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Home My Public Portal AboutCanyon Springs DEIR Public Comment #75 (Colby)Denyelle Nishimori, Senior Planner 10183 Truckee Airport Rd. Truckee, CA 96161 dnishimori@townoftruckee.com Re: Comments on the Canyon Springs DEIR March 6, 2013 Dear Ms. Nishimori, Thank you for reviewing the many public comments on the Draft Environmental Impact Report for Canyon Springs (CS). Your job is a complex one, and the sheer volume of information coming in from all parties must be overwhelming. We appreciate your diligence, objectivity, and collected experience throughout this long public process. There are numerous flaws with this DEIR, as you’ve heard. Overall, the Canyon Springs DEIR doesn’t adequately address several key guidelines that members of this community clearly stated as important in the 2025 General Plan. Going further back to a couple of the points comprising “The Truckee Way,” it is pretty obvious to this resident that a development like Canyon Springs hasn’t exactly come along to reaffirm the unique “Sense of Place” that Truckee residents declared so important: it reads in part that Truckee residents seek to “[...] preserve and protect the environment and quality of life which makes Truckee an attractive place to live and visit.” A 20-year, multistage development on the far eastern edge of town easily qualifies as rural sprawl, and it certainly doesn’t improve the quality of life for nearby residents, for the residents who must endure all of that sprawling subdivisions’ ingress and egress, or for the taxpayers who get to foot the bill for creation and maintenance of all the additional infrastructure required to service that sprawl. How exactly will Canyon Springs will improve our existing quality of life while simultaneously eliminating or mitigating all of the very real impacts that CEQA requires the developer consider? If the ways in which the development of CS will add to the existing quality of life that we enjoy in Truckee cannot be stated succinctly and incontrovertibly understood by all stakeholders, and welcomed by the neighboring community, the project’s legitimacy should be seriously reevaluated. But specifically, the Canyon Springs DEIR, as required by CEQA, fails to adequately address critical issues affecting everyone in Truckee (especially Glenshire and Olympic Heights residents). Juxtaposed with Truckee’s General Plan, we see elements in the following sections of the DEIR (among others) as significantly flawed and needing significant revision. Chapter 4-14, Transportation Traffic Chapter 4-4, Biological Resources Chapter 4-7, Greenhouse Gas Emissions Chapter 4-9, Hydrology Water Quality Re. DEIR Chapter 4-14, Transportation Traffic From the Truckee General Plan: “The Circulation Element … addresses, as a central focus, the provision of a roadway network that has adequate capacity to serve current and projected traffic within the town.” The DEIR fails to adequately account for existing traffic conditions or propose solutions to the already problematic levels and types of traffic found on Glenshire Drive, much less the 5000 additional trips per day generated by the project at buildout. Glenshire Drive doesn’t safely or adequately serve Glenshire residents, especially at the Donner Pass Road intersection. There’s also (to my knowledge) no guarantee – or committed funding - ensuring that a roundabout or equivalently effective measure will ever be built. It’s stated in the DEIR on page 4.14-71 (Mitigation Measure TRANS-4) that there would be a Construction Traffic Management Plan created by the Town, and that there would then be less than significant traffic impacts. Where is this document? Isn’t its place here in the Transportation and Traffic section of the DEIR? Shouldn’t such documents – and safety studies, such as those proposed in Mitigation Measure TRANS-5 – be prepared prior to construction? Why were so many other intersections in Glenshire not studied? Olympic Heights? A more comprehensive evaluation of the CS project’s impact on all streets intersecting with Glenshire Drive seems pretty reasonable. Additionally, it seems highly problematic to assume that I80 will host so many of CS’s vehicle trips. I-80 closes sometimes: it subjects westbound travelers to the agricultural station’s stop, and actually produces more greenhouse gasses given the acceleration and speed needed to drive on it. Why not hydroplane down Glenshire drive into town? Finally, I understand that the references and design methodology used for this shaky traffic evaluation may be outdated. If this is indeed the case, a complete reestimation of traffic numbers is needed. Re. DEIR Chapter 4-4, Biological Resources General Plan Conservation and Open Space Element Guiding principles (seen here: http://www.townoftruckee.com/Modules/ShowDocument.aspx?documentid=1229) seem to all disallow a project like CS which clearly situates itself amidst an already impacted migratory deer herd corridor. On page 4.4-47, the DEIR states, “according to CDFG, impacts resulting from residential development and recreational use are currently the biggest concern for the future of this deer herd.” This should caution against a large development like CS and suggest greater preservation in this location, but instead, an inadequate, quickly done study of the herd is cited shortly thereafter. Also cited are the many existing fractures in the deer herd’s migratory pathway (roads, k-rails in the center of Hwy 80, more developments, fences). So, how would a 20 year construction project enhance the herd’s well being? How would the hydrological impacts on the water in Glenshire Pond effect the deer herd and all the birds we enjoy seeing there? More data is needed, whether in the form of an extended existing study or a new study, and it should be done by someone independent of the developer. Where’s the USFW’s data? Re. Chapter 4-7, Greenhouse Gas Emissions Removing trees impacts carbon sequestration. This needs to be addressed and accounted for when considering project mitigation. 20 years of Diesel-powered construction trucks travelling some 7-8 miles round trip adds up. Significantly. Why this uncalculated number is dismissed as “less than significant” is not only questionable, it suggests a lack of concern on the developer’s part. And, given the likely outdated methodology used to quantify traffic impacts, greenhouse gas emissions are likely miscalculated as well. Page 4-7.22 demonstrates disregard for the intent of the CA Air Resources Board – and the will of any rational person who understands air pollution . Expect an annual production of 3025 lbs of CO2 released by the project (a very conservative estimate, the obscure calculation of which the Town should closely scrutinize). This 3025 lbs/yr will be nearly double the ARB’s desired threshold for such a project, the DEIR acknowledges, but since the Northern Sierra Air Quality Management District and Town haven’t formally adopted a number, the DEIR declares that the emissions impact is “less than significant.” This is disingenuous and simply not a good faith effort to do what people clearly want done – decrease emissions through building closer to the center of town, burning biodiesel at least, locally sourcing materials, etc…. Over half of the expected emissions from this project – it’s construction and its lifetime - come from transportation sources - construction equipment burning Diesel and then cars and trucks commuting (see table 4.7-4). Greenhouse gas emissions should be recalculated and basic assertions/calculations made transparent for the public. Possible mitigation measures in the form of sustainably constructing such a project should be far more quantified and detailed than “install skylights and solar panels into the designs of the residences.” (See page 4-7.21) Any number of standards-based green building certifications (LEED, Build It Green) lends itself to stating credible data ranges that illustrate the emissions reduced. The developer should also understand that “green building” is nowhere more appropriate than a place with as much cold, snow, and sun as here. To not consider basics like passive solar design, readily available reclaimed local materials, rainwater harvesting (isn’t it still illegal in Nevada County?), energy efficiency, and the like would be foolish. Re. Chapter 4-9, Hydrology and Water Quality On page 4-9.16, the “d. Proposed Drainage Plan” is unclear. Why isn’t a final drainage plan required when the design has changed from what it was in 2011? Would the acknowledged “suggested revisions from the 2007 technical review” be incorporated? When? During the construction of CS? Is this an adequate “plan”? If I understand correctly, the many drainages proposed here are known to encourage more erosion during runoff than more diffused drainages. What measures exist to handle anything beyond 20 year weather events? Such measures remain vague and largely unspecified. Why isn’t it mentioned that rainwater runoff and drainage will go to Glenshire Pond before it goes to the Truckee River? Where is the study on the impact of the drainage to the wildlife and water quality of the pond? What might impacts be to pond levels? What would people living around the pond be likely to experience? What of the Urban Water Management Plan that only cites water as being available through 2023? Any calculations on what happens beyond 2023? Please address potential impacts to Glenshire Pond and the ability of the proposed CS drainage plan to actually accommodate runoff and drainage amid all kinds of weather events. These analyses should be included here. The Supporting Statements for Truckee’s Vision (as seen at http://www.townoftruckee.com/Modules/ShowDocument.aspx?documentid=1200) state four things. 1) Reduce sprawl. 2) Protect open space. 3) Reduce dependence on the automobile by fostering compact development. 4) Provide affordable housing. That’s a list that the people of Truckee should be proud of. As only partially noted above, the CS DEIR fails to adequately esteem Truckee’s vision and democratically voiced will. Get into the project details and the holes in some of this planning become really evident. CS is inappropriate and antithetical to what Truckee’s residents have said they prefer when a developer comes to town looking to make a buck – infill along the lines of the railyard plan, which portends something that could truly improve the Town in a socially, economically, and ecologically more sound way. I encourage the Town to hold this project to the high standards crafted by Truckee residents. Thanks for considering these comments and for all of your hard work on this project. We look forward to your reply. Sincerely, Ronnie Colby Kristen Colby