HomeMy Public PortalAboutCanyon Springs DEIR Public Comment #38 (Riley)March 5, 2013
Denyelle Nishimori, Senior Planner
Truckee Community Development Department
10183 Truckee Airport Road
Truckee, CA 96161
Re: Canyon Springs DEIR
Dear Denyelle,
It is my opinion that the submitted Canyon Springs DEIR fails in its analysis of Project
Alternatives as required by the California Environmental Quality Act, CEQA. This DEIR
does not allow an adequate comparison of Project Alternatives sufficient for comparative
review and consideration by the Public, TOT and all concerned. Specifically this DEIR does
not appropriately consider Project Alternatives which could greatly reduce Traffic,
Environmental and Community concerns.
PROJECT DENSITY:
The submitted DEIR considers project density but does not propose a Project Alternative
where Canyon Springs meets the “Rural Clusters” criteria as described in Table LU-7,
Clustered Development Types and Applicable Land Use Designations, 2-62 of the 2025 TOT
General Plan’s Land Use Element. Our General Plan specifically assigns this designation to
“Rural residential areas on Town edges”, words which are consistent with Canyon Springs.
Instead of an Alternative Project density consistent with “Rural Clusters”, this DEIR suggests
that the Canyon Springs project have a “Rural Suburban Cluster” designation. This
designation is inappropriate because it is intended for “Sites peripheral to Town core,
generally not on sites within the rural fringe”. Why doesn’t this DEIR compare a Canyon
Springs project which is consistent with a Rural Clusters designation, to the project as
submitted? Even more alarming is the suggestion that this submittal have an allowed density
under the “Suburban Clusters” designation when the Canyon Springs site is clearly on the
“Town edges” and not the “Town core”.
PROJECT TRAFFIC:
The submitted Canyon Springs DEIR does not propose a Project Alternative where Canyon
Springs has no bearing / impact on our existing roadways and intersections. Instead, the
submitted DEIR suggests that this project would mitigate its impacts to our existing roads
and traffic infrastructure and is reliant in some degree to improvements to the Glenshire
Drive / Donner Pass Road intersection which are to be completed as part of the Railyard
Project which may or may not happen. To allow adequate comparative analysis, why doesn’t
this DEIR propose a Canyon Springs Alternative with a density determined by what our
existing roads will bear, and without necessary and dependent improvements to mitigate
Canyon Springs’ traffic impact? This Alternative was specifically requested, by me, in the
project’s DEIR Scoping Meeting and appears in Appendix B, Scoping Meeting Comment
Matrix + Letters, page 107 of the submitted DEIR. It is unclear why this DEIR fails to
review a “no impact to traffic intersections” alternative, to allow consideration of a smaller
project that wouldn’t impact existing neighborhoods and streets.
ENVIRONMENTAL / ECONOMIC BLIGHT:
The submitted Canyon Springs DEIR does not adequately consider the impacts that this
project could have if it were to fail as an investment and become a so-called “Ghost
Subdivision”. As a Town we’ve seen several recent developments suffer from an oversupply
of undeveloped parcels, decreasing property values for everyone in a struggling economy.
This is as much an environmental concern as it is an economic concern. If Canyon Springs
were to fail financially after its roads and infrastructure were in place, sitting idle and forlorn
while “we the people” bail the lenders out, this community would have allowed a significant
environmental impact and a resultant and directly associated economic impact to our Town.
What are the assurances that this development won’t create a tremendous environmental
impact and then fail as an investment? Why doesn’t this DEIR review a much less risky
approach to Project Phasing, one where the first Phase is greatly reduced from what is
proposed and subsequent phases are conditioned and informed by the successes and failures
along the way? As proposed, the DEIR does not adequately consider “Conditional Phasing”,
where the environmental and associated economic risks could be reduced and metered out.
My request for “Conditional Phasing” was made in the project’s DEIR Scoping Meeting and
appears in Appendix B, Scoping Meeting Comment Matrix + Letters, page 107 of the
submitted DEIR. Why doesn’t the DEIR consider the very probable scenario where Canyon
Springs becomes a Ghost Subdivision, impacting us environmentally and economically?
The submitted DEIR fails to meet the intent and requirements for Project Alternatives under
CEQA. It does not provide adequate information and analysis sufficient for Public
consideration and review. It is my opinion that this DEIR unreasonably favors the applicant /
developer in its analysis and conclusions and is insufficient in its depth with regard to many
more concerns than the few I’ve raised in this letter. It may be necessary to restart this
process with an entirely new Environmental consultant. As the Lead Agency, our Town has
not gotten the benefit of a thorough and comprehensive impact assessment.
Thank you for including my comments with so many other community members who are
concerned with the significant impacts that the Canyon Springs project could bring. I hope
that it goes without saying that these written comments represent the views and concerns of
many more than those who take the time to write them.
Sincerely,
Brendan Riley, AIA
Truckee Resident,
California Architect,
HPAC Commissioner