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Home My Public Portal AboutPublic Comment #038 (Pratt)John & Carol Pratt November 19, 2014 Denyelle Nishimori Associate Planner Town of Truckee 10183 Truckee Airport Rd Truckee CA 96161-3306 Ms Nishomori Some comments on the proposed Canyon Springs project: Traffic: 1. Canyon Springs Traffic Analysis Addendum was prepared by LSC Transportation and Consultants, Inc. on January 17, 2014. The traffic analysis is supposed to analyze School Season AM & PM peak travel times. The additional analysis was conducted December 26, 2013-January 17, 2014. This is during school holiday winter break for the Glenshire community and region; therefore traffic counts are invalid for the additional analysis conducted for traffic impacts associated with Canyon Springs, (pg. 4.14-1). RDEIR traffic counts invalid, need to be re-analyzed with a peer review 2. Table 4.14-1 Truckee General Plan Goals and Policies Pertaining to Transportation & Traffic, Policy CIR-P2.4 states ‘Discouraging the use of local and residential roadways as through routes, particularly for commercial and industrial traffic’, (pg.4.14-5). This could be challenged with the proposed project utilizing Edinburg for access or Martis Peak Rd. 3. Town Policy looks at the 10th highest summer weekday PM peak hour (4- 6pm) to analyze traffic impacts, yet for Canyon Springs the analysis will look at AM & PM peak hours for school related traffic. The analysis should look at both traffic triggers to analyze the future impact of this development as more second homebuyers purchase homes in the Glenshire area. Using only school AM & PM peak hours is not valid, the DEIR should analyze both in accordance with the Canyon Springs project, (pg. 4.14-15). 4. RDEIR states that a traffic analysis was utilized for Canyon Springs that was completed for the PC-3/Joerger Ranch Specifc Plan. PC-3 is a commercial and industrial development, how can this traffic analysis be utilized for a residential development outside of the Town core? Using this traffic analysis is invalid, and cannot be justified for RDEIR. (pg.4.14-19, citation 7) 5. RDEIR states that ‘Whitehorse Rd. looking to the west along Glenshire Dr. is roughly 195 feet, which does not meet the Town’s 330-ft requirement, and is a significant impact, (Pg. 4.14-53). RDEIR says may not be significant if Town Engineer approves a reduction of the corner sight distance to the minimum of CalTrans. This seems to be counter to Town Standards and should be re-evaluated with actual mitigation measures put in place. The intersection of Courtnay and Somerset also has sight limitations if the Edinburgh access is used. 6. RDEIR states that there is an unacceptable level of service (LOS) at Glenshire/Donner Pass Rd. intersection (pg. 4.14-51). Yet the pedestrian, bicycle path and mass transit section excludes that there is a significant impact, because there is no congestion management plan. If there is to be an unacceptable LOS at important intersection within the project vicinity, the EIR should analyze LOS with a congestion management plan in place. This needs to be re-analyzed with a congestion management plan created as well. Wetlands: 1. The project site includes 5.94 acres of wetlands, and is proposing fill to be placed in wetlands for the project implementation, with 54 square feet of disturbance to wetlands, (pg4.4-4142). Disturbance of these jurisdictional waters violates the Clean Water Act, section 404. The DEIR needs to provide mitigation to avoid disturbing the wetlands with the proposed footbridges and provide an alternative to disturbing the jurisdictional waters. RDEIR statement that the impact would be minimal is invalid, waters from the site flow to the Glenshire Pond & Truckee River, which would create cumulative impacts with fill added to the wetlands on site. 2. RDEIR states, ‘The project could directly impact these wetlands through modification of the hydrology that supports the area’, (pg. 4.4-42). Modification of the hydrology will have a direct impact to the Truckee River Watershed, this statement needs to be further clarified, as less than significant impact is not verified or studied. RDEIR needs to be revised to analyze how the hydrology will be modified, what the impacts are and how to mitigate. Elkhorn Ridge housing development has heavily disturbed the Glenshire area with lacking mitigation and poor construction, which has created water quality and erosion impacts to the Glenshire Pond. Canyon Springs cannot allow further development impacts to the small rural neighborhoods of Glenshire. 3. How does this impact water runoff from the hardscape to the proposed catchment basins or is it even possible to contain the water runoff and stop it from reaching the Glenshire Lake (pond and ultimately the Truckee River? 4. The RDEIR states that the newest filed study by the EIR biologist from LSA was conducted November 1, 2013 (pg. 4.4-8). November is usually a very dry time of the season in Truckee and is not ideal for biological field surveys. The DEIR needs to be revised to include a more recent biological field survey in the spring-summer months, the November 1st, 2013 field survey is inadequate to properly assess biological resources when the environment is in drought conditions. Furthermore the analysis of the new filed survey is not included in the appendixes, a RDEIR needs to include the field survey data. Wildlife: 1. The RDEIR states that ‘California Department of Fish & Wildlife (CDFW) is particularly concerned about the impacts to habitat (movement) and migration corridors of the Verdi subunit of the Loyalton-Truckee mule deer herd as a result of residential development and recreational use in the project area and increased edge effects, (see citation 18 & 19 on pg. 4.4-30). How can the RDEIR state there will be no impact to the deer herd when the RDEIR states CDFW are concerned with their decline with the proposed residential development. The RDEIR is inconsistent with the CDFW statements as written and cited in RDEIR and Appendixes. 2. CDFW concern for ‘the deer population declines in the Northern/Central Sierra have been substantial’, (pg. 4.4-30 citation 20). Again the RDEIR discounts the importance of the Loyalton-Truckee deer herd while CDFW and NDOW have submitted substantial evidence of the herd utilizing the area and region. By not protecting the corridor the herd utilizes the project threatens Town of Truckee General Plan Goal COS-5, the DEIR needs to create better mitigation to protect the longevity of this species. 3. The RDEIR further discounts the importance of the deer herd by stating only two significant deer occurrences have happened on the project site. When CDFW study a herd they do not collar the entire herd, they collar a select study sample. The data shows that the deer herd is utilizing the site. The statement ‘Critical fawning habitat for this deer herd occurs in two distinct locations approximately 1.5 miles south and 7 miles southwest of the project site; therefore, there is a low potential for fawning habitat for this mule deer herd on project site’, (pg. 4.4-31-32) is invalid as data from CDFW clearly shows the herd use of the project area and region. The statements made in RDEIR are inaccurate, trying to diminish the value of biological resources in the project parcels. A peer review of data points, maps, and surveys is needed. 4. RDEIR states the project would create disturbances for 20+ years, yet wildlife would have plenty of undisturbed areas to move through project site (pg. 4.4-44). This statement contradicts the claims that the deer herd is not utilizing the site. Deer continue to follow similar paths year after year, therefore the deer herd will be impacted with 20+ years of construction and development. This is a significant impact, a construction plan to minimize dust will not result in a less than significant finding. Further analysis is warranted to protect the deer migration and preservation of habitat, construction impacts are not mitigated, revise DEIR. There is also the very real probability that each parcel could have a in-law unit built on it, which would increase the density, traffic etc by an unkown factor. There should be a very clear mandate that the Edinburgh gate would be for emergency only. In conclusion, there are way too many flaws in this report and plan for it to go ahead with out significant change and review. Sincerely John & Carol Pratt 10531 Regency Cir - Truckee, CA 96161-1618 Phone (530) 587-5060 - FAX (530) 587-5060 – Cell (530) 448-1224 - E Mail jpratt2@sbcglobal.net