HomeMy Public PortalAboutPublic Comment #10 (Green)
Denyelle Nishimori
City of Truckee
10183 Truckee Airport Road
Truckee, CA 96161
Re: Joerger Ranch Specific Plan
SCH Number - 2012052073
Dear Ms. Nishimori,
The undersigned represents Citizens Advocating Rational Development (“CARD”), a non-profit
corporation dedicated to issues in development and growth.
This letter contains comments on the Draft Environmental Impact Report on the Joerger Ranch
Specific Plan, in accordance with CEQA and the Notice of Completion and Availability. Please ensure
that these comments are made a part of the public record.
ENERGY
The DEIR does not discuss any requirements that the Project adopt energy saving techniques
and fixtures, nor is there any discussion of potential solar energy facilities which could be located on the
roofs of the Project. Under current building standards and codes which all jurisdictions have been
advised to adopt, discussions of these energy uses are critical. The construction of a mixed use
commercial/industrial project with a multi-family residential component which may accommodate up to
97 residential housing units and approximately 460,000 sf of commercial and industrial uses, will devour
copious quantities of electrical energy, as well as other forms of energy.
WATER SUPPLY
The EIR ( or DEIR – the terms are used interchangeably herein) does not adequately address the
issue of water supply, which in California, is a historical environmental problem of major proportions.
What the DEIR fails to do is:
1. Document wholesale water supplies;
2. Document Project demand;
3. Determine reasonably foreseeable development scenarios, both near-term and long-term;
4. Determine the water demands necessary to serve both near-term and long-term development
and project build-out.
5. Identify likely near-term and long-term water supply sources and, if necessary, alternative
sources;
7. Identify the likely yields of future water from the identified sources;
8. Determine cumulative demands on the water supply system;
9. Compare both near-term and long-term demand to near-term and long-term supply options, to
determine water supply sufficiency;
10. Identify the environmental impacts of developing future sources of water; and
11. Identify mitigation measures for any significant environmental impacts of developing future
water supplies.
12. Discuss the effect of global warming on water supplies.
There is virtually no information in the DEIR which permits the reader to draw reasonable conclusions
regarding the impact of the Project on water supply, either existing or in the future.
For the foregoing reasons, this EIR is fatally flawed.
AIR QUALITY/GREENHOUSE EMISSIONS/CLIMATE CHANGE
The EIR lacks sufficient data to either establish the extent of the problem which local emissions
contribute to deteriorating air quality, greenhouse emissions or the closely related problem of global
warming and climate change, despite the fact that these issues are at the forefront of scientific review
due to the catastrophic effects they will have on human life, agriculture, industry, sea level risings, and
the many other serious consequences of global warming.
This portion of the EIR fails for the following reasons:
1. The DEIR does not provide any support or evidence that the Guidelines utilized in the analysis
are in fact supported by substantial evidence. References to the work of others is inadequate unless the
document explains in sufficient detail the manner and methodology utilized by others.
2. Climate change is known to affect rainfall and snow pack, which in turn can have substantial
effects on river flows and ground water recharge. The impact thereof on the project’s projected source
of water is not discussed in an acceptable manner. Instead of giving greenhouse emissions and global
warming issues the short shrift that it does, the EIR needs to include a comprehensive discussion of
possible impacts of the emissions from this project.
3. Climate change is known to affect the frequency and or severity of air quality problems, which is
not discussed adequately.
4. The cumulative effect of this project taken with other projects in the same geographical area on
water supply, air quality and climate change is virtually missing from the document and the EIR is totally
deficient in this regard.
For the foregoing reasons, the EIR is fatally flawed.
ALTERNATIVE ANALYSIS
The alternative analysis fails in that the entire alternatives-to-the-project section provides no
discussion of the effects of the project, or the absence of the project, on surrounding land uses, and the
likely increase in development that will accompany the completion of the project, nor does it discuss the
deleterious effects of failing to update the project upon those same surrounding properties and the land
uses which may or have occurred thereon.
Thank you for the opportunity to address these factors as they pertain to the referenced DEIR.
Very truly yours,
CITIZENS ADVOCATING RATIONAL DEVELOPMENT
NICK R. Green
President