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HomeMy Public PortalAboutPublic Comment #037 (The Meadows HOA) The Meadows Homeowners Association P.O. Box 1696 Truckee, CA 96160 (530) 587-8647 November 14, 2014 Denyelle Nishimori Town of Truckee Community Development Department 10183 Truckee Airport Road Truckee, CA 96161 Re: Canyon Springs Revised Draft Environmental Impact Report The Canyon Springs Subdivision Project is the most recent of several residential developments proposed on this site. Through the years, The Meadows Association has closely followed all of these proposals and has consistently expressed our concerns about density and resulting impacts. Our most recent letter dated March 1, 2013 was submitted for consideration in the scope of the Draft Environmental Impact Report (DEIR). In reviewing the September 29, 2014 Revised Draft Environmental Impact Report (RDEIR), we found that our concerns were either inadequately addressed or not addressed at all. DENSITY: What is the TOTAL proposed density (not only the proposed 185 lots, but also multi- family housing and second dwelling units)? The RDEIR acknowledges that construction of second dwelling units are allowed, and includes a projection of 50% in the Traffic Study (Reference: TABLE 4.14-6 PROJECT TRIP GENERATION) but does not include them for impact discussion in any other areas. The Town’s own General Plan “assumes that 20 percent of all future single-family units will be secondary dwelling units”. However, the actual number could be higher since this is a new development and it is much easier to site plan a second unit when a lot is vacant. The 8 affordable lots will be allocated for future “multi-family” attached housing. The RDEIR assumes a total number of 26 affordable housing units (Reference: TABLE 4.14-6 PROJECT TRIP GENERATION). This number also needs to be factored into TOTAL density for impact discussion. TABLE 4.14-6 PROJECT TRIP GENERATION references a total “quantity” of 292. This is significantly higher than 185. This undetermined density should not be a hidden density. It should be a specific potential number and, therefore, included in the maximum approved density. For example if it is determined that 20% of new development will have second dwelling units, then a development of 100 units will only be able to create 80 lots, because 20 of the lots will have a second unit and thus will have reached the maximum allowed density. TRAFFIC - INTERSECTION OF WHITEHORSE ROAD/MARTIS PEAK ROAD/ GLENSHIRE DRIVE: The Meadows Association is particularly concerned about the intersection of Whitehorse Road/Martis Peak Road/Glenshire Drive. The RDEIR confirms that drivers exiting Whitehorse Road onto Glenshire Drive do not have adequate corner sight distance to judge acceptable gaps looking either to the east or west. Reference: RDEIR (4.14-53 to 4.14-57) i. Intersection Corner Sight Distance The addition of project traffic at the Martis Peak Road/Glenshire Drive/ Whitehorse Road intersection could result in hazardous driving conditions due to the current limited sight distance conditions. b) Whitehorse Road Looking West Along Glenshire Drive Whitehorse Road looking to the west along Glenshire Drive is roughly 195 feet, which does not meet the Town’s 330- foot requirement (see Figure 4.14-8). Please note this Figure does NOT take into account the reduced visibility due to snow banks in the winter months. The corner sight distance at this location is limited by the existing embankment and vegetation on the northwest corner of the intersection, as well as by the horizontal and vertical curvature along Glenshire Drive. The corner sight distance improves as the driver on Whitehorse Road approaches the edge of the travel lane on Glenshire Drive. Measured 10 feet back from the edge of the traveled way, the corner sight distance is approximately 195 feet, and when measured from a 5-foot setback the corner sight distance increases to approximately 255 feet; however, these values do not achieve the Town’s 330-foot requirement and impacts to drivers on Whitehorse Road would be potentially significant. The corner sight distance at this location could be improved by modifying the existing embankment on the northwest corner of the intersection. However, such an improvement would likely require the acquisition of right-of- way from the single-family parcel located on this corner. Town standards indicate that “where restrictive conditions do not allow compliance with the specified sight distance requirements, the Town Engineer may approve a reduction of the corner sight distance to the minimum stopping sight distance as outlined in the Caltrans Highway Design Manual.” According to Caltrans standards, at a 30-mile-per- hour design speed, the minimum stopping sight distance is 200 feet. Measured stopping sight distance for drivers approaching along Glenshire Drive from the west is 210 feet measured to an object six inches in height, and at least 255 feet to a vehicle turning into the westbound through lane. Therefore, adequate stopping sight distance is provided for eastbound drivers along Glenshire Drive to see and react to a driver pulling out from Whitehorse Road. Furthermore, no accidents were reported at this intersection during the 5-year period from 2006 to 2010. Therefore, hazardous driving impacts at this location would be less than significant and no mitigation measures are warranted. c) Whitehorse Road Looking East Along Glenshire Drive The corner sight distance from Whitehorse Road looking to the east along Glenshire Drive is roughly 170 feet, which does not meet the Town’s 330- foot corner sight distance requirement. To the east of the intersection Glenshire Drive curves to the north and then back to the south. When looking east from Whitehorse Road, a driver can see a portion of the road, but as it turns to the north it disappears from sight and reappears into the driver’s sight as it curves back to the south. The corner sight distance at this location is limited by an existing utility box in the northeast quadrant of the intersection, as well as by existing vegetation. If the existing utility box (actually a sewer pump station controller) and vegetation were removed, then the corner sight distance to the east would be improved to roughly 580 feet, thereby meeting minimum corner sight distance requirements. However, the stopping sight distance along Glenshire Drive east of Whitehorse Drive (measured along the travel lane) is over 500 feet, as the existing utility box does not block the driver sight line along the traveled way. Therefore, adequate stopping sight distance is provided. If a driver makes a right turn from Whitehorse Road without an adequate gap, a vehicle traveling on Glenshire Drive westbound would have adequate stopping sight distance to react and come to a stop. Furthermore, no accidents were reported at this intersection during the 5-year period from 2006 to 2010. Therefore, hazardous driving impacts at this location would be less than significant and no mitigation measures are warranted. It does not seem to be a reasonable or responsible conclusion that, because there were no accidents reported at this intersection PRIOR to the addition of 2,578 one- way daily vehicle trips. (Reference: TABLE 4.14-6 PROJECT TRIP GENERATION), that the impacts will be less than significant. There is no acknowledgement or studies of the additional reduction in visibility from all directions due to snow banks in the winter months. There is no acknowledgement or studies of the decreased stopping ability on icy roads, especially at the edge of a “steep grade of about nine percent” during the winter months. Yet, the drivers referenced above, that the RDEIR assumes are capable of stopping for someone pulling out from Whitehorse Road in front of them, are the same drivers referenced below that have two times the State and County average accident rates” and “need to leave more distance between vehicles and avoid sudden stops.” Reference: RDEIR (4.14-56 – 4.14-57) ii. Roadway Segment Hazards The Glenshire Drive east of Martis Peak Road roadway segment has an average accident rate (from 2006 to 2010) about two times the State and County average rates for similar facilities. The injury and fatal accident rate is also higher than the State and County average rates for similar facilities. However, the severity of the accidents is relatively minor overall, given that no fatalities were reported, and two- thirds of the accidents resulted in property damage only (no injuries). Furthermore, while one-third of the accidents occurred under icy/snowy road conditions, which represents a relatively small proportion of the overall winter, each of these acci- dents involved a single vehicle, and there were no injuries. This roadway segment has a steep grade of about nine percent. The existing travel lane width is striped to accommodate two 11-foot travel lanes with an outside fog line and the actual asphalt roadway is 24 to 25 feet wide in all locations. Paved and unpaved shoulder widths are generally 2 to 4 feet wide. Both Nevada County and Town of Truckee roadway design standards call for 12-foot travel lanes with 4-foot shoulders, and maximum grade of eight percent. Therefore, while this segment of Glenshire Drive is deficient with respect to the current County standards for this type of roadway in some areas, it essentially meets the required design standards. It should be noted that Glenshire Drive met the standards that were applicable at the time it was constructed. As the County standards have been up- dated over the years, most of the rural County roadways do not meet the current County standards. In 2008, Nevada County installed several hundred feet of guardrail along the por- tion of the roadway segment approximately 1,500 feet east of the Martis Peak Road/Glenshire Drive intersection, and rehabilitated the pavement on the Nevada County section of Glenshire Road in 2009. As previously stated, the Nevada Community Development Agency Department of Public Works’ investigations on this road show a majority of crashes occurred in 2006 and 2007 and were concen- trated in a 500 foot area approximately 1,500 feet east of the Martis Peak Road intersection. While the guardrail and pavement improvements were not specifically intended as safety projects, according to the Nevada Community Development Agency Department of Public Works, both improvements have contributed to overall improved roadway conditions at this location. The Nevada Community Development Agency Department of Public Works found that accident rates at this location have been reduced since these improvements have been installed. This is consistent with the County’s findings that crash rates typically drop after a pave- ment improvement project, either due to the improved pavement surface or the improved striping associated with pavement projects. While the accident rate along this roadway segment is higher than State and County averages, it would be speculative to try and predict potential traffic impacts based on variables such as icy/snowy road conditions or illegal driving behaviors such as speeding or using handheld electronics (e.g. smart phones) while driving. It is driver responsibility to comply with the law and exercise safe driving practices such as slowing down, leaving more distance between vehicles and avoiding sudden stops and quick direction changes in icy/snow conditions, which are often the cause of accidents. Additionally, in rural communities throughout California, including Truckee and the area surrounding the project site, the incident of vehicular and wildlife collisions is an expected and unpredictable hazard. Although the proposed project would result in an increase of up to 1,600 daily one- way trips, including 160 peak-hour trips, on this roadway segment, which when compared to existing conditions, equates to about a 50-percent increase in the total peak-hour traffic volume, the 2008 and 2009 roadway improvements, as described above, have reduced potential hazards at this roadway segment. Therefore, potential hazardous driving impacts related to the additional vehicle trips of the proposed project at this roadway segment would be less than significant. How can this impact be reduced to “less than significant”?? The RDEIR seems to conclude that because new asphalt and guard rails have been installed that it will reduce an accident rate that is two times the state and county average and putting another 1600 daily trips on this same road segment will have no impact. Those of us who live here and travel this road extensively are aware of the extremely hazardous driving conditions on this road segment. If you were to travel it today you would see numerous skid marks, glass from collisions and blood stains from animal/vehicle collisions. The icy/snowy road conditions of the winter months are particularly dangerous. Accidents and spin-outs occur on a regular basis. It is irresponsible to conclude that an additional 1600 daily trips on this road will be less than significant. In addition, one of the recommended mitigation measures will route even more traffic on this road segment. Mitigation Measure TRANS-4b: Construction traffic shall not be permitted to exceed the Town's level of service standards at the Glenshire Drive/Donner Pass Road and Glenshire Drive/Dorchester Drive intersections and construction traffic shall not travel to and from the project site using the Glenshire Drive/Donner Pass Road intersection during the AM or PM peak hour. (Reference: 4.14-70) If traffic is prevented from traveling down Glenshire Road/Donner Pass Road, the only other direction would be Glenshire Road east of Martis Peak Road. TRAFFIC – OTHER: * The RDEIR does not address the safety concerns for children leaving the Meadows communities from Whitehorse Road and walking along Glenshire Road to catch the school bus at Yorkshire with this increase in traffic. * Significant improvements to the intersection of Donner Pass Road and Glenshire Drive must be funded and completed before any additional projects are approved in the Glenshire Area. WILDLIFE: * What is the realistic impact on the Loyalton-Truckee Verdi sub-unit Deer Herd that returns to the Hirshdale/Glenshire/Martis Valley in the spring for fawning and summer forage and, in recent years, has been wintering over. In addition to the 100 plus acres of trees and vegetation expected to be removed for the project (Reference Biological Resources. D. Impact Discussion. 4.4-36 to 4.4-42), the RDEIR did not address what the additional loss of habitat in acres of trees and vegetation required by the Truckee Fire Protection District for: 1) 30’ defensible space around structures; 2) 10’ on both sides of roads and driveways; 3) Fuel Modification Plan for the entire subdivision, including a 200-300 ft. shaded fuel break. (Reference: DEIR Appendix B, Letter from Bob Bena, Truckee Fire Protection District May 12, 2011) What will be the cumulative loss of habitat for the Deer Herd and other wildlife? * The RDEIR continually references that long-term disturbances from human activity, pet dogs and other domestic pets belonging to homeowners and visitors to the project could have a significant impact on the herd. How will the proposed development protect deer and other wildlife from free-roaming domestic animals? The proposed mitigations in the RDEIR are inadequate as they are overseen by a homeowners association that can be changed at the whim of any majority of homeowners rather than by protective deed restrictions. * What are the guidelines for fencing within the proposed development? Will they inhibit migration and create a gauntlet effect? Again, realistic and enforceable mitigations need to be protected by deed restrictions rather than a homeowner association whose rules can be changed by the homeowners. * Will bear boxes be required to prevent increased interaction between humans and bears? GENERAL COMMENTS: * What is the effect to surrounding property values when there are so many vacant lots on the market within the Town already (Elkhorn Ridge, Grays Crossing, etc.)? * Why wasn’t the development of the adjacent “Teel/Raleys Property” included as a cumulative impact in the RDEIR? * The TDPUD and TSD have indicated that the Canyon Springs Project will require modifications or additional infrastructure to accommodate this subdivision. What cost will the existing district members bear? What modifications will be required to other existing infrastructure and what will be the resulting costs to district members? * The number of phases (8) with “build-out” of the project are anticipated to take “20 or more years”. We believe the proposed mitigations will do little to offset the continual construction traffic, noise and disturbance to surrounding homes for decades. Thank you for addressing the Association’s concerns. Sincerely, The Meadows Board of Directors: Ken Weakley Mike Sabarese Dave Giacomini