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Home My Public Portal AboutCanyon Springs DEIR Public Comment #67 (Truckee River Watershed Council)TRUCKEE RIVER WATERSHED COUNCIL PO Box 8568 Truckee, CA 96162 Ph: 530-550-8760 www.truckeeriverwc.org March 5, 2013 TO: Denyelle Nishimori, Town of Truckee FR: Lisa Wallace, Truckee River Watershed Council RE: Canyon Springs Draft EIR Dear Ms. Nishimori, Thank you for the opportunity to provide feedback and comment on the Draft EIR for Canyon Springs. The Truckee River Watershed Council brings the community Together for the Truckee - to protect, enhance and restore the Truckee River watershed. We identify, coordinate, fund and implement restoration and preservation projects directly related to the health, beauty, and economy of the watershed. Combining sound science and a deep understanding of our region’s values, we focus on the root causes of threats to the Truckee River watershed. Based the mission of the Watershed Council, we reviewed the following sections of the Draft EIR with the associated figures and appendices:  4.2 Agriculture and Forestry Resources  4.4 Biological Resources  4.6 Geology, Soil, and Seismicity  4.9 Hydrology and Water Quality  4.10 Land Use Planning  4.13 Public Services and Recreation  6.0 CEQA-Required Assessment Conclusions 4.2 Agriculture and Forestry Resources From our perspective, it appears the document for the most part adequately addresses Agriculture and Forestry Resources. We would like to note following point for the consideration:  Forestry Planting. We have the following recommendation regarding the replanting addressed in section “D.1.d Result in the Loss of Forest…” (Figure 3-6). The replanting standard of 35-foot center is ineffective to meet goals of forest health and wildlife habitat (vs. for example, a timber plantation). We strongly recommend replanting and (and forestry management) meet a more effective standard, as for example, defined by the US Forest Service in An Ecosystem Management Strategy for Sierran Mixed-Conifer Forests (North et al. 2009), also referred to as General Technical Report (GTR) 220. 4.4 Biological Resources From our perspective, it appears the document for the most part adequately addresses Biological Resources. We would like to note following points for the consideration:  Wetlands (and Wet meadows). Wetlands and wet meadows are now rare habitat in the Truckee River watershed. Among other attributes, these are valuable for birds and for water quality. While the Draft EIR addresses the wetlands in the project area, the development nonetheless will be adjacent to those wetlands. Our experience shows wetland habitat to be very appealing to humans (attracted by the water, plants, and wildlife) who tend to walk through and around the habitat. Increased access and proximity often results new use patterns around the wetlands, for example “volunteer trails” created through, thus and damaging, the wetlands. We strongly recommend additional protections for the wetlands (and associated wet meadows and riparian areas, i.e. Buck Creek, secondary drainages, and the 78 square feet of meadow areas for installation of wood piles for footbridges). For example:  Using California Department of Fish and Wildlife requirement of 100’ setback for all wetlands/drainages (vs. the 50 foot setback required by Town Code);  Restricting or discouraging human access via thorough signage, plantings (wild rose and other natives), and temporary fencing protect these sensitive areas.  Invasive Weeds. Weeds, and especially those classified as Invasive Weeds, are present and spreading in the Truckee River watershed. Invasive weeds degrade native vegetation and habitat, and negatively impact wildlife, recreation, and fire suppression. We strongly recommend measures for prevention against the introduction and minimizing the spread of invasive plants. For example:  Prior to construction, a qualified botanist should survey the construction area and map the presence of all noxious weed species by species, quantities, life stage, and location;  All noxious weed species should be reported to Nevada County, and treated as recommended;  Soils where noxious weeds are present shall not be mixed with soils with other noxious weed-free soils.  Incorporate specific measures for preventing and minimizing the spread of invasive weeds, as outlined in the California Invasive Plant Council’s (CAL-IPC) “Preventing the Spread of Invasive Weeds: Best Management Practices for Transportation and Utility Easements”. These are available on-line: http://www.cal-ipc.org/ip/prevention/landmanagers.php and http://www.cal-ipc.org/ip/prevention/tuc.php.  Require applicant and Town construction and maintenance contractors to follow the best management practices for invasive weeds as defined in the CAL-IPC checklists. 4.6 Geology, Soil, and Seismicity From our perspective, it appears the document adequately addresses Geology, Soil, and Seismicity. 4.9 Hydrology and Water Quality From our perspective, it appears the document for the most part adequately addresses Agriculture and Forestry Resources. We would like to note following point for the consideration:  BMPs. It appears stormwater management and other Best Management Practices for erosion control, runoff, and water quality protection are addressed at the level required for a Draft EIR. However, it is our observation and experience that even the recent residential and commercial development in the Truckee River watershed are being implemented with ineffective techniques and practices in stormwater management and construction management. We strongly recommend a robust review of drainage plans, grading plans, stormwater management specifications and all other associated documents so that water quality is protected even with the development of roads, trails, and residences. 4.10 Land Use Planning Any comments we have regarding consistency are discussed in other parts of this letter. 4.13 Public Services and Recreation There could be some confusion in purposes of the “recreation” and “open space” plans put forth. Section 4.4 Biological Resources acknowledges, for example, the Verdi subunit of the Loyalton-Truckee Deer Herd and the proposed development is clustered to leave a migration path open for the herd. However, it appears that a proposed trail system transects the migration corridor. The goals and uses of the recreation and open space designations should be clarified and any conflicts addressed so that, for example, multi-use/high-use trails are separated from migration corridors and stream courses. Existing dirt roads that lead through meadows and wet areas should be decommissioned with educational signs about restoration and sensitive habitats, and a trail in the upland areas can be created and encouraged. 6.0 CEQA-Required Assessment Conclusions From our perspective, it appears that the CEQA-required Assessment Conclusions are consistent with the environmental evaluation of Chapter 4.