in Truckee? • Will the existence of this development promote sprawl and leapfrog development beyond current Town boundaries? • There is a disagreement about how much open space is preserved and whether the development is clustered, and an independent measurement by the consultant is necessary. How much open space is present? What proportion of the development is open space? • What is the highest and best use for this land? Why? • What will be the impact on school, fire, police, and medical services? • A homeowner's association is planned to enforce important mitigating restrictions on the property. How can we be sure that it will be effective? Greenhouse Gas (GHG) / Climate Change: • What are the Climate Change related impacts associated with the projects proposal to remove trees, and how will this be offset? • How will creation of a "heat island" from artificial surfaces be prevented? • What will the "life- cycle" greenhouse gas emissions be from this project including but not limited to: construction of the development and including residents and visitors driving back and forth to it? • What green building techniques will be used? • The DEIR should incorporate mitigation measures including but not limited to those required to achieve a net zero energy project. If this is not feasible, the EIR should articulate the reasons why it is not. Cultural: • What archeological resources are present on this property? • Has the site been reviewed by the Native American Heritage community? • What steps should be taken to ensure the buildings will be consistent with the character of Truckee? Recreation: How will this project affect recreation opportunities in the region? Will projected owners need recreational facilities such as parks and playgrounds in addition to the trails? Air Qualms: • How will this development affect air quality? • What will be the effect on levels of NOx, PM10, and PM 2.5? • Is it subject to inversion layers? Noise-This project is under one of the Airport flight paths • What noise exposure will result? What will be the consequences of this noise exposure? Mandatory Findings of Significance: What are the cumulative impacts of this development together with Glenshire, The Meadows, and developments in the region but outside the Town Of Truckee such as Martis Peak, Juniper Hills, Juniper Creek, and the Teel property (when developed)? Why is this project superior to no project, or smaller alternatives such as 106 DU (which is 0.5 per buildable acre), and 53 DU? How are the above issues affected by the projected construction period of up to 20 years Thank you very much for your attention to these critical issues. Jo Eaton Presi nt, MAPF eigh Golden President, SOSG Terrell Watt reviewed and contributed to this letter Delivered by hand and by email.