HomeMy Public PortalAboutCanyon Springs DEIR Public Comment #63 (Kelley)Lori Kelley
lkelleyl@sbcglobal.net
March 4, 2013
Denyelle Nishimori, Senior Planner
10183 Truckee Airport Rd.
Truckee, CA 96161
dnishimori@townoftruckee.com
Re: Comments for Canyon Springs DEIR
Dear Denyelle,
Below are the comments I am requesting be addressed regarding the adequacy of the DEIR for
the proposed Canyon Springs development project.
Aesthetics
The DEIR contains no maps in the Aesthetics section showing an overlay of proposed project
site onto actual current landscape photos of trees, habitat and scenery, including housing models
placed to see how the view shed would be impacted. How will this be addressed so the readers are
able to sufficiently comprehend and comment on the aesthetics impacts? This is especially necessary
due to some lots being proposed on ridges.
Will mitigation measures implement removing lots from the plan that would obstruct the view
shed once built upon? If not, what mitigation measures would be implemented to insure this view
shed not to be compromised?
The DEIR makes an assumption that “Currently, the principal source of light pollution in the
vicinity of the project site is development with the Town limit”. Where is the evidence to support this
statement (P4.1-23). Further, if this were the case, there is no evidence that the current project will
not significantly add to the light pollution. Who would monitor light pollution when homes get built,
and how would it be guaranteed to be under control? The DEIR states “Grading for future homes and
grading operations would be carefully managed to blend into adjacent non-graded areas and protect
existing trees” (P4.1-31). How would this be overseen and guaranteed? The DEIR needs to be show
proof that a sufficient bond would be posted by the developers to insure this is carried out throughout
the infrastructure and build out process (20+years). DEIR states “Infrastructure improvements would
comprise approximately 2,600 linear feet of new off-site water mains. As show on Figure 3-11 in
Chapter 3… the new 10-inch water main…. would not substantially alter the visual qualities of these
areas”. (P4.1-31) It is very difficult to find this on Figure 3-11, and needs to be highlighted or magnified
so the average reader can gain a true understanding. Again, visual impacts need to be adequately
transparent in the DEIR.
The DEIR states “a cumulative impact would be considered significant if, taken together with
past, present, and reasonably foreseeable projects in the Town of Truckee SOI and the Boca Quarry
project in Nevada County, the project would contribute to an adverse effect on a designated scenic
vista, the degradation of the view from a scenic highway, exposure of people on- or off-site to
substantial light or glare, or if it would result in a substantial degradation of the visual quality or
character of the project site and its surrounding. There are no reasonably foreseeable projects in the
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March 4, 2013
vicinity of the project site”. (P4.1-33). There is no real quantified basis for this assumption of “…no
reasonably foreseeable projects in the vicinity…”. How long ago was this assumption made? The 362
and 320 acre parcels adjacent to the eastern and northern edges of the project could very well propose
development well before the infrastructure would be in place for the proposed Canyon Springs project.
In order for the DEIR to adequately address “cumulative impacts”, all possible scenarios need to be
taken into consideration and addressed in the DEIR.
The aesthetics section of the DEIR does not include impacts or cumulative impacts that take
into consideration the possibility of this project becoming, for an unknown period of time, an un-built
(ghost) development, as in Elkhorn Ridge or Sierra Bluffs in the same vicinity. Such an occurrence of
blight severely impacts view shed/aesthetics. How would this be prevented or mitigated?
Agriculture and Forestry Resources
The DEIR refers to Town of Truckee GP 2025, page 7-12 (P4.2-5): “Areas of rangeland
vegetation in and around Truckee generally provide the best potential for agricultural uses; however,
there is no active grazing taking place in Truckee today”. How can it be proven that this statement
would apply in 20+ years (expected life of this development project)? Can it be proven that there will
not be a need for increased agricultural uses in the Truckee region in the next 20+ year future? Local
community farming has become a necessary trend for the past 10+ years. What are the cumulative
impacts in this scenario?
The DEIR claims “Overall, the 176.17 acres of public open space on the project site would be
permanently reserved by protective conservation easement or dedication to the Town of
Truckee/Truckee Donner Land Trust”. (P4.2-7). Where is the data to support this assertion?
Agreements of such conservation easements and acceptance of dedications by the Town of
Truckee/Truckee Donner Land Trust need to be included in the DEIR for support. Also, “permanently
reserved” needs to be clarified for the readers.
Biological Resources
Plant Communities
Sawyer and Keeler-Wolf 1995 reference used for analyses in the DEIR is outdated. This has
been updated in 2009 and analyses need to be done with the updated reference.
The updated/current 2010 Alliances and Associations of Habitats on the CDFW website need
to be used in the DEIR analyses.
Snags
P4.4-26: These microhabitats provide feeding habitat for woodpeckers and nesting and
roosting habitat for cavity nesters, including owls, woodpeckers, and bats. Approximately 72 snags
occur on the project site.
P4.4-40: Project impacts: Implementation of the project would result in removal of
approximately 27.92 acres of Jeffrey pine community, approximately 7.25 acres of sagebrush
community, and removal of approximately 26 snags. These communities provide potential habitat for
Sierra Nevada red fox, goshawk, willow fly-catcher, and yellow warbler, and removal of this habitat
could impact these species if they are present on the project site during construction. An additional
approx. 76.68 acres of these combined communities would occur within the residential and recreation
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March 4, 2013
lots subject to increased human presence, and could result in this habitat becoming less suitable for
these species.
Figure 4.4-43: Indicates approximately 17 snags will be removed on southern portion of
project, just to accommodate a few parcels. The DEIR does not indicate on the map which snags will be
removed, and puts the reader in the position of making assumptions. Further, it appears that 10 of the
72 existing snags on site are the only 10 on the upper north half of the project site. Figure indicates
that all but possibly 2 or 3 of these snags would be removed to accommodate the placement of
lots/roads. This snag removal along with the proposed deer and other wildlife habitat removal would
basically destroy the possibility of wildlife thriving in this upper portion of the site, making this impact
“significant”. How will the DEIR amend the project to lessen this impact to “insignificant”?
DEIR goes on to say that most of the potential impacts to wildlife that feed or nest off of the
proposed habitat and snags to be removed or cut up by residences and trails, would be “less than
significant”. There needs to be more study data, under direction and supervision of the CDFW,
especially for the removal of the snags – this could be detrimental to many species in the region. There
needs to be further research on how waiting to cut trees down until after nesting season, will the birds
return? I understand that birds did not return to The Old Greenwood project in Truckee, after cutting
trees down.
Special-Status Wildlife
Bats
P4.4-56 Impact BIO4: Removal of Jeffrey pine habitat and snags could potentially disturb
roosting bats if active roosts are present on the project site.
P4.4-56 Mitigation Measure BIO-4: At least two days prior to removal of snags and potential
roost trees, construction activities shall commence in the vicinity of the potential roosts to expose bats
potentially using the roosts to the sounds and vibrations of equipment with the intention of causing
the bats to leave the roost, thus avoiding potential injury when the roost is removed.
DEIR contradicts itself, wherein Impact BIO4 states removal of habitat and snags could
potentially disturb roosting bats, but then suggests a mitigation measure that would definitely disturb
roosting bats by imposing the sounds and vibrations of equipment onto them with the intention of
causing bats to leave the roost, thus avoiding potential injury when the roost is removed. While
removing snags after forcing the bats out of their roost may avoid potential injury when a roost tree or
snag is removed, the alternative of the trauma caused by to forcing them out of their roost with loud
construction noise pollution, basically “bullying” them out of their roost, deems this not an acceptable
mitigation. This scare tactic and removal of trees/snags would likely initiate a decline in the bat
population in the region, by virtually removing one of their roosting areas. The response from my
friend’s daughter when she heard about this so called “mitigation measure” for the bats sums this up
(this came from what she learned in an anti-bullying project at school). Her comment: “I think the
developers need to put themselves in the bats’ shoes!”
This proposed mitigation measure for bats is inhumane and dangerous to the species. The
DEIR needs to readdress this. The only acceptable mitigation measure is to leave the wildlife habitat in
place and devise a way to develop around the habitat. (Put yourself in their shoes!)
Got off track a bit here, but the wildlife habitat and snag destruction is not necessary; please address
how it can be preserved while still developing this site?
L Kelley/D Nishimori
March 4, 2013
Back on track…this unnecessary removal of Jeffrey Pine habitat and Snags conflicts with Town
General Plan Goal COS-5, Policy P5.3: Protect to the extent possible federal or State-designated
endangered, threatened, special status or candidate species. This COS-5, P5.3 is conflicted with in
many areas of the biological section of this DEIR. Removal of wildlife habitat and snags will be
detrimental to the bird population in the region, causing a severe decline.
Bald Eagle
P4.4-29: No bald eagles were observed on or near the project site during previous surveys.
There have been many sightings of bald eagles on the site and in the vicinity (within one mile),
especially due to bodies of water in the vicinity.
Loyalton-Truckee Verdi sub-unit deer herd
The Loyalton-Truckee Verdi sub-unit deer herd (VSU) is known for utilizing the project site for
their spring and fall migration, as well as summer foraging. This area is vital to the herd in order for
them to get to their fawning grounds in the spring, forage in the summer to help maintain a healthy
state, then to return to their wintering grounds in the fall.
The project conflicts with the Town General Plan (GP) Goal COS4-P4.1 – in that the plan does
not adequately provide for the integrity and continuity of biological resources open space, habitat and
wildlife movement corridors, as the open space proposed would be interrupted by trails, roads,
humans and dogs, including removal of habitat, and is not contiguous or large enough.
The project conflicts with the Town GP Goal COS4-P4.2 – in that the plan does not protect
sensitive wildlife habitat from destruction by incompatible land uses where appropriate, i.e.
movement corridors are being disrupted by too much habitat removal, development, 20+ years of
noise and air pollution, and disrupting connectivity of the VSU herd.
The project conflicts with the Town GP Goal COS-5 – in that the CDFW deems the VSU as a
declining and valuable biological resource.
P4.4-27states (In reference to the Verdi sub-unit (VSU): “This subunit is known to utilize the
project site and surrounding area for migration purposes. Wildlife corridors are within the project
area designated as open space”. This statement makes an assertion that the deer use only the open
space of the project, when cameras and sightings in other areas of the DEIR indicate they also use
portions of the project that is proposed to be developed on. How can it be proved they do not use any
parts of the proposed project other than the designated open space?
P4.4-32 states “According to CDFG in their 1988 Loyalton-Truckee Deer Herd Plan Update, the
majority of the Canyon Springs site is located within a major migration corridor of the Loyalton-
Truckee deer herd”. Then makes assumption: “However, recent data suggests that only a few
individuals use the site as a corridor or for forage at any given time”. This assumption includes no
verbiage following it indicating the support for this assumption (not easy for the reader to find these
materials). The DEIR clearly dismissed 1988 plan due to their current small study data. Their data
gathering is relying on insufficient data.
DEIR Conclusion section of Appendix E, 4-13 states: “Given the size of the population of mule
deer in the region, very few of them utilize the Canyon Springs site during the time period when
migration is expected to occur”. This statement is proven to be inaccurate: see pg 3-3 and 3-6 in
Appendix E: camera study results of the DEIR biologist indicate 151 deer detections on the site during
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the VSU fall 2010/spring 2011 migration periods. Per the DEIR, the estimated count of the VSU herd is
approximately 800, therefore 151 camera detections on the site equates to approximately 20% of the
total herd count. This study data indicates many of the deer utilize the Canyon Springs site during
times when migration is expected to occur. This is especially true given the cameras were out for only
two 65 day periods, at only four stations of each corner of the site, and on only 283 acres! (If the count
were only10% of the herd utilizing this site, it would be very significant!) .
Conflicting statements in DEIR, section 4.2 of appendices, first paragraph, it is stated the LTDH
uses the general vicinity of the Canyon Springs site and other areas in the vicinity during
migration. Last paragraph states the site is not a major deer migration corridor.
Have the DEIR consultants given the project owner’s deer report any independent peer review
or consulted any other experts for other information or possible dissenting opinions. The deer analysis
appears to be biased due to conflict of interest and needs more factual and recent data.
Has John Heal consulted in the capacity directly for any of the project owners, developers,
engineers or other related parties? If so, this warrants a peer review of his research and studies before
the project goes before the Planning Commission for approval.
P4.4-38: states “the project would also include the installation of approximately 2,600 linear
feet of new off-site water mains adjacent to existing roadways in the Glenshire residential area located
to the west of the project. It does not state the exact location or what seasons this would occur in. This
could have a significant impact on the VSU deer herd due to documented camera sightings. What
wildlife studies will be done in conjunction with Town GP Goal COS-4 and 5 to protect sensitive
wildlife habitat from destruction and intrusion by incompatible land uses, maintain biodiversity with
special consideration of the VSU , a valuable biological resource, etc.? SOS Glenshire has shared data
from a wildlife camera study that indicates hundreds of deer sightings in a concentrated stretch along
Glenshire Drive west of the project sight over spring-fall 2011 and 2012, 398 in one area and this was
with one of the two cameras failing for about half of the deployed time. The DEIR needs to fully
disclose details and deploy strict mitigation measures to eliminate any “significant impacts” this water
main project installation would cause to the VSU and other wildlife.
Per February 2013 phone communication I had with Sara Holm, Wildlife Biologist with
California Department of Fish and Wildlife (CDFW):
1. Sara Holm stated the DEIR biologist camera study count of 151 indicated significant use of this
site by the VSU in migratory seasons.
2. Hundreds of deer occurrences were captured on 16 CDFW cameras deployed adjacent to and
on the border of Canyon Springs site, including bucks, does, fawns, and collared deer Sara
stated this is significant when cameras were placed randomly, not knowing where most of
deer had been cited. Cameras were placed along top northwest corner and south & southwest
corners and over an approximate two year period (winter not included). Significant deer
usage was recorded at edge of both north & south project site.
3. CDFW and Nevada Department of Wildlife (NDOW) collaring study for the deer herd has been
underway since fall 2009 and still has 3 collars to deploy in spring 2013. There was 1 collared
deer between 11/5/11 & 11/6/11 recorded going through Canyon Springs property
(definitely migrating), along with two others on the Canyon Springs property. This is
significant, as these 3 deer were collared randomly and away from Canyon Springs, so
anticipating the new collar data to show more.
4. The deer are site faithful - like to use the same path, and use same summer and winter
ranges. Last set of collars proved they followed same paths, and when a change happens, it
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affects their energetics, wasting energy, does are pregnant when they arrive - they are already
energetically taxed when they go through the winter - it can affect their ability to survive.
Deer spend majority of their time on summer range, if they have does in poor condition and
they cannot have new fawns, the herd will not maintain themselves. This is a migrating herd of
deer, and can’t just look at any one part of their life cycle, as they won’t survive one cycle
without the other. All 4 phases are as vital as the other – Winter Range, Migrating, Summer
Range, and Fawning Grounds.
5. Existing satellite collars indicate the deer use very small summer ranges, within 1 – 2 square
miles. So, this indicates that home ranges are so small that to document any significant Canyon
Springs deer usage, the collaring would have had to been on or very near the Canyon Springs
site. Preliminary reports John Heal acquired from NDOW (appendix E, pg 4-23) were collared
on the wildlife area, not the Glenshire area. If deer were collared on the Canyon Springs site,
Sara would expect them to use the site extensively, and not much on other land.
6. When asked why deer were not collared on the Canyon Springs site, Sara replied because there
was a difference of opinion on how data would be used, as the land owners wanted exclusive
use of the data. The owners were initially willing to allow collaring, but the department
wasn't willing to give them exclusive rights to the data. So, they were collared adjacent to the
property, along with 16 cameras deployed.
7. The 14 satellite collars out will not come off until 2014. No final write up being done due to
still actively collecting data. Probably no reports until early 2015, for whole picture for Verdi
sub-unit.
Based on my above comments and outlined communication with Sara Holm regarding the
Loyalton-Truckee Verdi sub-unit Deer Herd, please note the following:
DEIR conflicts with many Truckee General Plan Goals and Policies.
DEIR clearly misrepresents the current VSU usage of the Canyon Springs site, as well as the
importance of this site to the overall herd vitality (per relying on inadequate data, assumptions, and
conflicting statements).
DEIR omits the significant impacts the proposed development would have on the VSU due to
habitat removal, building where they have site fidelity (same paths of movement), interrupting
connectivity and foraging grounds.
DEIR states there is no direct evidence that the deer use the site or critical migration in
substantial numbers – Critical Migration is not explained.
DEIR does not give direct evidence that deer DO NOT use the site for migration.
DEIR discounts summer range, as it is just as critical as the other phases: wintering range,
migration corridors and fawning areas, which is why CDFW and NDOW, the herd’s winter range
managing entity, are working together on the current collaring study.
Per CDFW and NDOW, recent deer activity has been recorded on the Canyon Springs site.
The fact that the CDFW/NDOW current collaring study indicates deer activity on the Canyon
Springs site and being the only comprehensive state wildlife agency study underway for the VSU herd
since 1988, 25 years ago, it is highly warranted to extend this EIR process until the study is completed
and reports prepared. It would be a detriment to the declining valuable VSU deer herd and a vital
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omission in this EIR process to continue to the approval stage of this project that is being proposed in
the middle of their corridor without gaining the information from the completed collaring study. The
wildlife need a voice. We (the public, developers and the Town) are their voice.
All of the above deems the project as proposed to be a “significant impact” to the VSU deer
herd. DEIR needs to be amended to address all above inadequacies.
Hydrology
DEIR does not address the Glenshire Lake. This is a vital omission due to the Canyon Springs
site runoff goes into the Lake, before it then goes into the Truckee River.
Studies need to be done on the water quality impacts project would impose to the Lake and
how the cost of ongoing maintenance of water quality management would be handled.
Land Use and Planning
Sprawl/Infill/Clustering
This project violates Truckee General Plan Goal LU-3 in that it does not minimize the potential
for residential and commercial sprawl. It would create a bridge to open up development to the east by
providing utilities to be connected to. And it does not reduce environmental impacts.
This project does not meet the standards for development definition of infill from the US Green
Building Council.
This project violates Truckee General Plan Goal LU-7 in that it groups too many dwellings to be
located in a rural residential area on Town edge.
Alternatives
DEIR is deficient in all proposed Alternatives because the cumulative impacts and reports were
not addressed or analyzed.
Transportation and Traffic
DEIR indicates no accident data for the portion of Glenshire Drive from Donner Pass to the
West entrance of Glenshire. This information needs to be included and the analysis of traffic impacts
re-done utilizing this information. Many accidents and deer/vehicle collisions have been observed on
this portion of Glenshire Drive. Further, mitigation measures need to be implemented for the already
failing intersections of Glenshire Drive and Olympic Dr, and Glenshire Drive and Highland. What
mitigation measures will be implemented?
P4.14-58 ii: “The roadway segment of Glenshire Drive east of Martis Peak Road as a steep
grade of about nine percent. The existing pavement width accommodates 11 ft travel lanes with no
shoulder in some locations…Therefore, as this segment of Glenshire Drive does not meet the design
standards, it is considered to have an existing geometric deficiency.” The Glenshire Drive east of
Martis Peak Rd roadway segment on has an average accident rate (from 2006 to 2010) about two
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times the State and County average rates for similar facilities. The injury and fatal accident rate is also
higher than the State and County average rates for similar facilities…”
The above-referenced road/traffic information indicates the roadway segment of Glenshire
Drive east of Martis Peak road is a significant impact by being dangerous and hazardous. The stretch
of Glenshire Drive indicates the possibility of the same; however, study data needs to be retrieved
before this analysis can be made. The only analysis I have is on the ground residents observing many
accidents in this section of roadway.
Information listed in the Wildlife Vehicle Collision Reduction Study – Report to Congress,
August 2008 clearly indicates Glenshire Drive, Hirschdale Road and Martis Peak rate high for Wildlife
Vehicle Collisions:
The increase in Wildlife Vehicle Collisions (WVCs) appears to be associated with an increase in vehicle
miles traveled (VMT).
The occurrence of WVCs, however, is associated with many more factors, as reflected by their
characteristics, which include:
•More than 98 percent of WVCs are single-vehicle crashes.
•89 percent of WVCs occur on two-lane roads.
•WVCs occur more frequently on low-volume roads.
• Compared to all motor vehicle collisions, WVCs occur more frequently on straight roads with dry
road surfaces.
•WVCs occur more frequently in the early morning (5–9 a.m.) and evening (4 p.m.–12 a.m.), when deer
are more active and traffic volume is relatively high.
•WVCs occur more frequently in spring and especially in fall, when animals move around more due to
migration, mating, or hunting seasons.
•The vast majority (as high as 90 percent in some states) of reported WVCs involve deer.
What are the consequences and impacts to drivers and animals? This needs to be addressed through
studies and mitigation measures. What wildlife and roadway studies will be done to address this
“significant impact”?
Further, I have obtained SOS Glenshire data from their recent wildlife/roadway camera study
in the area for two spring-fall seasons of 2011 and 2012. The data indicates very high deer usage on or
near areas of Glenshire Dr, Hirschdale Rd, Martis Peak Rd and Edinburgh as follows:
1. Eastern portion of Glenshire Drive area between Martis Peak and Hirschdale Rd: 314 deer
detections
2. Martis Peak Road, just west of the project site: 274 deer detections
3. Glenshire Drive, west of the middle of the project site: 398 deer detections
4. Glenshire Drive, west of Glenshire entrance: 164 deer detections
5. Edinburgh: 99 deer detections (note: camera indicated this area is highly utilized by many other
wildlife species as well)
NOTE: There were some camera/battery malfunctions at locations 1-3 above, so there is a slight
understatement, and significant malfunctions at location 4 and 5, so probably a high understatement.
NOTE: The mapping of this data is not yet completed and should be available early spring 2013.
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March 4, 2013
NOTE: The following information came from a resident at Glenshire and White Horse Road
intersection on March 5, 2013: Summer and fall are the busiest with deer activity. I can confidently say
that in the summer and fall it's a daily sighting. They like to graze across the street last Fall/Summer
seemed to be exceptionally busy with deer up Glenshire Drive on my way home from work. Really had to
watch it. Doesn't surprise me that the Fawn Sign went up, but a few were killed.
P ES4, #4 of Traffic Appendix: (Re: Glenshire Drive east of Martis Peak Road): It is
recommended that the project applicant contribute up to $50,000 to fund a safety study as well as
implementation of safety improvements along this roadway segment.
The above wildlife/roadway data warrants the same recommendation for a wildlife/roadway
safety study and improvements along this roadway. Analysis should be implemented to calculate such
contribution by the applicant. Per many communications with wildlife biologists of the Highway 89
Stewardship Team, signs are not an effective mitigation measures. Fencing and crossings are highly
recommended.
Based on the above information, it is imperative a wildlife/vehicle collision study be
performed, as well as a wildlife/roadway study for the roads that would be impacted by the proposed
development project. SOS Glenshire camera study data seems to be adequate in proving significant
deer usage on the main roadways this project would impact. Lack of addressing these issues is a gross
omission in the DEIR. What studies and mitigation measures will be done to address the “significant
impacts” this project would have on WVCs?
General
I found the DEIR process did not adequately fulfill one of CEQA’s main purposes: To enhance
public participation in the environmental review process through scoping meetings, public notice, public
review, hearings, and the judicial process. The following are the deficiencies I base this finding on:
-DEIR disks sold did not initially include the appendices (although I feel this was unintentional, it still
occurred, causing some reviewing parties the inability to review and comment to their desired level).
-Regarding the one DEIR interactive community meeting held for this project on 1/29/2013, to the
best of my knowledge, there was only one local newspaper publishing, and not even part of the main
newspaper, but in on the very bottom corner of an insert of the newspaper (Tahoe World).
-Also, in regards to this 1/29/2013 community meeting, it was understood that part of the reason for
not holding a DEIR meeting in the Glenshire region was that it needed to be recorded. According to
some who attempted to view the webcast, the recording was very poor with the audience questions
mostly not heard and the only break out venue recorded was the traffic section, but to almost no avail
due to poor sound. Also, this webcast was only publicized on February 27, 2013, seven days prior to
the DEIR comment deadline. Given the size and complexity of the DEIR, this is not sufficient time to
review and comment for the average public member.
-Also, was the project legal description and announcement appropriately published in the local Sierra
Sun newspaper? I observed it in a south shore paper, but not the local one.
-No DEIR Hearing was held, when the Town had held DEIR Hearings on previous project proposals.
The magnitude of this project’s possible impacts warrants a DEIR Hearing to benefit the public,
applicants and the Town.
L Kelley/D Nishimori
March 4, 2013
CONCLUSION
I found that the DEIR in many areas made assumptions/assertions, lacked in providing
adequate/current evidence, studies or information and did not adequately calculate cumulative
impacts to support many of the “less than significant” findings.
Based on the identification of all of the inadequacies and significant impacts outlined in this
letter, the DEIR clearly needs to be revised to fully address these inadequacies, including performing
or allowing the performance of necessary studies, identifying sufficient mitigation measures and fully
complying with the Town General Plan. Further, the new information then needs to be re-circulated to
the public for a new DEIR review and comment period.
Thank you and please feel free to contact me with questions regarding my comments and concerns
addressing the adequacy of the DEIR.
Sincerely,
Lori Kelley
Lori Kelley
lkelleyl@sbcglobal.net