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HomeMy Public PortalAboutPublic Comment #19 (SCO)Page 1 of 7 140 Litton Drive Suite 240 Grass Valley, CA 95945 Tel: 530.272.5841 Fax: 530.272.5880 Gen’l Email: info@scopeinc.net Truckee: 530.582.4043 October 29, 2013 Via email to dnishimori@townoftruckee.com Denyelle Nishimori, AICP Town of Truckee Community Development Department 10183 Truckee Airport Rd. Truckee, CA 96161 Re: Joerger Ranch Specific Plan ((PC-3) – Draft EIR Comments SCO Job No. 200905 Dear Denyelle: The following comments are in response to the Joerger Ranch Specific Plan (PC-3) Draft EIR: Land-Use, Population, and Housing Impact 3.8.4: The discussion on page 3.8-15 analyzes the anticipated amount of employee housing required as a result of the full-time equivalent employees that could be generated as a result of the project. This discussion assumes that build out of the PC-3 is one project. The discussion fails to recognize that PC-3 is a Specific Plan prepared under the parameters of Government Code Section 65451. The plan is intended to build out over 20 year horizon and its primary scope is to focus on coordinated land-use, establish zoning, outline infrastructure requirements and set forth financial obligations for implementation and improvements. The plan anticipates build-out under several ownerships with different interests but guided under the parameters of the Specific Plan program. The plan has targeted specific land uses that are currently not being provided in the Truckee region so Truckee can provide an atmosphere that encourages new development opportunities to capture and service existing demand that is seeking such services outside the region. Mitigation Measure 3.8.1 attempts to mandate workforce housing as if the PC-3 is being developed as one specific project. This mitigation measure does not recognize the provisions of Truckee Development Section which reads: 18.216.040 Workforce Housing Requirements B.2. The number of workforce housing units to be constructed and completed for a development project,by which employees are calculated as full time equivalent employees in accordance with Sections C.1,shall be as follows: Re: Joerger Ranch ~ Comments on Specific Plan Draft EIR Date: October 29, 2013 Page 2 of 7 S:\JOB_ADMIN\200905 ~ JOERGER RANCH\EIR\EIR COMMENT LETTERS\NISHIMORI_DEIR COMMENTS.DOC i. For development projects that generate less than seven FTEE,the development project shall be exempt from the requirements of this Chapter; ii. For development projects that generate seven or more but less than 20 FTEE,the development project shall pay a fraction of an in lieu affordable housing fee equivalent to the number of FTEE divided by 28. iii. For development projects that generate 20 or more but less than 40 FTEE,the development project shall construct and complete one workforce housing unit for each 14 FTEE. iv. For development projects that generate 40 or more FTEE,the development project shall construct and complete one workforce housing unit for each seven FTEE. This section sets forth provisions for exemptions and sets forth levels of implementation based on number of employees. PC-3 may or may not reach the level of anticipated development described in the project description. Further PC-3 may provide the development opportunity for startup businesses and new employment generators which can have an overall positive impact on Truckee’s economy. Mitigation Measure 3.8-1, as worded, places a burden on small projects that otherwise might be exempt from this criteria set forth in the above-referenced Development Code Section. We respectfully request Mitigation Measure 3.8.1 be rewritten so that development projects within PC-3 are treated equally to other development projects in the Truckee region. As stated on pages 3.8-16 & 17, implementation of the project would not increase population growth in Truckee beyond the build-out levels assumed in the 2025 General Plan. In fact, if the workforce housing provisions are implemented fairly, there may actually be a reduction in housing. Basically this mitigation measure as written does not mitigate any physical impact on the environment. Therefore there is no nexus between the mitigation being proposed and the so-called impact. Any potential impact will be mitigated by adherence to the standards adopted by the Town as set forth in the Development Code Section listed above. Chapter 3.11 Transportation and Circulation Section 3.11.3; Table 3.11-4 Land Use Elements: Table 3.11-4 should be corrected as follows: The Parcel Size for Parcels 4 & 5 should be 3.16 acres, not 7.59 acres. Parcel 6 should be 4.43 acres, not 7.59 acres. The total Quantity for Parcels 4, 5 & 6 should be 66.12 KSF, not 132.24 KSF. The “CS” zone on Parcel 14 should be corrected to read “CR”. The FAR for the CS zone on Parcel 14 (11.69 acres) should be 20%, not 40%. The KSF should be 101.84 KSF, not 203.69 KSF (see Project Description 2.0, Table 2-1, pg.2.0-5). The Joerger Ranch SP does allow for some FAR increases but ONLY for specific targeted uses and only in Re: Joerger Ranch ~ Comments on Specific Plan Draft EIR Date: October 29, 2013 Page 3 of 7 S:\JOB_ADMIN\200905 ~ JOERGER RANCH\EIR\EIR COMMENT LETTERS\NISHIMORI_DEIR COMMENTS.DOC the CL zone. A 203,000 S.F. Shopping Center cannot physically fit on 11.69 acres when you factor in parking, snow storage, storm water treatment and landscaping. Table 3.11-12 – The above errors are reflected in this table. Additionally, this table appears to include “Research & Development” as a Commercial use rather than an Industrial use. This chart should reflect 119 KSF for LT Industrial, not 83 KSF, and the Commercial KSF should be adjusted accordingly. These numerical errors identified above result in 168 KSF increase to the Project square footage and an inflated Commercial KSF. These errors are duplicated and compounded within all of the trip generation charts as well as the Comparison Chart (Table 3.11-12). We request that the data in all of these charts be corrected and the traffic impacts reassessed. With these changes to the overall KSF and an accurate allocation toward LT Industrial, the project will be below the threshold anticipated in the General Plan and significantly closer to the Current City TransCAD Model. This is extremely important since these high numbers are the basis for acquiring significant off-site mitigation measures. Page 3.11-12; Trip Generation: We request that the proposed public parking lot as described be removed from consideration. The proposed parking lot was intended to be a gift of land for the benefit of local residents desiring to use the trail system. As stated in other sections of this report, it is assumed that traffic generated from this project exceeds what was anticipated in the 2025 General Plan and that additional traffic generation is used to justify a variety of off-site road improvements throughout the Town (see MM 3.11-A, 3.11-1D). We do not believe there is a nexus to require such improvements based on questionable assumptions and traffic use not generated by this project. Page 3.11-25; Comparison between Proposed Project and Assumptions in General Plan: We question why the General Plan Land Use assumptions for the property are so much different from the Current City TransCAD model as shown in Table 3.11-12. In addition why do these assumptions not reflect the reduction for pass-by and intercepted trips (see pg. 3.11-25, 2nd paragraph, last sentence)? This methodology appears to provide a false baseline assumption and reflects false trip data generated from the project. This site is uniquely different from a typical commercial real estate perspective in that it will intercept a tremendous amount of existing traffic traveling to Tahoe and the Northstar Resort. On face value this does not appear of much importance. However, the end result appears that these numbers are used to justify a variety of off-site improvements. These off-site improvements are based on the premise that the project generates more traffic than anticipated in the General Plan and therefore mitigation such as construction of the Glenshire Drive and Donner Pass Road Intersection and off-site striping requirements on various roadways throughout the Town is needed to mitigate project impacts. Please provide an explanation of why the traffic model is so much different than what was anticipated in the General Plan and why reductions for logical assumptions such as pass-by and intercepted trips are excluded. Traffic Impacts 3.11-1: The following comments are in response to the mitigations proposed for various off-site roadways and intersections: Re: Joerger Ranch ~ Comments on Specific Plan Draft EIR Date: October 29, 2013 Page 4 of 7 S:\JOB_ADMIN\200905 ~ JOERGER RANCH\EIR\EIR COMMENT LETTERS\NISHIMORI_DEIR COMMENTS.DOC Glenshire Drive/Donner Pass Road Intersection currently operates at a LOS F. This is an existing condition. The report concludes that the proposed project would exacerbate the existing LOS deficiency and therefore concludes that the project is responsible for improvements to that intersection. This assumes that projects within the Joerger Ranch Specific Plan are the only development occurring in Truckee. A variety of recently approved projects (i.e. Avery Hotel, Rock Commercial Expansion continual build out of the Glenshire subdivision, build-out of Gray’s Crossing subdivision, public use of the Gray’s Crossing golf course, build-out of the Winter Creek Subdivision, and others) also exacerbate this existing LOS. The Town has adopted AB 1600 mitigation fee program for situations just like this where there is an existing deficiency as a result of an existing condition and is being exacerbated by a variety of sources. That program is intended to generate funding to offset the incremental decline of the road systems LOS by imposing development fees to be used to construct improvements to correct deficiencies on all projects that contribute to the existing deficiency. The purpose of the fee program is to avoid placing the financial burden entirely on one project. While this improvement is listed in the fee program, it is not subject to receive funding from the program because it’s not listed in the three- year Capital Improvement Program (CIP). To burden one development project with such mitigation, while the intersection is continuing to erode based on others that contribute traffic is not fair and places the projects within the Joerger Ranch Specific Plan at a disadvantage. We request that this improvement be placed in the Town’s Capital Improvement Program so that equitable funding is generated to all those that are further contributing to the deficiency at that intersection pay their fair share of the needed improvements. Mclver/West River Street Intersection. As outlined above, many sources contribute to this impact and as such PC-3 should be responsible for paying its fair share towards that mitigation, not the full improvement. We request that this improvement be placed in the Town’s Traffic Mitigation Fee Program so that equitable funding is generated by all those contributing to the deficiency of this intersection. SR 267/Brockway/Soaring Way. The report states that “Implementation of the project would cause the SR 267/Brockway/Soaring Way intersection to exceed the LOS threshold in 2012. Removal of the existing traffic signal and construction of a multi-lane roundabout would improve the LOS to an acceptable level.” It further states that “…while provisions of capacity enhancing improvements to the existing signalized intersection also improve the level service to an acceptable level this would not be consistent with the Town’s policy (General Plan Policy P7 .1), which strives to replace existing traffic signals with roundabouts including traffic signals on State Highways.” While this is true, the report fails to list the other pertinent policies which guide recommended traffic improvements. Those policies read as follows: P7.1 Strive to replace existing traffic signals with roundabouts as a means of intersection control, including traffic signals on State Highways. Re: Joerger Ranch ~ Comments on Specific Plan Draft EIR Date: October 29, 2013 Page 5 of 7 S:\JOB_ADMIN\200905 ~ JOERGER RANCH\EIR\EIR COMMENT LETTERS\NISHIMORI_DEIR COMMENTS.DOC P7.2 Install roundabouts instead of new traffic signals or capacity enhancing improvements to existing signalized intersections,when roundabouts will achieve the same or better Level of Service as a traffic signal,where it is physically feasible to do so,and when installation of the roundabout will not be substantially costlier than a signal. A7.1 Conduct a study of existing signalized intersections in Truckee to determine which might be suitable for replacement with roundabouts,and develop a prioritization and implementation program for their replacement.Criteria that should be used in considering replacement of existing signals with roundabouts include pedestrian access and safety,historic character,urban design goals for a corridor or neighborhood,costs,and construction feasibility. As discussed above, the traffic volume listed in Table 3.11.4 do not reflect accurate traffic volumes generated by PC-3. Therefore we do not know if the LOS exceeds what was anticipated in the General Plan. What we do know, is that the General Plan Circulation Element Table CIR- 5 anticipates improvements by the Town “upon development of PC-3 or long range”. Those anticipated improvements at SR 267/Brockway Road/Soaring Way include a “roundabout or additional through and turning lanes”. A roundabout at this intersection is included in the Town’s Traffic Impact Fee Program. However, Action Policy A7.1 has not been completed to determine construction feasibility. These policy statements indicate a roundabout OR additional through and turning lane improvements could satisfy these policies. The key factor is determining if installation of a roundabout will not be substantially costlier than a signal. The existing intersection is already signalized and adding additional through and turning lanes will be significantly less costly than removing the signal and replacing it with a roundabout. If the roundabout at the development known as Gray’s Crossing is any indicator (construction cost estimated over $5 million) mandating such improvement conflicts with General Plan P7.2 listed above. We request that the text on page 3.11-45 reflect all policies listed above so decision-makers are aware of the criteria they can use in making such a discretionary decision. As written this mitigation measure precludes that discretionary process. In addition Caltrans has recognized that this intersection and roadway segment will need to be improved in the 20 year horizon and the owners of PC-3 will not be responsible to bear the cost of any of these planned projects or program projects (see attached Caltrans letter and’s date route to 267 segments one and two summary). Being that both Caltrans and the Town have recognized that this intersection improvement to be a regional need it only appears fair that this improvement be placed in the in the Town’s CIP and PC3 be required to pay its fair share mitigation fee. The DEIR needs to evaluate what through or turning Lane improvements would be needed to accommodate development within the PC3 project on the interim basis and the Town needs to conduct the required feasibility assessment required by General Plan Circulation Re: Joerger Ranch ~ Comments on Specific Plan Draft EIR Date: October 29, 2013 Page 6 of 7 S:\JOB_ADMIN\200905 ~ JOERGER RANCH\EIR\EIR COMMENT LETTERS\NISHIMORI_DEIR COMMENTS.DOC Element A7.1 to determine if a roundabout is appropriate before a full roundabout mitigation can be imposed on PC3. Brockway Road/Hope Court/Site Access. Hope Court serves a multitude of housing units known as Pinyon Creek. That project was required to contribute funds for future intersection improvements at Hope Court. Those funds should be made available to implement this improvement. In addition, future development should be required to pay their fair share cost of this improvement. We request that this mitigation be amended to incorporate a reimbursement agreement so that projects that contribute to and benefit from this improvement pay their fair share. Soaring Way/Joerger Drive/Site Access. Adjacent to Soaring Way is approximately 25 acres of land owned by the Truckee Airport District with significant development potential. In fact, the District is pursuing a large scale office complex consisting of non-airport type uses. Future development should be required to pay their fair share cost of this improvement. We request that this mitigation be amended to incorporate a reimbursement agreement so projects that contribute to and benefit from this improvement pay their fair share. This also applies to SR 267/Brockway/Soaring Way improvements. We request that the draft EIR consider amending the following mitigation measures: Mitigation Measure 3.11-1A: Construct a center turn lane on Donner pass road to allow to stage left turn movements to be made from Glenshire Drive. Payment of a traffic mitigation fee is considered to be adequate mitigation for this intersection. The project proponent shall pay the town’s traffic impact fees contributing to this improvement. Mitigation Measure 3.11-1D: Amend the last sentence to read The project shall Re-stripe the existing pavement to provide TWLTL on West River St. east of the McIver Crossing. The project proponent shall pay Town of Truckee traffic impacts fees contributing to this improvement. Mitigation Measure 3.11-1F: Add an additional sentence that reads in compliance with Table 2- 2: Specific Plan Implementation Measures and Action Items and Table 2-3: Intersection/Roadway Frontage/Class I Bike Trail Improvements. A reimbursement agreement shall be prepared so that projects that contribute to and benefit from this improvement pay their fair share. Mitigation Measure 3.11-1G: Add an additional sentence that reads in compliance with Table 2-2: Specific Plan Implementation Measures and Action Items and Table 2-3: Intersection/Roadway Frontage/Class I Bike Trail Improvements. Mitigation Measure 3.11-1H: Add an additional sentence that reads in compliance with Table 2-2: Specific Plan Implementation Measures and Action Items and Table 2-3: