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Home My Public Portal AboutCanyon Springs DEIR Public Comment #71 (Backlund)March 4, 2013 To: Denyelle Nishimori, Senior Planner, Town of Truckee Re: Comments on the Proposed Canyon Springs project DEIR Dear Denyelle, The following are comments and concerns regarding the adequacy of the DEIR for the proposed Canyon Springs housing development: ENVIRONMENTAL EVALUATION Cumulative Projects Considered p. 4-‐4 The Town of Truckee recently updated its long-‐term sphere of influence under the Nevada County LAFCO to include property adjacent and east of the proposed Canyon Springs project. Under Nevada County, this property is zoned for planned development and as such should be included in the scope of this EIR for cumulative impacts throughout the document. The DEIR states “…The residential properties surrounding the project site to the west within the Town limit are primarily considered “built-‐out” under the Town’s zoning designations RS-‐X (Residential Single-‐Family – Built-‐Out) and RR-‐X (Rural Residential – Built-‐Out); accordingly, no substantial reasonably foreseeable projects would occur in this area….” Please clarify how you define build-‐out. Already approved subdivisions including Elkhorn Ridge, and the The Bluffs are largely vacant lots, building is still occurring in Juniper Hills and requests to split and subdivide lots are still submitted for property near Juniper Hills. BIOLOGICAL RESOURCES In the Agriculture section on p. 4.2-‐7, the DEIR states “…A central portion of the project site is zoned Open Space in recognition of a wildlife migration corridor, and the remainder of the site is zoned for residential use…” State of California data for the mule deer migration corridor indicates a north south passage across the proposed project site while the proposed open space runs largely east to west. To suggest the open space set aside in the project will be used by wildlife, mule deer in particular, is speculation unless there is data to support this statement. Goal COS-‐4, P 4.2 Protect sensitive wildlife habitat from destruction and intrusion by incompatible land uses where appropriate. All efforts to protect sensitive habitats should consider (1) Sensitive habitat and movement corridors in the areas adjacent to development sites, as well as on the development site itself, (2) Prevention of habitat fragmentation and loss of connectivity (p 7-‐31) This project blocks a known deer migration corridor, making no attempt to protect it. New deer study data needs to be incorporated into DEIR, as current analysis is not sufficient and updated. GEOLOGY The concealed fault line is shown in Figure 4.6-‐2 to run along the bottom of a drainage. The EIR should include an analysis of the impacts of implementing Mitigation Measure GEO-‐1 (trenching in a waterway) and provide recommendations if the concealed fault is found to be active or potentially active. Mitigation Measure GEO-‐2 should be far more detailed in describing acceptable methodologies for addressing eroding banks and landslide areas adjacent to a waterway. The tentative map in this area should be redrawn to eliminate or shrink the 4 lots adjacent to the landslide areas to assure there is adequate land area for reconfiguring the banks. Lot lines should be placed 50ft from the 100-‐year flood plain, not just the building envelopes dues to the presence of erosive soils and the potential for impacting water quality. Stormwater run off from private property can contain-‐, fertilizers, detergents and a variety of other chemicals that shouldn’t be allowed to contaminate the flood plain. HYDROLOGY FEMA Maps FEMA recently revised their flood plain maps for the Truckee region. In many cases, the revised maps have proven to be inaccurate. Have the FEMA 100 year flood plain maps relied upon for the analysis of this project been proven to be accurate? Martis Peak –Whitehorse Rd/Glenshire Drive intersection The Hydrology section of the DEIR is too limited in scope. It fails to evaluate stormwater management along the proposed approach to the project. This should be included in the EIR. Additionally, the EIR should include the study of storm water management for Glenshire Drive between Martis Peak and Hirschdale Roads. A particularly eroded area already exists on the northeast corner of the Martis Peak-‐Whitehorse/ Glenshire Drive intersection. This area is so eroded, it appears that it could compromise parts of the intersection. A stormwater management plan for the approach as well as this intersection should be included in the EIR. Glenshire Drive from the West Glenshire Entrance to Donner Pass Road: Frequent and random stopping and turning onto Union Pacific property to access the Truckee River creates erosion and compaction to soils adjacent to the roadway. The EIR should include an analysis of these impacts as well as a storm water management plan. LAND USE PLANNING Land Use and General Plan: Goal CC-‐1, 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 (p3-‐30) This development represents sprawling development and not clustered. Project development should illustrate ‘Rural Clusters’ as noted in General Plan (Table LU-‐7, 2-‐ 62) TRAFFIC Adequacy of Glenshire Drive east of Martis Peak Road The final turns in Glenshire Drive traveling west prior to the intersection with Martis Peak and Whitehorse Roads are particularly steep, narrow and provide little to no visibility of oncoming traffic. (p. 12, Traffic Analysis) Cars get stuck on the roadway during snowstorms. It is too narrow for people to turn around, so they must wait in idling cars for a tow truck. Traffic is often slowed or completely stopped as a result. Several of these events happen each winter. The EIR needs to more thoroughly explore the cumulative environmental (emissions) and public safety impacts of these traffic events under the various timeline scenarios discussed in the DEIR. Driver Site Distance to the East of Whitehorse Road (p. 15, Traffic Impact Analysis): The DEIR states, “…The corner sight distance from Whitehorse Road looking to the east along Glenshire Drive is roughly 170 feet, which does not meet the Town’s 330-‐foot corner sight distance requirement….” This condition is proposed as acceptable because drivers traveling along Glenshire Drive have adequate site distance to compensate for unexpected traffic from Whitehorse. However, the influence of grade and speed during inclement weather is currently not and should be included in the EIR analysis of this intersection. As drivers proceed west on Glenshire Drive and approach the intersection with Whitehorse, they are accelerating to get up the steep grade particularly under icy and snowy conditions. If you stop accelerating, you could get stuck on the steep grade. It is difficult to compensate for drivers entering from Whitehorse under these conditions. This should be studied and included in the EIR. Again, if you are traveling west on Glenshire Drive and have to stop because a car in front of you is blocking traffic while trying to make a left hand turn onto Martis Peak Road, then all the cars behind you are at risk of getting stuck. As mentioned previously, this portion of Glenshire Drive is steep and narrow with blind corners. Having traffic back up on Glenshire Drive westbound before the intersection with White Horse and Martis Peak Roads would be particularly hazardous. Analysis of this scenario needs to be included in the EIR. Likewise, approaching this intersection traveling east on Glenshire Drive and then proceeding down the grade just past the intersection under icy conditions is also dangerous. First you are compensating for traffic from Whitehorse and then there is something about the way the road is banked, but it is very easy to end up in the oncoming lane of traffic as you head into the turns just past the intersection. Or, you have oncoming traffic in your lane as drivers coming up the grade navigate around stuck cars on the blind corner. Study of this scenario should also be included in the EIR. The DEIR needs to analyze the structural engineering and design of this roadway for public safety and load capacity. Glenshire Drive from the West Glenshire Entrance to Donner Pass Road: Accident Data should include an analysis of accidents on Glenshire Drive between the intersections with Donner Pass Road and the west entrance to Glenshire with a focus on the area near Olympic Heights. (Appendix, pp. 11 Traffic Impact Analysis) Frequent and random stopping and turning onto Union Pacific property to access the Truckee River creates hazardous conditions along this roadway as well as erosion and compaction to soils adjacent to the roadway. The EIR should incorporate these types of driving patterns and environmental impacts into its analysis of emissions, safety and storm water management. Mitigation of Donner Pass Road/Glenshire Drive Intersection (pps 63-‐65 Traffic Impact Analysis): The DEIR concludes, “…the Glenshire Drive/Donner Pass Road intersection is shown to operate within the LOS thresholds with implementation of the Donner Pass Road Extension….” Pps. 64,65. The data supporting this conclusion should be in Table 22. The DEIR states that “…as when faced with long delays for making left-‐turn movements from Glenshire Drive, drivers can be expected to shift their travel patterns to instead use the Donner Pass Road Extension…” There is a problem with this logic as it presents an incomplete picture. The General Plan allows a LOS of E in the downtown shopping core district. If you are traveling westbound on Glenshire Drive and want to avoid gridlock downtown at Bridge Street, you will have an incentive to use the Glenshire/DPR intersection as it allows you to readily access Keiser to Jibboom to bypass the clogged downtown core. The DEIR needs to consider how preference for avoiding downtown gridlock at Bridge Street could influence vehicle trips through the Glenshire/Donner Pass Road intersection. Scope of Traffic Analysis Laurel Heights Improvement Assn. v. Regents of the University of California (1988) 47 Cal.3d 376, 396 (Laurel Heights I) is the leading case addressing the scope of a project to be analyzed in an EIR. The Laurel Heights I court stated that “an EIR must include an analysis of the environmental effects of future expansion or other action if (1) it is a reasonably foreseeable consequence of the initial project; and (2) the future expansion or action will be significant in that it will likely change the scope or nature of the initial project or its environmental effects.” (See Berkeley Keep Jets Over the Bay Committee v. Bd. of Port Commissioners (2001) 91 Cal.App.4th 1344; Del Mar Terrace Conservancy, Inc. v. City Council of the City of San Diego (1992) 10 Cal.App.4th 712.) When you apply the Laurel Heights decision to this proposed project, I would argue that the Railyard Master Plan project must be initiated to allow all phases of the Canyon Springs project to go forward. The DEIR states “…the Glenshire Drive/Donner Pass Road intersection is shown to operate within the LOS thresholds with implementation of the Donner Pass Road Extension…”p.64. The Railyard Master Plan must go forward if Canyon Springs is approved and as such the two projects are linked and the environmental impacts of the Railyard Master Plan need to be included in the scope of the traffic analysis. Relative to the Donner Pass Road/Glenshire intersection, the DEIR concludes “…With the new center turn lane, some level of development could occur before the LOS threshold is exceeded…Or, developments in other areas of Truckee could occur that result in an increase in through traffic volumes on Donner Pass Road of about 25 percent (without Canyon Springs).” P. 64. It appears that construction of Phases 1 through 5 or 1 through 4 of Canyon Springs will preclude any other already approved development from completing build out during because the Canyon Springs project will have already saturated allowable vehicle traffic numbers for the DPR/Glenshire Drive intersection prior to construction of the Donner Pass Road Extension. Please explain if this is an accurate conclusion or not and if not, why. Vehicle Miles of Travel The “region” definition for calculating vehicle miles traveled is inadequate. Because this proposed project is contiguous with the Town of Truckee’s eastern boundary, consideration must be given to areas frequently traveled to outside of the Town’s boundaries to the North. In particular, the region should include travel to/from Boca and Stampede Reservoirs as this recreation area is frequented by people residing in the eastern outskirts of Truckee. Additionally, many people who reside in Eastern Truckee do so because they work in Reno, Nevada. The VMT needs to account for these commuter miles traveled. Construction Traffic Impacts The DEIR discusses construction traffic related to road construction, but fails to include truck traffic relative to logging which is an inevitable product of this proposed development. The traffic analysis needs to include data on how construction truck traffic will compensate for the inadequate site distance at Whitehorse Road. Further, there should be specific information/data as to whether the proposed safety mitigations for this intersection will be effective with truck traffic. The EIR should also include information on the design and engineering of Glenshire Drive from the intersections with Martis Peak and Hirschdale Roads that demonstrates overall load capacity. Can the road withstand the repetitive construction loads? UTLILITIES Water Supply p. 4.15-‐8 p. 4.15-‐13 Reference is made to Figure 3-‐11 as showing off-‐site infrastructure improvements, but this is actually shown in 3-‐12. Existing Setting p. 4.15-‐8, Water Infrastructure p. 4.15-‐13,14 The fact that the project site is currently not within the service area of the TDPUD combined with the fact that the project will trigger the construction of new off-‐site infrastructure should warrant a “significant impact” with mitigation measures. The approval by Nevada County LAFCO of an SOI update for the TDPUD cannot be presumed, nor can its timeline. The scope of the EIR should include an analysis of the environmental impacts of the off-‐site infrastructure improvements are the direct result of the project. Wastewater Capacity p 4.15-‐22 Reference made to Figure 3-‐10 that should be made to Figures 3-‐11A and 3-‐11B. The EIR should include specific data showing grade adequate to allow gravity feed of wastewater to a single collection site in the northwest portion of the property. ALTERNATIVES An additional alternative should be included in the EIR that shows both reduced density as well as an overall reduced development footprint as a means of reducing significant environmental impacts. Thank you for your consideration, Kaitlin Backlund and Ron Hunter