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HomeMy Public PortalAboutPublic Comment #044 (DFW)California Natural Resources Agency EDMUND G,BROWN.Jr.Governor DEPARTMENT OF FISH AND WILDLIFE charlton h.bonham,Director North Central Region 1701 Nimbus Road Rancho Cordova,CA 95670 (916)358-2900 www.wildlife ca.gov November 20,2014 Truckee Community Development Department Attn:Denyelle Nishimori,Senior Planner 10183 Truckee Airport Road Truckee,CA 96161 dnishimori@townoftruckee.com Subject:Revised DEIR for the Canyon Springs Subdivision (SCH#2004052060),County of Nevada,CA Dear Ms.Nishimori: On October 2,2014,the Department of Fish and Wildlife (CDFW)received the Revised Draft Environmental ImpactReport(DEIR)for the Canyon Springs Subdivision (Project). The CDFW appreciates the Lead Agency's willingness to accept comments on the Project until November 20,2014.The comments provided hereinare based on our review of the Revised DEIR. As a trustee for California's fish and wildlife resources,the CDFW has jurisdiction over the conservation,protection,and management offish,wildlife,native plants,and their habitat.As a responsible agency,the CDFW administers the California Endangered Species Act (CESA),theNative Plant Protection Act,and other provisions of the Fish and Game Code (FGC)that conserve the State's fish and wildlife pubic trust resources. The CDFW offers the following comments and recommendations on the proposed Project in our role as a trustee and responsible agency pursuant to the California Environmental Quality Act (CEQA),California Public Resource Code §21000 et seq. The main focus of this letter is to reinforcethe CDFW's concerns as expressed in the comment letter dated March 1,2013 relating to how theProject will have significant effects to the mule deer (Odocoileus hemionus)of the Verdi subunit of theLoyalton- Truckee deer herd and how the Project may lead to an increase in edge effects.The additionalmitigation measure included in the Revised DEIR does not reduce impacts to a less-than-significant level. The comments provided herein are based on the information provided in the DEIR,the CDFW's knowledge of sensitive and declining vegetative communities and wildlife species in the area.Comments herein are limited to the likely biological resource impacts from the proposed Project. Conserving California s WifdCife Since 1870 Ms.Nishimori November 20,2014 Page 2 of 5 Project Description The Project is located at the far eastern end of the Town of Truckee in the Canyon Springs area,immediately east of the Glenshire subdivision and approximately 1 mile south of Interstate 80.The Project would include 177 market-rate single family lots ranging in size from 14,000 to 31,000 square feet.The Project includes 100-foot to 300- foot visual buffers along the westerly border near the area of Edinburgh Drive and the northwest corner of the Project site.Approximately 176 acres will be dedicated to public open space and be permanently reserved by a conservation easement or dedication to the Town of Truckee/Truckee Donner Land Trust.The Project will require the construction of a road network with primary access from Martis Peak Road,and a secondary access from Edinburgh Drive.The road network will require two vehicular access points,four bridges and other utilities related infrastructure.The Project also proposes a multi-use recreationarea,along with a pedestrian and bicycle trail system. Impacts to the Loyalton-Truckee Deer Herd The CDFW has repeatedly provided evidence to the Town of Truckee via photo trap and collar data that the Canyon Springs property is used by the Verdi sub-unit (VSU)of the Loyalton-Truckee mule deer herd (LTDH)for migration,and most recently shown that certain deer use the property almost exclusively as summer range for forage, shelter and potentially as fawning grounds.The prime summer range of the VSU includes the remaining undeveloped portions of Martis Valley along with adjacent naturalhabitat in the greater Truckee area.Since2009,CDFW has been conducting ongoing monitoring around the Project site,which continues to provide data.Each collared deer found using the site is typically either pregnant or with fawns at the time of capture,suggesting that for each individual verified to be using the Project site,there areother non-collared deer that will be with them.The collared deer that migrate through,or that partially orexclusively use the property,are a subsample of the population and therefore only small representative of the actual number of deer that rely on it.Pellet surveys and camera arrays have also shown greater numbers of the deer using the site than those collared.The life-history characteristics of VSU and collar data indicate that deer have high site fidelity and return to the same summer and winter ranges,and migrate on nearly the same paths from year to year.Additionally,fawns learn migratory paths from their mothers,so there is no expectation for use of the Project site by the VSU to decrease. The CDFW would like to emphasize that the open space areas proposed to minimize the impacts of the Project on deer habitat occur generally around the outside of the clustered development.CDFW acknowledges the efforts taken to cluster development and limit the footprint of the lots.However,the remaining open space areas will be cut by interior roads,pedestrian trails and footbridges,limiting deer movement and use of the site for foraging.This design makes it unlikely that wildlife would use this open space.A compilation of studies suggest that edge effects may influence mammal behavior and reproductive success an average of 300 feet from alteredhabitat (Bentrup 2008).Geographical Positioning System (GPS)data shows deer using virtually the same path during spring and fall migration and returning to the same areas for fawning and summer range.Having totravel farther (ie.around the Project)to get to summer or Ms.Nishimori November 20,2014 Page 3 of 5 fawning areas impacts their energetics at a time when body conditions are depleted from the winter and females are pregnant.This data indicates that deer rely on the Project site for foraging and migration and will be displaced regardless of the 176 discontinuous acres designated as open space. Contrary to the conclusion of the Revised DEIR,the CDFW believes that the Project will significantly impact foraging habitat and the migration corridor of the VSU LTDH.The DEIR does not provide adequate mitigation to reduce impacts to less-than-significant. The cumulative effectsof past development and removal of additional habitat proposed in this Project will impact the LTDH and will lead to further significant decreases in the VSU population due to direct and indirect effects.Deerhave been documented as using the Project site for foraging and migration.We acknowledge that migrating deer may only be on the property for minutes or hours during migration and that the Project site is one of several pathways onto summer range but that does not lessen the impacts to deer that do rely on the Project site.Deer movements will be limited and forced to use the remaining open space areas,increasing browsing pressure,leading to habitat degradation,resulting in decreased fawn survivorship and general adult deer body condition (Chad et al.2009).Concentrating deer numbers onto smaller areas makes them more vulnerable to disease and predation (McLeod 1997).In turn,this could increase the presence of predators in the communityand the Project site including mountain lion (Puma concolot),American black bear (Ursus americanus)and coyote (Canis latrans),as predators tend to target deer with decreased body conditions (McLeod 1997).Additionally,the disturbance of Project construction,routine maintenance,noise,domestic pets (dogs),and habitat loss may have long-term population effects including the potential for the VSU to cease migrating into California from their winter range in Nevada. The Revised DEIR includes additional mitigation measures that will benefit deer during migration or during daily use while on summer range,but due to the likely significant adverse effects to the VSU LTDH as discussed above,the CDFW still recommends acre for acre habitat replacement in the form of a conservation easement or fee title acquisition and conservation easement to protect foraging and migration habitat within the remaining migration corridor if the Project alternative is adopted.Alternatively,the CDFW recommends considering subdivision at a minimum often acre parcels as suggestedby CDFW in 1990 for mitigation of Tahoe Boca Estates. Direct and Indirect Impacts from Edge Effects The Revised DEIR does not provide additional or any analysis of the potential biological impacts from edge effects resulting from the Project.When natural habitat is fragmented,it is concurrently reduced in area,dispersed in a matrix of human-modified habitat,and exposed to that matrix along its edges (Wilcox and Murphy 1985).This Project will have indirect effects in Canyon Springs where they either do not currently exist or exist to a lesser degree than they would with the Project.The area designated as open space is discontinuous across the Project site and is bisected by roadways and pedestrian trails.Edge effects,such as disturbance by human caused noise and lighting,decreases in avian productivity (Andren and Angelstam 1988),line-of sight Ms.Nishimori November 20,2014 Page 4 of 5 disturbances,air and water-borne contaminants associated with vehicles (air pollution can degrade vegetation),and fugitive dust during both construction and operation,are all documented impacts that have negative effects on sensitive biological resources that occur in similar habitat type as that of the Project site.Considering the information in the latter comments,the CDFW believes that there is ample reason for concern regarding the Project's long-term biological impactsfrom edge effects.The CDFW recommends that the final EIR thoroughly discuss and consider the significance of these effects and propose mitigation measures to reduce any significant effects to a level less-than- significant. Conclusion The proposed Project will have an impact to fish and/or wildlife habitat and should be evaluated in such a manner to reduce its impacts to biological resources.Assessment of fees under Public Resources Code §21089 and as defined by FGC §711.4 is necessary.Fees are payable by the project applicant upon filing of the Notice of Determination by the lead agency. Pursuant to Public Resources Code §21092 and §21092.2,the CDFW requests written notification of proposed actions and pending decisionsregarding the Project.Written notifications shall be directed to:California Department of Fish and Wildlife Region 2, 1701 Nimbus Road,Rancho Cordova,CA 95670. Thank you for considering our concerns with the adequacy of the DEIR.The CDFW personnel are available for consultation regarding biological resources and strategies to minimize impacts.If you have questions please contact Tanya Sheya,Environmental Scientist,by e-mail at Tanya.Sheya@wildlife.ca.gov or by phone at (916)358-2953. Sincerely, Tina Bartlett Regional Manager ec:Jeff Drongesen Isabel Baer TanyaSheya Sara Holm Department of Fish and Wildlife State Clearinghouse Ms.Nishimori November 20,2014 Page 5 of 5 References Andren,H.and Angelstam.1988 (Andren and Angelstam 1988).Elevated predation rates as an edge effect in habitat islands:experimental evidence.Ecology 64:1057-1068. Bentrup,G.2008.(Bentrup 2008)Conservation buffers:design guidelines for buffers, corridors,and greenways.Gen.Tech.Rep.SRS-109.Asheville,NC:USDA, Forest Service,Southern Research Station.Accessed online February 19,2013 http://nac.unl.edU/bufferquidelines/quidelines/2 biodiversitv/IO.html. Chad,J.B.,Gary,C.W.,David,J.F.,Bruce,E.W.,&Thomas,R.S.2009.(Chad et al. 2009)Effect of enhanced nutrition onmule deer population rate of Change/El efecto de la nutrition aumentada en la tasa de cambio poblacional de venados bura (odocoileus hemionus)/Effet d'un complement d'alimentation sur le taux de croissance d'une population de cerfs mulet.Wildlife Monographs,(172),1-28. McLeod,S.R.1997.(McLeod 1997)Is the concept of carrying capacity useful in variable environments?Oikos 79:529-542. Wilcox,B.A.,and D.D.Murphy.1985.(Wilcox and Murphy 1985)Conservation strategy:The effects of fragmentation on extinction.American Naturalist 125: 879-887.