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HomeMy Public PortalAboutPublic Comment #21 (T-TSA)TAHO &TRUCKEE SANITATION AGENCY A Public Agency Directors 13720 Butterfield Drive O.R. Butterfield TRUCKEE, CALIFORNIA 96161 Dale Cox (530) 587 -2525 • FAX (530) 587 -5840 Erik Hemikson S. Lane Lewis Jon Northrop General Manager Marcia A. Beals VIA U.S. MAIL AND E -MAIL 29 October 2013 Ms. Denyelle Nishimori, Senior Planner Town of Truckee Planning Division 10183 Truckee Airport Road Truckee, CA 96161 dnishi mori g4ownottruckee.com RE: The Joerger Ranch Specific Plan (PC -3) Draft Environmental Impact Report Dear Ms Nishimori: The Tahoe - Truckee Sanitation Agency (T -TSA) has received the Draft Environmental Impact Report (DEIR) and associated technical appendices for the Joerger Ranch Specific Plan, or PC -3 Project (Project). T -TSA staff has reviewed these documents and offers the following comments. T -TSA pro-, ides regional wastewater treatment service to several Tahoe & Truckee area communities in portions of El Dorado, Placer, and Nevada counties through the Agency's five member sewage collection districts. The five member entities involved are the North Tahoe Public Utility District, the Tahoe City Public Utility District, the Alpine Springs County Water District, the Squaw Valley Public Service District, and the Truckee Sanitary District (TSD). The Northstar Community Services District (NCSD) is also served by T -TSA facilities through an agreement with TSD. T -TSA owns, operates and maintains the Truckee River Interceptor (TRI), a main trunk line for raw sewage conveyance, and the Tahoe - Truckee Sanitation Agency Water Reclamation Plant (WRP), both of which are described in more detail below. The 17 -mile long TRI pipeline runs along the Truckee River corridor between Tahoe City and the WRP in Truckee. The interceptor flows exclusively by gravity and varies in size from 24- to 42- inches in diameter. The interceptor conveys all of the untreated, raw sewage collected from the northern and western shores of Lake Tahoe, Alpine Meadows, Squaw Valley, and Truckee. Wastewater from the Northstar development is conveyed to T -TSA via an export agreement between NCSD and TSD. The WRP regional facility is designed to treat and dispose of the sewage delivered by the TRI. Throus,h a series of biology =ical, chemical and physical processes, the wastewater is purified to a degree where surface and ground water quality is protected. Wastewater flow to the facility NORTH TAHOE • TAHOE CITY • ALPINE SPRINGS • SQUAW VALLEY • TRUCKEE varies in quantity and quality in proportion to the population present during the year. The WRP is principally sized to treat the maximum sewage flows that occur during peak holiday periods with the large influx of seasonal residents and visitors. We would like to take this opportunity to offer the following comments on the DEIR and associated documents: 1. There appears to be conflicting information with respect to the traffic control improvements that would be made at the intersection of Soaring Way and Joerger Drive. Text on pages ES -4 and ES -5 make mention of a four -way intersection with stop signs and a left -hand turn pocket. However, Mitigation Measure 3.11 -1H on pages ES -36 and 3.11 -47 and the text on Page 3.11 -46 refer to a single -lane roundabout at this location. In any case, T -TSA is concerned about the potential inadequacy of traffic controls for vehicles wanting to turn into the northbound lane of Joerger Drive from eastbound Soaring Way. There is a large volume of traffic that makes this turn including (1) cars heading to the soccer fields, (2) cars, trucks, and heavy equipment to the Truckee Sanitary District, (3) cars and school buses to the school district bus yard, (4) cars to the old sanitation access road, (5) cars, trucks, and heavy equipment to the Teichert quarry, and (6) cars, trucks, and heavy equipment to the Tahoe - Truckee Sanitation Agency's water reclamation plant. Please carefully re- evaluate the amount of traffic that makes this turn throughout all times of the day and provide the necessary mitigation to keep traffic flowing without causing a traffic queue on Soaring Way that extends beyond the capacity of the proposed improvements at the busiest times. 2. On page ES -6, the DEIR correctly states that "wastewater treatment would be provided by the Tahoe - Truckee Sanitation Agency (T- TSA)" As mentioned in Mitigation Measure 3.12 -1 and in the text on page 3.12 -5, there is a need to assess the potential impacts on the sanitary sewer infrastructure that would serve the proposed Project. The Project would result in an increase in the amount of wastewater that would require conveyance through the TRI and treatment at the WRP. More detail will need to be furnished on the proposed improvements before T -TSA can make an assessment. In order to accurately evaluate whether or not the TRI has sufficient unused capacity to serve the proposed Project, estimated Project wastewater flows must be provided to T -TSA. Project developers will need to present facility layouts with tabulated fixture unit counts and other T -TSA billing factor counts. The methodology used to develop these fixture, factors, and flowrates also must be submitted. 3. Mitigation Measure 3.12 -1 states that "the business is subject to receiving a `Will Serve' letter for the specific use /business." Further, the text on page 3.12 -5 states that "the TSD and T -TSA requires the issuance of a 'Will Serve' letter for all commercial development... If these agencies determine that they can treat the business (wastewater generator) then they would issue a `Will Serve' letter for the business." Mitigation Measure 3.12 -1 reiterates that "the business is subject to receiving a 'Will Serve' letter for the specific use /business." Please be informed that T -TSA does not issue Will Serve letters. All capacity allocations are made on a first -come, first -serve basis for all projects within T -TSA's service area. 4. Impact 3.12 -2 states that there is no mitigation required for construction of new or expanded wastewater treatment and/or collection facilities as a result of this Project. Also, on page 3.12 -1 the DEIR states "Currently, the T -TSA WRP has a capacity of 9.6 million gallons per day mgd, which is adequate to meet projected buildout demands of its service area through 2025. " The text on page 3.12.6 states "The T -TSA wastewater treatment plant current capacity of 9.6 mgd is adequate to meet the projected buildout demands of the proposed project. Therefore, the project would not require any off-site expansions or new construction of wastewater treatment facilities because the anticipated wastewater generation would be within the capacity of the existing wastewater treatment plant. " As clarified above, T -TSA operates on a first -come, first -serve basis. Once proposed Project wastewater flow data have been developed and submitted to T -TSA, a capacity evaluation of the TRI and WRP needs to be performed to determine whether any expansion or upgrade of the conveyance, treatment and disposal facilities will be required to serve each stage of the proposed Project at the time the Project is expected to be constructed. Only then would it be known whether mitigation measures are required for T -TSA's facilities. 5. T -TSA is not currently listed as a "nearby facility" on Page 3.6 -3. Further, T -TSA is not listed as a user of Joerger Drive on Page 3.11 -3. Has the sometimes heavy traffic into and out of T -TSA's facilities been accounted for in the Project's traffic studies? Have Project planners taken into account the presence of our facilities when studying other impacts of the Project? Please take note that the facilities that T -TSA owns and operates in the Martis Valley are separate and distinct from those owned and operated by TSD. 6. On pages 3.12 -1 and -2, the DEIR states that T -TSA's "sanitary wastewater treatment requirements are established in the National Pollutant Discharge Elimination System ( NPDES) Permit issued by the RWQCB... The Tahoe - Truckee Sanitation Agency has a permit to discharge treated wastewater into the Truckee River corridor." Please be informed that T -TSA does not directly discharge treated water to the Truckee River. Instead, plant effluent is discharged into a subsurface disposal field. The facility operates under Waste Discharge Requirements (WDRs) issued by the RWQCB, not an NPDES Permit. 7. Impact 4.12 of the DEIR discusses the potential cumulative impacts to utilities. Statements are made suggesting that the Project could be adequately served by current wastewater conveyance and treatment facilities and that "the project's cumulative impact to wastewater services is less than cumulatively considerable, and no additional mitigation is required. " We do not share the confidence that the Project will have no cumulative impacts. The effects of cumulative impacts that the Project may have on T -TSA's facilities should be further investigated. There are several other large developments in the region that Project planners will need to consider (e.g., Village at Squaw Valley, Homewood Mountain Resort, Northstar, etc). The Town will need to properly evaluate the cumulative impacts of these and other developments in assessing T -TSA's ability to serve the Project. 8. In the Joerger Ranch Specific Plan, a Class I bikepath is shown on Figure 2 -7 as being located on T -TSA property (Trail #46). A recreational trail is also shown (Trail #39) that may or may not be on T -TSA property. T -TSA has neither reviewed nor approved the proposed construction of trails in these locations. As such, please remove these trails from future versions of this figure. T -TSA would like to thank the Town for an opportunity to provide these comments. Please evaluate and address the concerns noted above so that we can better define the impacts that this Project might have on T -TSA's facilities and operations. If you have any questions, please do not hesitate to call me at (530) 587 -2525_ Sincerely, Jason A. Parker Engineering Department Manager JAP.jp C'. Marcia Beals, General Manager