HomeMy Public PortalAboutCanyon Springs DEIR Public Comment #50 (Riley)March 5, 2013
Denyelle Nishimori, Senior Planner
Truckee Community Development Department
10183 Truckee Airport Road
Truckee CA 96161
Re: Canyon Springs DEIR Comments
Dear Denyelle:
Please see my responses to Canyon Springs’ Draft Environmental Impact Report (DEIR) below.
If you have any questions feel free to contact me at any time.
As a resident of Glenshire since 2003, a Truckee Planning Commissioner from 2003 to 2007 and
the current Board President of Mountain Area Preservation, I have a long and extensive history
of involvement with the property now known as Canyon Springs. I live in close proximity to
this property and am familiar with the topography, terrain and its geographic location in
relation to the Glenshire neighborhood and the Town of Truckee. In my opinion this DEIR and
its subsequent analysis, findings and mitigation measures are inadequate, insufficient and
fundamentally flawed. I have listed below my comments and questions in regards to this DEIR
and look forward to a thorough and thoughtful reply to this letter as well as the many other
citizens who have taken the time to review this document and address their issues and
concerns.
TOWN OF TRUCKEE GENERAL PLAN
As a Planning Commissioner for the Town of Truckee during the entire 2025 General Plan
Update, I participated in hundreds of hours of community workshops, public hearings and
deliberations regarding the drafting and ultimately the final outcome of the Vision Statement,
Guiding Principles, Policies and Action Items of the 2025 General Plan.
1. During the 2025 General Plan Update process, the community was unable to discuss the
property currently known as Canyon Springs as there was an open application in the hands of
the Town. Thus, the Vision, Guiding Principles, Policies and Action Items created and certified
under the 2025 General Plan did not take into account this property and were not discussed at
a community level. I believe there are direct conflicts with this project as proposed with
respect to the 2025 General Plan. Specifically with regards to land use planning, density, green
house gas emissions, safety and traffic/circulation. Overlay Area 6 was created to require
development in this region to create a Planned Development that coordinated with adjoining
neighborhoods, but it lacks clarity and specificity and was not discussed with respect to how its
zoning designation was at odds with many of the guiding principles laid out in the 2025 General
Plan.
Please explain how policies created during the 2025 GP Update without consideration
for this property can be applied to this project. Specifically the desire to apply a minimum
building density of 50% discussed in relation to development in the town core can be applied to
a development proposed on the rural fringe, ie. the easternmost boundary of the Town of
Truckee.
TRANSPORTATION/TRAFFIC/CIRCULATION
I have listed below some of the guiding principles for the General Plan’s Circulation Element. I
believe the Canyon Springs project as proposed is in direct conflict with these principles.
CIRCULATION ELEMENT GUIDING PRINCIPLES:
1. GUIDING PRINCIPLE: Maintain acceptable traffic operations on the Town's roads through
application of Level of Service thresholds, and by conditioning new development on the ability
of local roads and intersections to accommodate projected traffic impacts.
Canyon Springs will be required to enact numerous costly and environmentally
disturbing and damaging infrastructure changes to accommodate their proposed impacts to
existing roads, specifically the addition of a third vehicle lane in multiple areas to accommodate
safe turning actions. Please explain how these requirements are not in contrast with the above
stated guiding principle.
2. GUIDING PRINCIPLE: Minimize the negative impacts of transportation infrastructure upon
Truckee’s community character, local neighborhoods, and the environment.
The residents in and around Glenshire, including those who live in Olympic Heights and
Hirschdale are poised to suffer through 20+ years of construction traffic, noise and pollution if
this project moves forward as proposed and that is banking on a strong building environment,
which is not the currently the case.
Please explain how Canyon Springs will minimize the negative impacts of transportation
infrastructure on our community character, local neighborhoods and environment.
The building of new roads and bridges will require extensive construction equipment to
transport and deposit materials. Who monitors the 7 ton load limit on roads to ensure that
vehicles that exceed this limit will not travel Glenshire Drive from town or via I-80?
3. GUIDING PRINCIPLE: Ensure that new development minimizes impacts on the roadway
network, is integrated into the existing transportation system and provides opportunities for
use of alternate modes.
Canyon Springs will impact our existing roadway network to unsustainable levels as the
traffic analysis has indicated. (Pg 4.14-29 Traffic/Circulation Section DEIR; 2578 One way
vehicle trips per day) This development proposes no alternate modes of transportation nor
does it propose to create a new roadway infrastructure that would allow citizens to safely
travel on bike into town from Glenshire. This project does not propose to complete the Legacy
Trail or other modes of transportation to safely transport citizens from the eastern periphery of
town into the downtown core.
Please explain how Canyon Springs will minimize its impacts on the roadway network or
provide alternate modes of transportation.
4. GUIDING PRINCIPLE: Work cooperatively with adjacent jurisdictions to address regional
traffic issues.
Please explain how the town of Truckee, the developer and Nevada County are working
together to address the impacts this development will create with increased traffic on Glenshire
Drive to Hirschdale and the Interstate 80 interchange. The traffic analysis failed to study the
impacts to Interstate 80 (I-80).
5. GUIDING PRINCIPLE: Reduce automobile travel demand to reduce impacts on the Town's
roadway system, lessen the need for new or expanded road facilities to accommodate
increased demand, and decrease pollutants emissions from automobiles.
Please explain how Canyon Springs will reduce automobile travel impacts to the Town’s
roadway system and lessen the need for new or expanded road facilities to accommodate the
increased demand and decrease pollutants emissions from the automobiles.
6. Please describe how the DEIR takes into account the required Downtown Traffic Study as
stated on page 2.3 of the Circulation Element of the General Plan. I realize a traffic study was
completed for the Railyard Master Plan. This took place many years ago and I do not feel it
adequately addresses issues faced today with increased traffic from Pioneer Commerce Center,
Henness Flats Housing, the new Truckee Parks and Recreation building and Frischman Hollow
housing all utilizing Donner Pass Road to enter into the Downtown Core.
7. On page 4-29 of the General Plan Circulation Element it states that, “The Glenshire Drive
realignment will be a required component in the planning, design and development of the
Railyard project. Other projects, outside of the Downtown Specific Plan Area, will contribute
to the need for this improvement, and should be required to participate in its funding. The
precise alignment, intersection configuration, and classification of this roadway will be
determined during planning and development of the Railyard project, and the Downtown
Traffic Study.
Please explain how Canyon Springs can be considered at this time without this
infrastructure in place and/or how Canyon Springs plans to contribute financially to develop
this required infrastructure.
8. The DEIR also makes the assumption that this infrastructure will be in place and bases its
traffic analysis on this assumption. The Railyard has made no indication it will be completing
this required infrastructure in the near or distant future as they lack the necessary funds to
make this a reality.
Please revise the traffic study to accurately assess the existing conditions at Glenshire
Drive/Donner Pass Road without the Railyard Bypass.
9. The traffic study says no need to evaluate traffic impacts at intersections outside Glenshire
neighborhood during school hours-this is incorrect as Glenshire Drive is accessed by Prosser
Lakeview and Prosser Heights neighborhood families taking their kids to school and preschools.
Please revise study to include Glenshire Drive and Donner Pass Road during peak school drop
off and pick up hours.
10. Despite accessing Martis Peak Road to leave the project site, those drivers taking their
children to Glenshire Elementary school will inevitably continue to town on Glenshire drive via
Glenshire and not turn around to take I-80. This was not taken into account in the traffic study.
This reality of school year traffic needs to be analyzed and the traffic study must be revised.
11. I do not believe that the impacts to Somerset Drive and Courtney have been adequately
assessed. This intersection is used by Juniper Hill residents as well as Glenshire residents and is
a main access point for parents driving their children to school from August to June. Most
parents will avoid the Somerset/Glenshire drive intersection when driving their children to
school, preferring to use Courtney and the back streets to get to Glenshire Elementary. Please
revise the traffic analysis to account for this omission in the data.
12. Please revise the current traffic study to account for all intersections that access Olympic
Heights from Glenshire Drive. There are no protected turn lanes along Glenshire Drive at this
time and with a speed limit at 45 miles per hour, this will pose a serious safety hazard with the
increased traffic from Canyon Springs.
13. At build out this project proposes to add 2578 ONE WAY vehicle trips on our roadways (Pg
4.14-29 Transportation/Traffic Section DEIR.
Please explain and provide detailed analysis to support the assumption that with the
Edinburgh Drive Access allowed there would be fewer than 1000 cars utilizing this street on a
daily basis.
As half of the proposed development would be closer to Edinburgh Drive, I do not
believe that less than one fifth of all car trips would utilize this access, as it is closer to town
than Martis Peak Road.
14. Please explain how there is only an increase of 20 cars using a proposed Edinburgh Access
from a 2011 project to a 2031 project levels, ie. supposed build out. The latter phases of
Canyon Springs are located in closer proximity to access points at Edinburgh, not Martis Peak
road. Please provide accurate and thorough analysis to prove the consultant’s assumption that
there would only be an increase of 20 cars over 20 years.
15. Please conduct a safety study at Glenshire Drive and Somerset Drive. As a mother who
takes her son to the bus and picks him up at this location everyday during the school year I
observe no less than 1/5 of all cars running the stop signs on a daily basis. This does not include
the majority of drivers who do a roll-through the stop sign at a reduce speed. I called the police
department last year to file a complaint and received no follow-up. I believe this will be
exacerbated by the increase of cars that will result from Canyon Springs.
16. Please address the safety issue regarding existing roadways that will be utilized from this
development into downtown Truckee, as well as down Glenshire Drive to Hirschdale and Boca
Reservoir and beyond. These two main thoroughfares are widely used by cyclists when the
roads are clear of snow. As they exist today, these roadways are inadequate to accommodate
both cyclists and motorists. It is a danger to cyclists and motorists in that there is not adequate
room for a cyclist to safely ride their bike alongside a passing motorist. I did not see this
addressed in the DEIR and believe this is an unacceptable omission. Canyon Springs must
address the impact they will create with the addition of so many new motorists as well as new
cyclists on the road.
17. What is developer’s plan for trail connectivity with the rest of the region, including the
Truckee river legacy trail? The proposed trails on the site do not connect with existing, public
trails.
SAFETY
1. This is a heavily wooded area prone to wildfire as seen during the catastrophic Martis Fire of
2001.
What is the evacuation plan in case of a fire and one of the access points at CS is closed?
GREEN HOUSE GAS (GHG) EMISSIONS
1. California has been at the forefront of climate change legislation with SB 375 and AB 32.
Despite the lack of mandates at the local level regarding allowable GHG emissions, the
proposed emissions will far exceed allowable levels in other jurisdictions.
How will this project mitigate the GHG vehicle emissions created with 20+ years of
construction traffic, likely to be many more than 20 years due to the depressed housing
economy.
2. The building industry is responsible for a considerable amount of GHG emissions both with
the creation of building materials, the on-the-ground act of construction and the life of the
structure and its inhabitants. Canyon Springs proposes to address energy consumption,
pollution and its impacts to GHG emissions levels with a set of so-called Design Guidelines. The
Design Guidelines are merely suggestions for what the builders and occupants of the proposed
housing can do to limit their impacts to the environment. There are no requirements listed,
instead words like should and could fill the pages. This is a weak document at best that does
nothing concrete to address the impacts created by an additional 200+ homes in the region.
Please describe how these proposed “Guidelines” will mitigate the impacts created by a
housing development with 200+ units?
3. The Town of Truckee has required GHG studies for previous development applications,
including but not limited to, PC-1, PC-3, Avery Hotel and Hilltop. (Please see Initial Study for
Avery Hotel and see pages 13, 14 & 15 in the Initial Study for the Hilltop Master Plan for
specifics on required mitigation measures with respect to GHG emissions.) As a required
mitigation measure for possible GHG emissions for the Avery Hotel, a project that did NOT
require an EIR, they must have their project LEED Certified. The mitigation measures for the
approved Hilltop Master Plan included requirements for building green above and beyond
those required to satisfy Title 24 Standards.
Please explain why these other projects were required to address GHG emissions with
stringent requirements and Canyon Springs is proposing weak, unenforceable mitigation
measures.
AESTHETICS
I believe this project is in conflict with a number of the Goals and Policies listed in the
Aesthetics section of the 2025 General Plan.
1. Goal CC-1 Preserve open space in Truckee that contributes to the town’s scenic mountain
community character.
Allowing a high density subdivision at the periphery of the Town of Truckee does not
contribute to our scenic mountain community character. Instead it supports sprawl and blight
and continued high density development into Nevada County and beyond.
Please explain how this project contributes to the town’s scenic mountain community
character with the removal of many trees, so much impervious asphalt, intrusion into a healthy
watershed and over 5000 daily vehicle trips added to our roadway.
2. CC-P1.3 Cluster new development so as to preserve the maximum amount of desired types
of open space, as identified in the Conservation and Open Space Element.
This project as proposed is not clustered. It is a sprawling, multi phased, high density
subdivision with fractured open space, located at the eastern boundary of our town. This sets
the stage for additional sprawling subdivisions to the east and beyond.
The proposed phasing plan includes an initial Phase 1 that is comprised of 37 homesites
that begin at the north entrance to the development and sprawls all the way to the
southernmost access point of the property. The subsequent seven phases will then try to fill in
the massive areas disturbed by this initial phase.
Please explain how this development is clustered and preserves the maximum amount
of desired open space.
3. P2.5 Preserve the scenic qualities of the Truckee River and other natural waterways through
setback standards, as identified in the Conservation and Open Space Element, and by ensuring
that new development respects and enhances the aesthetic qualities and natural environment
of these river corridors and waterways.
This project as proposed will impact fragile ecosystems and waterways that are direct
links to the Truckee River. Please explain how allowing building lots that encroach into the 100
year flood plain support the above stated policy.
4. P5.2 Require all new development to incorporate high quality site design, architecture, and
planning so as to enhance the overall quality of the built environment in Truckee and create a
visually interesting and aesthetically pleasing town environment.
We have seen and continue to see approved residential subdivisions sit idle and become
blighted, unimproved wastelands. How will this proposed development ensure that despite a
weak housing economy, they will be able to uphold the standards set above in Policy 5.2 of the
Community Character Element of the General Plan? What will protect the surrounding
residents from becoming negatively impacted by an approved subdivision that fails to thrive?
5. On page 4.1-9, section b of the Aesthetics discussion, as well as in the Project Description, it
states that the project site is 1.6 miles from the Town Core. This is a gross error as those who
live in Glenshire, to the west of the proposed property drive 8 miles to and from town. I am
concerned that this indicates the DEIR consultant did not visit the project site.
Please reassess this statement to correctly designate the location of this proposed
development and provide the public with the assurance that the consultant did in fact visit the
project site.
6. On page 4.1-30 it states that temporary stockpiles for grading and filling will be contained
and kept from contaminating waterways with sediment.
Please describe and explain in detail how the developer plans to do this. How will the
developer ensure that the waterways and the surrounding environment are not degraded
during long periods of delays in construction.
7. This is proposed to be an 8 phase development over the course of 20 years, believable if the
building environment were healthy and sustainable, which it is not. Unfortunately we have
seen a sharp decline in the construction industry in the Town of Truckee for the last 5 years.
Who will ensure that stockpiles of dirt that are unattended over time will not
breakdown and infiltrate the waterways that flow into the Glenshire pond and beyond into the
Truckee River?
8. On page 4.1-31 it states that there will be 2600 linear feet of new, off-site water mains.
Please explain how this will not disrupt the quality of life and access to jobs and services
for existing home owners in the area.
Please explain how existing home owners will not bear the burden of the cost to
construct off-site improvements to the water main.
9. On this same page it states that tree removal will not affect the overall tree canopy nor
impact views from surrounding mountain viewsheds.
Please explain how removal of trees on-site will not affect the overall tree canopy nor
impact views from surrounding mountains to the project site. If one removes trees from the
project site, does that not affect the tree canopy?
10. On page 4.1-32 it states that glare from paved surfaces will be mitigated by landscaping.
Please explain how landscaping mitigates the impacts of glare?
11. On page 4.1-33 it states that “there are no reasonably foreseeable projects in the vicinity of
the project site.”
The property directly to the east and north of Canyon Springs, aka Planned Residential
Development 2 or the “Teel Property” is comprised of 850 acres and would allow up to 275
residential units as well as 10 acres of commercial development near Hirschdale. Please
describe how this developable land is not a foreseeable project in the vicinity of the project
site, especially if Canyon Springs is allowed to move forward at its proposed density.
In addition to PRD 2, there is Elkhorn Ridge at the project’s western property line, Sierra
Bluffs at the western edge of Glenshire, Cambridge Estates to the west and existing unbuilt lots
in Glenshire, Juniper Hill, and Martis Peak Road. Depending on how this project is reviewed,
the case could be made that Gray’s Crossing, Old Greenwood, the Railyard, Pine Forest, Hilltop,
Winter Creek, PC-1, and PC-3 will all impact and be impacted by Canyon Springs.
Please address this project within its true context in and around the Town of Truckee
and not as existing in a bubble, separate and disconnected to everything around it. I
respectfully request a revision to the statement that there are no reasonably, foreseeable
projects in the vicinity.
AFFORDABLE HOUSING
1. This project is required by the Truckee General Plan’s Housing Element to provide 15%
inclusionary housing to satisfy the affordable housing mandates established with the 2025
General Plan. The project applicant is proposing to provide 8 affordable lots on which someone
(it is not clear who this entity would be) would build multi-family housing. The intent of the
inclusionary housing policy was to provide affordable housing at a variety of income levels, but
specifically to design the housing in conjunction with, not at odds with the proposed style of
housing in the development. This project is in conflict with the General Plan in a number of
ways.
First, the developer proposes to construct the affordable lots in Phase 5 of this
development. There is no guarantee that this will ever occur, as the building industry has sunk
to record lows and despite there being a greater need than ever to construct affordable
housing, this developer is avoiding the requirement of building/providing affordable housing by
putting it off to an unspecified time. Gray’s Crossing was required to build affordable, single-
family cottages as part of their development agreement in Phase One of their project. Those
units have never been built.
Please explain how this development will be required and monitored to not only built
the required affordable lots and units but provide them in a timely manner.
Additionally, this proposal is at odds with the Housing Element in that the type of
proposed affordable housing is not seen anywhere in this geographical location. There is no
multi-family housing in proximity to this area. The closest multi-family housing is at Henness
Flats, 10 miles from the project site or Stoneridge Condominiums located adjacent to the
Truckee Cemetery. This project needs to offer affordable lots and/or homes in order to comply
with the intent of the General Plan’s Housing Element.
Please explain how the project’s proposal supports the intent of the General Plan’s
Inclusionary Housing Policies.
LAND USE/PLANNING
1. Goal LU-1: Manage growth so as to maintain the unique qualities and character of the Town
as a small mountain community.
Please explain how we are managing growth with the approval of a project such as
Canyon Springs? The scale and density are out of proportion with the small town character of
our town.
Please explain how the intensity of required infrastructure improvements, specifically
with regards to roadway modifications supports the Goal stated above.
2. Goal LU-7 Encourage clustered residential development to create efficient development
patterns, and to minimize environmental impacts and threats to public safety.
I believe this project conflicts with the above stated Goal. The impacts created with this
project with respect to increased traffic, disturbance to the wildlife corridors and fire safety are
not mitigated sufficiently. Danger to pedestrians, cyclists, wildlife and motorists will increase
with an additional 5000+ vehicle trips per day on Glenshire Drive. The proposed wildlife
corridor is at odds with the existing corridor on site due to its reconfiguration from a north
south orientation to an east west orientation. A wildfire that blocks access to one or more of
the modes of egress at the site would be catastrophic. Please revise the mitigation measures to
adequately address these safety and environmental impacts.
3. P7.2 Residential development shall be clustered to avoid areas of significant natural
resources, including wildlife habitat and migration corridors and visual resources.
Reconfiguring an existing wildlife habitat corridor to accommodate proposed
development is at odds with the above stated policy. Please address how this development
supports the above stated policy.
4. Table LU-7: This table defines Rural Clusters as: “Small clusters of two to six dwellings; each
dwelling unit located in proximity to units on adjacent property Location” Rural residential
areas on Town edges.
As Canyon Springs’ eastern boundary comprises the eastern boundary of the Town of
Truckee the development as proposed is at stark odds with this land use designation. This
development is proposed at the Town edge. Below the Rural Clusters designation is the Rural
Suburban Clusters designation which defines itself as:
Location: Sites peripheral to Town core, generally not on sites within the rural fringe.
NB: This clustering type should be implemented in conjunction with guidelines under Goal LU-7,
in order to avoid “rural sprawl”
This is a direct conflict with a General Plan policy. According to the General Plan the
proposed clustering style applied at Canyon Springs should be located on a parcel adjacent to
the Town core, not at the easternmost edge of the Town of Truckee. Canyon Springs is
proposing a clustering type that is defined as sprawl in our General Plan!
Please explain how this development proposal is not “rural sprawl” as it is not located
peripheral to the Town core, IS within the rural fringe and has a land use designation much
greater than the LU-7 table promotes.
I am hopeful that as this DEIR review process unfolds and the many issues and concerns of the
citizens of this town are addressed, it will become apparent that this proposed development is
inappropriate and stands in stark contrast to the Vision, Guiding Principles and Policies drafted
during the 2025 General Plan Update process. This project proposal amounts to a sprawling
subdivision located as far from the Town Core as could be and was never intended to be
developed at such a high density, as its zoning designation was revised and increased through a
General Plan Amendment brought forward by a developer to Nevada County in 1991.
It is in the best interest of the Town of Truckee and its hired consultants to revise, repair and
resubmit this DEIR to the community in order to fully acknowledge and address the magnitude
of environmental impacts this project would inflict if allowed to move forward as proposed.
In closing, I am appreciative of this opportunity to share my questions and concerns regarding
the proposed Canyon Springs development.
Sincerely,
Nikki Riley
LEED AP
Glenshire Resident
Board President Mountain Area Preservation