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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 2 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. 3 • 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. 4 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 5 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). 6 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. 7 • 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 8 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 9 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). 10 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 11 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. 12 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 13 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. 14 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 15 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 16 17 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. 18 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) 19 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: 20 • 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. 21 22 23 24 Attachment 5: ½ Mile Walking Circle at Proposed PC-3 Project Site 25 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. 26 • 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 27 the Southern California Chapter of the American Society of Landscape Architecture. Contributor to “Design with Digital Tools” McGraw Hill, 2000 28 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 29 (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 – 30 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. 31 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