HomeMy Public PortalAboutPublic Comment #23 (MAP)
To: Denyelle Nishimori October 29, 2013
Senior Planner
Town of Truckee
Truckee Community Development Department
10183 Airport Road
Truckee, CA 96161
Dnishimori@TownofTruckee.com
From: Alexis Ollar
Executive Director
Mountain Area Preservation
10116 Jibboom Street
Truckee, CA 96161
RE: Comment Letter on Public Draft Environmental Impact Report (DEIR) for the
Proposed Joerger Ranch Specific Plan Project (PC-3 Project) (SCH# 2012052073)
Dear Mrs. Nishimori,
On behalf of the Board and Staff at Mountain Area Preservation (MAP) we would like to
submit the following comments regarding the Draft Environmental Impact Report (DEIR)
for the proposed project, Planned Community-3 (PC-3). Mountain Area Preservation’s
mission is to preserve the Truckee region’s community character and natural environment
for present and future generations. MAP has worked for 26 years in the region advocating
for sound land use planning, open space and smart growth development.
Our goal with commenting on the PC-3 DEIR is to support the Town’s General Plan
policies for PC-3, while providing more heightened mitigation measures to protect
Truckee’s community character and the scenic viewshed at the gateway to Town. Since, the
Project applicant is proposing a Specific Plan, zoning and tentative tract map for PC-3, we
have provided a new mitigation measure and conditions of approval that will bring the
Specific Plan into conformity with the General Plan and General Plan policies for PC-
3. Our proposed new mitigation measure also provides clearer direction for the
development at PC-3 to ensure the Project when developed is consistent with the Town’s
General Plan and all other applicable policies and regulations. This new mitigation measure
also provides a more clear direction for a more cohesive development to occur at the Joerger
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Ranch site. The DEIR also contains numerous inadequacies, including deferred and
inadequate mitigation measures to address significant impacts related to air quality, visual
and biological resources and plan consistency among others. Specific defects in the DEIR
are also contained in our following comments. Our comments have been prepared with the
assistance of the following experts; Jared Ikeda, Land Use Planner and Terry Watt, Land
Use Planner. (See attachment 6 for Consultant’s CV/Resume).
Introductory Comments
MAP supports the purpose of the General Plan and its policies for PC-3. (See e.g.,
Attachment 2, Partial List of General Plan Excerpts and Inconsistencies Relevant to PC-3).
The General Plans intent of establishing appropriate types, mix, design and scale of uses to
fulfill needs currently lacking within the Town are appropriate. Targeting land uses that
strengthen the local economy by capturing uses that are currently being met by travel to
other areas within the region is a smart approach towards making the town even more
livable with heightened connectivity. In addition, the intent of providing land uses at PC-3
that do not compete with the downtown, also providing the surrounding neighborhoods with
access to commercial amenities without vehicle reliance, and providing zoning uses for the
relocation of light industry from the Truckee River corridor helps to improve the economy
and livability of the entire town.
Major elements of these comments include the following:
• New Mitigation Measure: The main purpose of these comments is to recommend the
inclusion of one New Mitigation Measure in the DEIR that would resolve general
plan inconsistencies and provide feasible mitigation for significant impacts to Air
Quality, Greenhouse Gas Emissions, Climate Change, Biological Resources, Visual
Resources, Transportation and impacts related to Project-Plan inconsistencies. The
PC-3 Project, if approved without additional conditions, allows the applicant to sell
parcels without an integrated design and streetscape plan fulfilling required
mitigation, reduce significant impacts identified by the DEIR and being consistent
with Town goals and policies. The Specific Plan, zoning and tentative map must be
held accountable to meet the Town’s goals, policies and action items as well as
reducing to the maximum extent the significant impacts of the Project.
• Alternative Location(s) for Non-Profit Center Site: MAP’s proposed solution in the
form of a New Mitigation Measure that would modify and condition the Specific
Plan provides a means of meeting these legal requirements, while allowing approval
of a Project at PC-3, near-term sale of some of the parcels and superior locations for
a non-profit community center. We are aware the applicant has offered Parcel 6 for
a non-profit center and believe that that particular parcel has many constraints to
being developed; constraints that make development uncertain, costly and potentially
infeasible. Our proposal would be to locate the non-profit center in a mixed use,
walk-able area where shared parking, transit stop and services are easily accessible.
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• DEIR Project Alternatives: We appreciate the Town for including the all ‘Industrial
Alternative’ in the DEIR analysis. We have now delved more deeply into Town
policy, smart and sustainable planning and believe an integrated design and mix of
uses that do not compete with downtown, but complete the surrounding
neighborhoods within a ½ mile walking circle will provide for a superior Project at
PC-3. (See attachment 5, Walking Circle for Project Site). We are supportive of the
DEIR environmentally superior alternative, the ‘Reduced Intensity Alternative’. The
New Mitigation Measure we are proposing would allow the development to transpire
in a unified manner, while protecting the scenic corridor and natural resources at the
gateway to Truckee.
• Specific Plan & DEIR Defects/Inconsistencies: The Specific Plan and DEIR both
exhibit a lack of specificity and feasible mitigation measures. We have addressed
some of the defects and particular parts of the Specific Plan and DEIR that need to
be revised. We used this comment period time to work on a solution that would
address the most significant of those defects – deferred and incomplete mitigation to
reduce impacts to Air Quality, Transportation and Green House Gas emissions are
inadequate for the DEIR. Preliminary comments on the numerous inadequacies and
defects in the DEIR follow our comments on the solution; New Mitigation Measure.
Finally, the comment period for a project of this importance, scale and complexity is
extremely short. We plan to follow up with the applicant and the Town regarding our
comments and suggestions after the close of the DEIR comment period.
Background
The solution MAP proposes would allow the Project to comply with planning and CEQA
requirements. As currently proposed, the PC-3 Project fails to comply with numerous
General Plan goals, policies and actions including those related to Land Use, Community
Character, Economic, Biological Resources, among others. In addition, the DEIR fails to
require feasible mitigation measures in the form of Specific Plan modifications capable of
meeting Town goals and policies and reducing significant and significant unavoidable
impacts to Air Quality (e.g., Impacts 3.1-1 and 4.1), and defers mitigation for biological
impacts (e.g., Impacts 3.2-4 and 3.2-5). Finally, the DEIR fails to adequately analyze and
mitigate other potentially significant impacts such as those related to General Plan
consistency (e.g., PC-3 Specific Plan policies, economic, visual character, streetscape
design, and biological)1. The proposed Specific Plan, Zoning and Tentative Tract Map do
not provide the certainty needed to meet either the goal and policy obligations in the
General Plan or the mitigation measures in the DEIR. In addition, the proposed Specific
Plan, Zoning and Tentative Tract Map are not detailed enough to illustrate how the Town’s
1 See Attachment 2 hereto, partial list of General Plan goals, policies and action items the PC-3 Project is
inconsistent with as proposed. MAPs proposed New Mitigation Measure would bring the PC-3 Project into
consistency with these provisions.
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requirements in its Development Code will be achieved. The problem lies in the lack of an
adequate Specific Plan to achieve the Town’s vision and policies for the PC-3 site along
with the lack of a legally adequate environmental impact report. Our proposed New
Mitigation Measure is feasible and addresses these problems.
New Mitigation Measure – Specific Plan Overlay Designation and Conditions
The New Mitigation Measure described in detail below provides a feasible approach to
modifying the proposed Specific Plan such that the goal, policy and mitigation obligations
can be met as required by law. This new measure incorporates the general elements of the
‘Reduced Intensity Alternative’ by reducing the total amount of development by
approximately 50% (for a total of approximately 230,387 allowable non-residential square
feet). (See DEIR at page 5.0-3).
The New Mitigation Measure also:
• Reduces the developable area to mitigate for visual, biological and community
character impacts;
• Further limits the range of potential land uses;
• Requires that land uses, with the exception of the housing parcel (portion of Parcel
1), be subject to additional planning to produce a more integrated and detailed design
to meet both Town policies and mitigate significant impacts; and
• Does so by adding Specific Plan Overlay Designations, including one for Mixed Use
areas and another for the Scenic Corridors. Development approvals, including any
development permits and Final Map, for the Mixed Use areas would be conditioned
on completion of additional planning steps specified in the Overlay Designation.
• Sale of parcels in the Scenic Corridor Overlay Designation would be conditioned on
completion of additional planning steps specified for that Overlay Designation.
• Addresses the Town’s Policy, Project objective and DEIR recommendation to
relocate uses along the Truckee River to the PC-3 site. “Accommodate the possible
relocation of certain existing types of commercial and industrial business located
along the Truckee River Corridor.” (Page 2.0-3 of the Draft EIR).
The New Mitigation Measure does not modify the Multi Family Residential (MFR) portion
of Parcel 1. However, the more detailed design phase for the MFR should focus on the
connectivity of these units to the adjacent uses in the Mixed Use areas to maximize walk-
ability, bike-ability and overall safe ease of access without reliance on an automobile. In
addition, these units should be of the highest quality design. A description of the New
Mitigation Measure including Specific Plan overlays and related conditions is set forth
below:
New Mitigation Measure: 3.1-4 (a): To reduce Area Source Emissions, Cumulative Air
Quality emissions, cumulative impacts on greenhouse gases and climate change, Energy
Source Emissions, potentially significant visual impacts and resolve Project – Plan
inconsistencies related to community character, economic impacts on Downtown, Specific
Plan policy inconsistencies, among others, the following Specific Plan Overlays and
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conditions shall be adopted as part of the Specific Plan approval in concert with a
reduction in land use intensity similar in total square footage and total housing units
under the Reduced Intensity Alternative (for a total of approximately 50, inclusive of 48.7
workforce housing units and approximately 230,387 square feet of non-residential mixed
uses. Bonus densities could be allowed based on an adopted incentive program to relocate
the industrial uses along the river to the PC-3 site).
Figure 1: PC-3 Mixed Use Overlay Designations & Scenic Buffer Overlay
PC-3 Specific Plan Mixed Use Overlay Designations for Areas A and B:
Tentative Tract Map parcels shown on the Tentative Map (Figure 2-7) located within the
Specific Plan Mixed Use Overlay Designations as illustrated above on Figure 1, may be
sold individually or collectively, however, no other approvals for development including
but not limited to Final Map, design, grading, building, other shall be made until all of
the following additional planning steps are successfully complete for each respective
Mixed Use Overlay area, A and B. (See attachment 1 for larger configuration of Figure
1: PC-3 Mixed Use Overlay Designations & Scenic Buffer Overlay).
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1) Economic Study: An economic study update analysis to include work previously
analyzed by BAE for PC-3 and an update for all of Town to identify current
anticipated demand for retail, office, industrial and other uses within the use list
(below); review available buildings and land use for other planned and proposed
projects in the downtown and other parts of Town to satisfy demand, and identify
niches that PC-3 can serve without adversely impacting Downtown and other
areas or projects. In addition, a survey of daily destinations that are not currently
located within a ½ mile walking circle shall be identified to fill out a list of land
uses for PC-3’s mixed use areas that: focus on under-served niches Town-wide;
uses that complete the surrounding neighborhoods to reduce reliance on the car2;
and uses that will not result in an adverse impact on Downtown and other areas or
projects. (See attachment 5, Project Site Walking Circle).
2) Design Plan: Using the findings from the Economic Study, fine tune the land
uses and land use regulations for the respective Mixed Use Overlay areas and use
a community based design process to illustrate the physical configuration of
development in the overlay areas to meet requirements in the General Plan and
DEIR mitigation measures for PC-3 including, but not limited to all of the
following:
• Streetscape design plan including elements of complete streets and high quality
design street furniture, signage, paving, landscaping;
• Solar orientation of structures;
• Integrated design that maximizes pedestrian connectivity between residential
and mixed use destinations as well as transit stops using similar techniques as
form based code or other regulating code and including but not limited to:
building orientation on street, narrower streets, prohibition of large parking
lots. An example of a regulation plan is included below for mixed-use design,
which supports a number of uses and a compact design that can be supported
by the ‘Reduced Intensity Alternative’ for PC-3. (See Figure 2 & 3 below).
• Non-motorized access trails/means between all parcels and greenbelts and
trails and bike/pedestrian friendly frontage improvements;
• Demonstration of achievement; all mitigation measures for biological resource
protection, (see e.g., MM 3.2-4 -3.2-10) including project redesign to avoid
wetlands and ephemeral streams and provide a minimum 50-foot buffer area
for these resources.
• Demonstration of achievement of other requirements of MM 3.1-2 and 3.1-
2 There is a rich body of literature on the palette of land uses that improve walk-ability when located
within a ½ mile-walking circle. The list of allowable land uses for the mixed use overlay districts
draws from that literature and Walkscore (http://www.walkscore.com/about.shtml). The Economic
Study should tailor these based on actual surveys in the surrounding neighborhoods.
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• The Design Plan shall be developed with robust public participation using
tools such as Crowdbrite to engage the public early and easily in the design of
the Project.
Figure 2 Mixed-Use Building Lot & Character Examples, Lee County
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3) Codes, Covenants, Restrictions and Reciprocal Easements where warranted:
Ideally CC&Rs would be created prior to parcels being sold off, but as long as they
are in place prior to development they will bind development and future property
owners to practical requirements developed during the Design Plan step above.
Figure 3. Compact Community Design with Mixed Uses Example, Lee County
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4) Incentives for Transfer or Relocation Riverfront Uses as appropriate3:
Simultaneously or prior to the above project specific planning steps, the Town
shall develop an incentive program for the existing uses along the River to relocate
to PC-3. Possible incentives could include waiver of certain fees or taxes,
payments, potentially density bonuses to PC-3 residential and/or mixed-use areas,
and the like. MAP will provide examples of incentive programs under separate
cover and look forward to discussions at the upcoming November 12th Economic
Workshop. This is also a prerequisite to any further approvals for parcels located
in the Mixed Use Overlay areas.
5) Land use modifications within Mixed Use Overlay Designations A and B:
Land uses permitted in Mixed Use Overly Designations subject to Economic Study
refinement:
• Soaring Way = complete street with bike/pedestrian/trails etc.
• Uses that “complete the neighborhood within a ½ mile walking / biking circle)
• Housing Over commercial (all types)
• Fitness and recreation (gym, parklet, pocket park; tot lot/par course; bike and
other outdoor recreations equipment rentals and sales; yoga studios; etc.)
• Teller machine/bank
• Real estate office
• Coffee house; bakery; bar
• Farmers market “area”; food truck station
• Community center/non profit center
• Public facilities – branch library, fire station, other
• Green industries (e.g., green tech product design and manufacturing and
research)
• Transit stop or center
• Small format drug and market (defined by square feet)
• Unique locally owned retail
• Dry cleaner
• Small garden center/nursery
• Light industrial (compatible with residential – like specialty food and spirit
production – e.g., brewery, bakery; R&D, repair shops)
• Uses identified in the “walk circle” survey as missing in the walk circle that would
capture significant trips.
3 “Accommodate the possible relocation of certain existing types of commercial and industrial
business located along the Truckee River Corridor.” (page 2.0-3 of the DEIR).
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Prohibited Uses:
• Anything large plate or big-box format
• Large format drug or supermarket
• Retail that would adversely impact Brockway Corridor/Downtown retail
• Incompatible manufacturing or industrial uses
PC-3-Specific Plan Highway Scenic Buffer Overlay - Conditions: In order to meet the
General Plan provisions related to Community Character and Town Gateway, Tentative
Tract Map parcels shown on the Tentative Map (Figure 2-7) located within the PC -3
Specific Plan Overlay Designation Highway Scenic Overlay Designation as illustrated on
Figure 1, may not be sold individually or collectively until all of the following planning
steps have been successfully completed. Once completed, for any areas beyond the
minimum scenic setback line (300 feet from HWY 267) shown on Figure 1, that are
shown to be developable consistent with Town Policies and without adverse impacts to
visual resources or the Gateway, shall be subject to the requirements (above) of the mixed
use overlay designations. For these developable areas, no other approvals for
development including but not limited to Final Map, design, grading, building, other shall
be made until all of the additional planning steps are successfully completed as set forth
above for mixed use overlay areas.
Planning steps prerequisite to identifying additional mixed use development area:
1) Scenic Sensitivity Analysis: A detailed scenic sensitivity analysis shall be
completed to determine appropriate scenic setbacks/buffers for parcels within the
Scenic Buffer Overlay designation. In no case shall development be permitted
between Highway 267 and the Minimum Scenic Setback shown on Figure 1. The
analysis shall be done consistent with the process set forth in attachment 3 and
shall include robust public participation using tools such as Crowdbrite to engage
the public early and easily in the determination of final scenic setback areas. (See
attachment 3 for methodology).
2) Wetland Delineation: Shall be completed for the CL parcel 6, as part of a
determination of whether any of parcel 6 is developable. If developable based on
the delineation and scenic sensitivity analysis (above), all other biological
mitigation measures in the DEIR shall apply including avoidance and buffers.
(See attachment 4, Wetland Resources at PC-3)
3) Land Uses - Modifications: The parcels in the Highway Scenic Buffer Overlay
shall remain in open space until the planning steps above have been completed. If
as a result of the completion of the above planning steps, any areas beyond the
minimum scenic setback line shown on Figure 1, shall be subject to the
requirements (above) of the mixed use overlay designations. For these
developable areas, no other approvals for development including but not limited to
Final Map, design, grading, building, other shall be made until all of the
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additional planning steps are successfully completed as set forth above for mixed
use overlay areas.
(All bold and italic text above is part of New Mitigation Measure)
The Draft Environmental Impact Report is Legally Inadequate
The lack of detail in the Specific Plan concerning an integrated project design and the
significant deficiencies of the DEIR initially led our organization to the conclusion that the
only way to secure the outcomes for the PC-3 Project Site sought by the General Plan and
DEIR mitigation measures was to ask the Specific Plan be revised prior to any further
consideration by the Town. Upon consulting with our experts, we concluded that a New
Mitigation Measure, which modifies and conditions the Specific Plan, could be a path
forward to allow the Town to consider approval of the Project with the New Mitigation
Measure in place and for the landowner to be able to sell parcels as they have indicated a
desire to do.
Our preliminary comments on the numerous defects in the DEIR are set forth below. It
should be noted here, that the New Mitigation Measure proposed above would go a long
way to resolve both the Project – General Plan inconsistencies and the DEIR defects. Our
planners have noted some of the DEIR mitigation measures and General Plan
inconsistencies below, and we have also provided attachment 2, which outlines more items
that are inconsistent for the polices and goals set forth for PC-3.
The DEIR Improperly Defers Feasible Mitigation
The lack of specificity in the Specific Plan, zoning and tentative map make it impossible to
determine whether mitigation measures to reduce significant impacts are feasible and will be
implemented. Examples include, but are not limited to the following:
Mitigation Measures 3.1-2 and 3.1-3: to reduce significant unavoidable impacts to Air
Quality and Greenhouse Gas and Climate Change require the project applicant to implement
a number of strategies, many of which are not possible to implement without an integrated
design for at least some collections of parcels. Specifically, strategies such as “a walkable
design/improved pedestrian network and destination accessibility” can only be achieved
with a detailed and integrated site design. Town policy consistency also requires attention
to high quality streetscape, connectivity and avoidance of ‘strip-commercial developments’.
The New Mitigation Measure described above would provide a feasible means of achieving
required mitigation. The DEIR fails to mitigate air quality, GHG and climate change by
deferring, which is unacceptable.
Mitigation Measures 3.2-4, 3.2-5, 3.2-8 and 3.2-9: collectively are required to reduce
potentially significant impacts to biological resources to less than significant. Yet, the
wetland delineations are not complete and there is no certainty project redesign will comply
with these measures. The New Mitigation Measure described above would provide a
feasible means of achieving required mitigation with a current wetland delineation for parcel
6, while identifying acceptable buffers and building setbacks from sensitive areas.
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The DEIR uses the deferred methods of mitigation, which then forecloses the public and
decision makers from reviewing and revisiting how resources will actually be protected, and
how impacts will be mitigated for the project. The DEIR needs to be revised and re-
circulated to show how the above mitigation measures will be applied or how the New
Mitigation Measure we are suggesting can be applied to the planning prerequisites to create
a more integrated and revised Specific Plan that will mitigate impacts to natural resources at
the site.
The DEIR Fails to Identify and Address with Feasible Mitigation the Numerous
Inconsistencies Between the PC-3 Project as Proposed and the General Plan:
The 2025 General Plan’s Vision Statement and Polices for PC-3 define the following
supporting concepts to guide implementation in Truckee and at the proposed development
site:
• The General Plan will reduce the dependence on the automobile in
Truckee by fostering compact development and providing for alternate
modes of transportation (1-7). The PC-3 Specific Plan fails to identify the methods
of transit that will create a walk-able/bike-able development at the project site. The
Specific Plan and DEIR should be revised to include a transit plan for the project
site. The planning prerequisites that we have outlined above as a part of our New
Mitigation Measure will help to ensure consistency with the Towns General Plan
policies and support the intended goals for PC-3.
• Policy-3 Site design shall consider appropriate access to Highway 267, via
Brockway Road and Soaring Way, and shall minimize visual impacts from Hwy 267
corridor (2-30). The Specific Plan and DEIR fail to illustrate how the proposed
zoning and future development at PC-3 will mitigate the visual impacts of
commercial, manufacturing and light industry along the Brockway/HWY 267
corridor. The New Mitigation Measure described above would provide for analysis
that could create appropriate setbacks to preserve the scenic corridor near the
development while still allowing ample development at the site consistent with the
‘Reduced Intensity Alternative’.
• Policy-4 The Specific Plan shall include standards for the design of retail shopping
areas that avoid "strip commercial" site layout, and that are oriented and scaled to
the pedestrian realm (2-30). The Specific Plan lacks a true vision and design
guidelines to direct consistent development at the site. The DEIR fails to address
mitigation measures that would protect the site from not becoming a ‘strip-mall’
style development along the highway corridor. The New Mitigation Measure
described above would bring the PC-3 Specific Plan into conformity with General
Plan goals, policies and action items. The mixed use overlay designations along with
the scenic corridor planning prerequisites would create reasonable scenic setbacks
and provide a better connection between the development, residential and open space
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parcels, while avoiding a strip-mall development.
The DEIR Fails to Analyze and Mitigate Significant Visual Impacts for the PC-3:
The proposed zoning at PC-3 allows commercial, industrial and business related uses (BIZ,
M1, CL, CRS, and CR zones) within a broad scenic area along highway 267. These
proposed districts allow a variety of different uses and an allowed height of up to 50 feet
within the “CL and CR” districts (pg 3.12 of the Specific Plan) and within the “M1 and
BIZ” districts (pg 3.26 of the Specific Plan). The Town’s General Plan policy for PC-3
states “Site Design for PC-3 shall consider appropriate access to Highway 267, via
Brockway Road and Soaring Way, and shall minimize visual impacts from the Highway 267
corridor.” It is not clear how the actual structures are to be oriented, or how the
entrance/servicing areas are to be located. The Specific Plan also fails to mention building
mass or how internal vehicular and pedestrian circulation and parking is to be contained at
the development site. The lack of detail limits the Town and public’s ability to review the
potential environmental impacts prior to construction. This is legally inadequate. The
Specific Plan includes photographs of different structures that may be considered
appropriate but a detailed diagram of building masses, parking, circulation and setbacks
within each of the proposed parcels needs to be provided in a revised Specific Plan. A
revised DEIR can then look at potential impacts with these uses, and provide more clarity
and a better description of what the impacts may be. The Specific Plan and DEIR need to be
revised to include these design details and specifics.
The Draft EIR fails to address the visual impact of 50 ft high structures within the Highway
267 corridor. The visual simulations that are provided do not specifically state that the
depicted building masses are at a height of 50 feet. It is questionable whether a massing of
50 ft high structures along Highway 267 could adequately be mitigated to a less than
significant impact to the visual character of the area. The lack of detailed design diagrams
within the Specific Plan depicting the location of building masses, orientation, circulation
and landscape screening makes the portrayal of potential change to visual and community
character along the Highway 267 Corridor difficult to understand and analyze for adequacy.
The visual impact and change to the community cannot be adequately determined from the
DEIR. The Specific Plan and DEIR need to be revised to include the design specifics for
development at PC-3.
Furthermore, it is not clear if large floor plate businesses such as those being targeted would
be allowed to establish signage and lighting that would be at a 50 foot height. Large floor
plate development would obstruct the viewshed and character of the community with large
signage. How would this potential impact be mitigated? The DEIR needs to identify signage
impacts and mitigation measures for the type of development being proposed.
Additionally, it is not clear from the implementation strategies whether the proposed uses at
PC-3 are really supportive and will not compete with other local uses nearby and within the
downtown. The Specific Plan fails to identify a clear strategy for the relocation of light
industrial along the river to be relocated. How will relocation occur to the PC-3 Specific
Plan areas? The Specific Plan needs to outline potential incentives and be revised to include
a strategy for industrial relocation consistent with the Towns policies and process.
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Concluding Comments
The Specific Plan and DEIR for a project of this scale and size is seriously lacking the kind
of detail that is needed to offset large impacts to natural resources, community character and
visual resources at the PC-3 Project site. Our organization and experts have identified a
number of inadequate mitigation measures that clearly will not limit the impacts that a
project of this extent will have on the community and environment. We feel that a path
forward for the project applicant and the Town would be adding the New Mitigation
Measure, planning prerequisites and conditions of approval to the Specific Plan and DEIR.
These items will help to create a better vision for the project, with an integrated site design,
which mitigates the impacts that a project of this magnitude will have at the Gateway to
Truckee.
As the only environmental advocacy organization focused to create smart development in
Truckee we look forward to continue working with you to achieve the stated goals and
purposes of the Specific Plan and General Plan for PC-3. We believe that development
properly completed within the area can be an asset to the entire town and one that we could
support if the above mentioned steps are completed as a part of the revised Specific Plan and
DEIR. Our proposed mitigation measure is intended to assist you and provide a great
opportunity to fulfill your goals and purposes and provide both economic and environmental
benefits for the community.
The following attachments are provided to assist you with understanding the New
Mitigation Measure we are proposing, the inconsistencies with the General Plan and the PC-
3 project, a scenic analysis methodology, specific wetland resources at the site, a walking
circle diagram and more information on the consultants working with us to analyze the
impacts of the project.
Attachments:
• Attachment 1: Figure 1 Overlay Designation Diagram
• Attachment 2: PC-3 General Plan Inconsistencies
• Attachment 3: Scenic Sensitivity Analysis
• Attachment 4: Wetland Resources at PC-3
• Attachment 5: Walking Circles
• Attachment 6: Consultants CV/ Resume
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If you have further questions regarding our comments or new proposed mitigation measure
please feel free to get in touch with us.
Sincerely,
Alexis Ollar, MS & GISP
Executive Director
Mountain Area Preservation
530-582-6751
Alexis@mapf.org
CC: Terry Watt, Jared Ikeda & Shute, Mihaley & Weinberger
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Attachment 2
PC-3 Project Inconsistencies with Town of Truckee
2025 General Plan Policies
Vision Statement Supporting Concepts that are to guide implementation in Truckee
• The General Plan will reduce sprawl by planning for projected growth, locating new
development around existing developed areas, and by encouraging clustered
development (1-7)
• The environment is fundamental to the economy and quality of life in Truckee and
the General Plan will protect and enhance this resource. The General Plan will
protect important open space lands and natural resources, will work to increase the
amount of permanently protected open space, and will strive to enhance public
access to open space lands and public resources.
• The General Plan will reduce the dependence on the automobile in
Truckee by fostering compact development and providing for alternate
modes of transportation (1-7)
Land Use Element Guiding Principles
• Locate significant new development around existing developed areas. (2-2)
• Locate the highest density and intensity of development on infill sites within
existing developed areas. (2-2)
• Prevent "commercial" sprawl in Truckee.
• Improve the character and visual quality of development in the Gateway
Area, along the Brockway Road corridor, and along the Truckee River in the
Downtown Study area.
Policies to Guide Development of the Specific Plan for PC-3
• Policy-3 Site design shall consider appropriate access to Highway 267, via
Brockway Road and Soaring Way, and shall minimize visual impacts from
Hwy 267 corridor.(2-30)
• Policy-4 The Specific Plan shall include standards for the design of retail
shopping areas that avoid "strip commercial" site layout, and that are oriented
and scaled to the pedestrian realm. (2-30)
• Policy-6 "If land use or noise compatibility requirements of the Airport Land
Use Compatibility Plan preclude or reduce the total number of housing that
can be developed on PC-3, required workforce housing may be permitted to
be located off-site". (2-31) Alternate off site area for affordable housing
needs to be included in EIR, and evaluate location and environmental
impacts.
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New Zoning for PC-3
• PC-3 is creating new zoning for the proposed development. A build-out and
allowable square footage per zoning area needs to be defined. "Residential
units are allowed at a maximum density of 12 housing units per acre" (2-29).
How many residential units will be allowed? "An average FAR of 0.20 shall
apply to commercial and industrial development" (2-29). Square footage of
commercial/ industrial needs to be clarified ?
Goals for Land Use Element
Action A6.1- Conduct and independent economic analysis prior to approval of the Specific
Plans for PC-3. The PC-3 economic study was conducted in 2010, with economic analysis
from 2008. With in the town of Truckee we have already approved the maximum allowable
space for commercial development to date. The economic thresholds for the town and
commercial space need to be revisited, since the data is from 4 years ago.
Community Character Element
3-24 Brockway Road Corridor "The identification of an appropriate visual character for
the development at PC-3, in keeping with the desired character of the corridor as a whole, is
thus a critical concern of the goals, policies and actions of this element".
Goal of Community Character-14 Enhance the character and the qualities of the
Brockway Road Corridor as a gateway to Truckee.
Policies
P14.1 Preserve and enhance the open space character and qualities of the Brockway Road
Corridor by including appropriate buffering and screening from the road corridor, and
interspersing development areas or nodes with green space. (3-48)
Actions
A14.1 Prepare streetscape design plan for the Brockway Rd corridor, incorporating the
elements identified in Policies 14.1 (3-48)
Economic Development Element
Policy 8.1- Encourage new retail to locate in the Downtown. (6-13)
Actions
A8.2 Review all proposed commercial projects outside of Downtown Truckee for their
potential to draw retail sales revenue away from the Downtown retail business and, if
necessary, work with developers to re-configure projects so that they are complementary to,
not competitive with, Downtown commercial activity. Establish a strategy to attract new
retail establishments to Downtown Truckee. (6-14)
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Attachment 3
Scenic Sensitivity Analysis
Process to determine scenic sensitivity:
A detail study process is needed to determine scenic sensitivity, appropriate design
guidelines and regulations towards future development within the highway scenic buffer
overlay. The following process has been adapted from the Caltrans’ Standard
Environmental Reference
(www.dot.ca.gov/ser/vol1/sec3/community/ch27via/chap27via.htm) as a basis for this
discussion.
A Scenic Resource Evaluation must be performed. The evaluation process must incorporate
existing community goals and values through reviews of applicable adopted local plans, and
community involvement to achieve consensus for identifying sensitivities and preserving
and enhancing community character. A change in visual character cannot be described as
having good or bad attributes until it is compared with the viewer response to that change.
Public opinion concerning the established visual character of the regional landscape, and the
proposed project that could change that character are the basis for evaluating the contrast or
change in the visual character.
In order to establish a baseline from which proposed projects can be evaluated, the process
must provide a field review to:
• examine existing conditions and
• the extent of visibility
• determine viewpoints and viewer groups
• determine visual features, qualities and scenic resources within those extents
• vegetative or structural feature having local, regional, or statewide importance.
• landmark trees or groups of trees providing a setting or focus of attention
• vegetation masses that display outstanding features of form or age
• unusual planting that has historical value
• topographic features including unique, massive rock formations
• historic building or architectural features
• features specifically identified in applicable planning documents as having special
scenic value
• a unique focus or feature integrated with its surroundings or overlapping other scenic
elements to form a panorama
• an exceptional example of a visual scene displaying proportion, balance, rhythm, and
variety - all of these are amenable attractions of a visual scene
The Scenic Resource Evaluation must be provided in a technical report including
photographs and graphic information necessary to substantiate findings. The features
should be mapped or otherwise identified to communicate the baseline to all interested and
involved parties. The baseline serves as a point from which scenic impacts from future
developments may be determined, and from which appropriate mitigation measures can be
identified.
The Scenic Resource Evaluation becomes the basis for establishing design guidelines for
any future development proposals. The guidelines must also be established through
discussion with the community and especially with viewer groups that may be directly
affected. Design guidelines must establish context sensitive design including:
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• Harmonizing development with existing topography and land uses;
• Preserving and enhancing community character;
• Meeting the needs of non-motorized travelers;
• Preserving any historic resources that may be within the affected area
• Protecting sensitive features that have been established through the Scenic Resource
Evaluation.
Discussion of design guidelines should further encompass identification of possible
mitigation measures to bring the impact level to an acceptable level to the community. The
measures should insure that the visual integrity of the landscape is maintained such that new
introduced elements seem to “belong” and that there is a visual harmony as a whole.
The guidelines should require preparation of photo-simulations to demonstrate the likely
appearance upon completion of a proposed project. To assess visual impact and
conformance to design guidelines, all proposed projects must at a minimum include site
plans showing building massing, parking, vehicular and pedestrian circulation, entry points,
maintenance and service locations, landscape screening, signage and lighting.
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Attachment 5: ½ Mile Walking Circle at Proposed PC-3 Project Site
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Attachment 6: Consultants CV/Resume
Jared M. Ikeda - Land Use Planner
Jared Ikeda is a land use planner with more than forty years of professional experience in preparation
of land use planning studies, community planning, environmental impact studies, urban site
planning, landscape development plans, and recreation planning. He has been involved in a wide
range of studies and projects for both public and private sector clients and has participated in and
directed all phases of land planning, investigative studies and landscape development. He has served
on the board of directors of a major international landscape architectural firm, been responsible for
management of a 20-person professional office, management of specific project work, supervision,
and coordination of multi-disciplinary teams, as well as serving as a specialist within multi-
disciplinary teams.
He has served as a lecturer in the Department of Landscape Architecture at California State
Polytechnic University, Pomona. His teaching activities focuses upon advanced landscape design
and stresses use of computer technology including AutoCAD and ArcMap GIS software. He has
prepared a number of visual impact and simulation studies using a variety of computer software
including Sketchup and Google Earth. Most recently he has been involved in the preparation of the
Monterey County General Plan Update from 1999 to 2004 and was responsible for studies and
preparation of the Environmental Resource Management Element and the Circulation Element. He
also directed consultant work on the Environmental Impact Report.
Experience
A selected list of his experience includes:
Prepared Environmental Impact Reports and Statements for a variety of residential development
projects, wastewater treatment facilities, oil storage terminals, high voltage electrical transmission
lines, and park and recreation facilities.
• Directed the preparation of the Master Environmental Impact Report for the 20,000 acre
Chino Hills Specific Plan for the County of San Bernardino. The Specific Plan enabled
development of infrastructure and delineation of land use for a planned community of more
than 89,000 people. The planning process encompassed a two-year effort. Mr. Ikeda was
also responsible for the Citizen Participation Program.
• Prepared the Las Virgenes, Triunfo, Malibu, Topanga Areawide Wastewater Collection and
Treatment Plan EIR/EIS for the Las Virgenes Municipal Water District / US EPA. This
EIR/EIS encompassed a region extending from the western boundary of the City of Los
Angeles west to the City of Camarillo and south of the Ventura Freeway to the ocean. The
study area included the majority of the Santa Monica Mountains and the Malibu Coast. This
study investigated, mapped, and analyzed all environmental conditions including possible
growth inducement within an environmentally sensitive region. The study focused upon the
development of a wastewater collection, treatment and disposal system under Section 201 of
the Clean Water Act. The study spanned a two year period with an extensive public
participation program involving concerned groups and individuals from the onset of the
study and through the public hearing and certification process.
• Prepared a visual impact analysis and land restoration plan for the Colosseum Gold Mine, an
open pit gold mine near the California/Nevada border. The project utilized computer
generated visual simulations.
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• Soviet Embassy EIS, Washington D.C.
Client: US State Department
Prepared the Environmental Impact Statement for the Soviet Embassy in Washington, D.C.
for the U.S. State Department.
• Mr. Ikeda has served as a consultant to Economics Research Associates in preparing an
Economic Development Strategy for Riverside and San Bernardino Counties in Southern
California. Mr. Ikeda analyzed and provided land use and real estate development
opportunity information to the primary consulting firm.
• Served as Principal-in-charge and provided direction for the preparation of the Specific Plan
for the 2000 acre East Tustin Specific Plan (now known as the Tustin Ranch) for the City of
Tustin and The Irvine Company. The plan is a balanced community calling for 8000
residential units of varying densities; 40 acres of commercial uses; 120 acres of mixed use
including hotel, office and commercial uses; up to eight schools and seven parks and a
community golf course.
• Served as a Principal Planner for the preparation of the San Juan Capistrano Master Open
Space Plan. The study approach evaluated all open space resources within the City to
determine the best utilization and plan for 160 acres of newly acquired open lands by the
City. Mr. Ikeda's role in this citywide study was to assist in the public participation program,
computer mapping, and preparation of the final report. This project received an Honor
Award from the Orange County Chapter of the American Planning Association for best
comprehensive plan in 1992.
• Participated as a consultant team for the preparation of the La Verne Heights Specific Plan
for Lewis Homes of California. Mr. Ikeda's role was to prepare computer simulations of
visual impact of the residential development and the fuel modification of the natural hillside
vegetation to conform with the fire hazard safety ordinance of the City.
Experience
Principal: Ikeda Consulting, 2005 to Present
Board of Directors of Landwatch Monterey County, 2010 to Present
Monterey County Redevelopment Agency, 2004-2005
Senior Admin Analyst: County of Monterey, Environmental Resource Policy, 1999-2004
Lecturer: Cal Poly Pomona, Dept of Landscape Architecture 1997-1999
Vice-President/Officer-in-Charge EDAW Inc., Irvine Office: 1980 to 1987
Education
Bachelor of Science in Environmental Design, California State Polytechnic University,
Pomona, 1968.
Honors
Best Comprehensive Plan, Orange Co. Section, American Planning Association, San Juan
Capistrano Master Open Space Plan, 1992
Distinguished Alumnus Award, 1983, School of Environmental Design, California State
Polytechnic University, Pomona.
Merit Award, American Society of Landscape Architects, Santa Ana River Open Space
Study, 1973
Lectures & Publications
Mr. Ikeda has served as a guest lectureur at UCLA, UC Irvine, and Cal Poly Pomona. Mr.
Ikeda has also served as Chairman of a panel on Computers and Landscape Architecture for
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the Southern California Chapter of the American Society of Landscape Architecture.
Contributor to “Design with Digital Tools” McGraw Hill, 2000
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Attachment 6: Consultant CV/Resume
Terrell Watt, AICP
Terrell Watt Planning Consultants
1937 Filbert Street - San Francisco, CA 94123
terrywatt@att.net Office: 415-563-0543 Cell: 415-377-6280
Since 1989, Terrell “Terry” Watt, AICP, has owned Terrell Watt Planning Consultants. Ms.
Watt’s firm specializes in planning and implementation efforts focused on regionally-
significant projects that promote resource and working landscape conservation as well as
sustainable development patterns and practices. Prior to forming her own consulting group,
she was the staff planning expert with the environmental and land use law firm Shute,
Mihaly & Weinberger. She is an expert in general and specific planning and zoning, open
space and agricultural land conservation strategies and environmental compliance. Her
skills also include facilitation and negotiation, public outreach, project management and
negotiation. Terry is a frequent presenter at regional, national and statewide workshops and
symposiums on general plans and sustainability best practices and case studies. She holds a
Masters Degree in City and Regional Plan from the University of Southern California and a
Bachelor’s Degree in Urban Studies from Stanford University.
TERRELL WATT PLANNING CONSULTANTS (1989 to the present). Planning
Consulting Firm Owner
Terry works with a wide variety of clients throughout California including non-profit
organizations, government agencies and foundations. She volunteers up to half her
professional time on select projects. Recent projects and roles include:
Consultant to the California Energy Commission with a focus on public outreach and
input to the Federal and State agencies related to the Desert Renewable Energy
Conservation Plan (2011 ongoing). The DRECP is the largest conservation plan in
California, covering 7 southern California counties. This planning process has produced
a draft set of maps showing the conservation attributes for this large planning area for
the purpose of describing potential priority development areas for renewable energy and
conservation areas both on public and private lands. Conservation on private lands is
subject to willing seller interest. http://www.drecp.org/
Planning Consultant to California Attorney General’s Office - Environment Section
focusing on climate change, CEQA and general plans. (2007- 2010). While working
with the Environment Section, assisted with: key settlements (Stockton General Plan and
Pleasanton Housing Element litigation); creation and maintenance of locally based best
practices for local government planning to address climate change issues; and
government outreach and consultation on general plans and climate action plans/energy
elements/sustainability planning efforts. Post 2010 continue to provide focused
consulting services to the Environment Section related to case settlement.
Project facilitator for the Martis Valley Opportunity Agreement (MVOA) (2011 –
ongoing). The MVOA is an agreement by environmental and conservation groups
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(Mountain Area Preservation, Sierra Watch, Truckee Tahoe Land Trust, Trust for Public
Land) and a Business Group (Vail, Northstar, East West Partners and SPI) that would
result in “transferring” a portion of the general plan development allocation from 6500
acres of SPI property in the Martis Valley to a 750 acre parcel contiguous to existing
development at the Northstar Ski Resort. The 6500 acre property would be permanently
conserved as a result of the transfer of development approval in the form of a general
plan amendment by the Placer County Board of Supervisors (anticipated in 2014). An
early Agreement includes the escrow instructions and conservation easement for the
6500 acre site that would record once the County Board has approved the general plan
amendment “transfer of development.”
Measure M-2 Sales Tax and Environmental Mitigation Measure. (2009 – ongoing). Co-
project manager/facilitator of a 30+-member environmental coalition that through a
unique partnership with the Orange County Transportation Authority and state and
federal wildlife agencies garnered significant funding for programmatic environmental
mitigation (conservation land acquisition and stewardship) in Measure M2, Orange
County Transportation Sales Tax. In November 2010, the OCTA Board allocated $42
million to purchase open space from willing sellers to provide early mitigation for
transportation projects. Additional funding was allocated to habitat restoration.
http://www.octa.net/Measure-M/Environmental/Freeway-Mitigation/Overview/
State Office of Planning and Research (2011 – ongoing). Volunteer advisor/outreach
coordinator of the Governor’s Office of Planning and Research “listening tour” on
potential reforms to realign CEQA with the state’s policy priorities of infill and
renewable energy. (2011). Currently assisting OPR with an Infill and Renewable Energy
Template as part of the 2013 Update of the General Plan Guidelines.
Marin Countywide General Plan and Environmental Impact Report (2004 to 2007).
Project Manager for the award winning Marin Countywide Plan Update and its
Environmental Impact Report. This award winning plan and its EIR contain leading
edge sustainability policies and implementation measures, including for climate
adaptation and energy self sufficiency. It was the first General Plan and related
environmental document to address climate change and incorporate recommendations
from the Attorney General’s office. http://reinventingthegeneralplan.org/models/marin-
county/
Staff to the Martis Fund, a joint project of five environmental groups and a Business
Group (Highlands Group and DMB Inc.). (2008 – ongoing). Early efforts included
Martis Fund formation including establishment of a 6-person Board with 4
representatives of the environmental groups and 2 representatives of the Business
Group. The Fund has distributed over $4 million dollars since its inception to a range of
conservation, stewardship and workforce housing projects. Funding comes from a
permanent transfer fee on all real estate sales at Martis Camp,
http://www.martisfund.org/PDFs/Martis-Fund-Brochure.pdf
South Livermore Valley Development and Agricultural Conservation Plan. (2000 –
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2005) Planning Consultant to the City of Livermore to develop the South Livermore
Valley Specific Plan and related City-County joint Area plans and General Plan
Amendments. To date the plan has resulted in the development of a world class wine
country with over 4,000 acres preserved in permanent easements. Easements have been
purchased by the Tri-Valley Conservancy using mitigation funds collected by the City
and County and turned over to the Conservancy for purchase of easements from willing
sellers. www.trivalleyconservancy.org
Tejon Ranch Land Use and Conservation Agreement. (2006 – ongoing). Project
coordinator for a dialogue process between environmental groups (Natural Resources
Defense Council, Sierra Club, Endangered Habitats League, Planning and Conservation
League, Audubon California) and The Tejon Ranch Company that resulted in a major
Land Use and Conservation Agreement for the permanent protection of 240,000 acres
(90%) of the 270,000 acre Tejon Ranch. Ongoing role overseeing implementation of the
Agreement, including early role forming and managing the Conservancy formed by the
Agreement. The Agreement provided the cornerstone of the Habitat Conservation Plan
for a major portion of the Ranch; the Tejon Multi-Species Habitat Conservation Plan,
TUMSHP, approved in April 2013.
http://www.tejonconservancy.org/images/uploads/rwa_exec.pdf
Newport Coast Land Use and Conservation Agreement (1990 – ongoing). Led a
negotiated settlement between The Irvine Company and 8 environmental organizations
resulting in the conservation of 90 percent of the Newport Coast and development
concentrated on a portion of the 10,000 acre property adjacent to (and now annexed to)
Newport Beach.
Green Valley, Fairfield Conservation and Development Agreement. An Agreement
between landowners, the City and developers that resulted in formation of a land trust
and a permanent source of funding from community facilities fees on all new residential
and commercial development in the City. To date the Land Trust, now called Solano
Land Trust, has permanently protected over 22,000 acres of natural and agricultural
lands by leveraging dollars raised through development fees with private donations,
federal and state funding and grants.
Infill Locator for California (2005-06). Participant on the advisory panel to the
California Statewide Infill Study project conducted by UC Berkeley’s Institute for
Urban and Regional Development and sponsored by BTH, HCD and Caltrans. The
outcome of this project is a California Infill Parcel locator tool to pinpoint sites for
potential infill to inform the potential for infill development in existing cities and urban
areas of California.
http://communityinnovation.berkeley.edu/reports/Future_of_Infill_Vol_1.pdf
LA Infill Project. Project coordinator for the California Infill Estimation Methodology
Project funded by an Environmental Justice Grant from Caltrans and jointly sponsored
by the City of Los Angeles, County of Los Angeles and Environment Now.
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PROFESSIONAL MEMBERSHIPS AND BOARDS
• Lambda Alpha International - Golden Gate
Chapter
• American Institute of Certified Planners (AICP)
• American Planning Association (APA)
• Tahoe Fund Founding Board Member
• Founder Council of Infill Builders and Federation
AWARDS
• State and National APA Awards for Marin County General Plan
• Carla Bard Award for Individual Achievement
• Environment Now Award for Measure M Support
• CA State Association of Counties Distinguished Service Award