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Home My Public Portal AboutPublic Comment #052 (Echols)11/19/14 To: Denyelle Nishimori, Senior Planner 10183 Truckee Airport Rd. Truckee, CA 96161 dnishimori@townoftruckee.com Re: Comments for Canyon Springs Revised DEIR I have many concerns about the adequacy of the DEIR and RDEIR for Canyon Springs. Both the DEIR and the RDEIR are very inadequate, and do not honestly address environmental issues involved with the Canyon Springs Development. Also, many aspects of the development, as proposed, are in opposition to the Truckee General Plan. This letter pertains to the sections in the Revised DEIR only. Traffic/Transportation: 1. The RDEIR does not address all of the roadways and intersections that will be affected by the project. One intersection not addressed is Whitehorse/Glenshire Drive. The sight distance exceeds town threshold and mitigation is inadequate. The RDEIR also 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. The RDEIR says this may not be significant if Town Engineer approves a reduction of the corner sight distance to the minimum of Cal Trans. This intersection should comply with Town Standards and should be re-evaluated with actual mitigation measures put in place. 2. The RDEIR states that Edinburgh may be used as an access road. This road might be also used for construction traffic. This seems to be in opposition to the Truckee General Plan Goals and Policies Pertaining to Transportation & Traffic, Policy CIR-P2.4 which states ‘Discouraging the use of local and residential roadways as through routes, particularly for commercial and industrial traffic’ These roads are not built to handle vehicle trip generation with project loads nor 40,000 lbs. for TFPD. RDEIR also states the project will result in inadequate emergency access, Edinburgh would be a secondary access point, yet that is considered an artillery and neighborhood road way, which is not built to handle vehicle trip generation with project loads nor 40,000lbs for TFPD. RDEIR should identify other alternatives for emergency access and secondary access without impacting neighborhood streets. 3. RDEIR states the 2011 Truckee Trans Cad traffic model with the build out of the General Plan shows no further growth from 2025 to 2031. Canyon Springs would increase development, how can it be said that there will be no more further growth if Canyon Springs is developed? 4. The intersection at Glenshire Drive and Donner Pass Road is at a unacceptable of service (LOS) according to the RDEIR. 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. 5. Table 4.14-7 shows that in 2031 there will be less traffic generation than the 2011 traffic trips for the Glenshire community with the project implemented. How will there be less vehicle trips when there is more development, and 20 years of construction utilizing local roads for the project? This is not adequately addressed. Biological Resources: 1. Wetlands: There are 10 proposed housing units located within a 50 feet setback from the spring instead of the required 100-foot setback. 18.38.020 of the Truckee General Plan designates blue line permanent and seasonal waterways, of which Bucks Spring is one, as needing a buffer area between proposed development and designated stream corridors to protect valuable environmental, scenic and recreational resources. 2. Table 4.4-1 Truckee General Plan Policies Pertaining to Biological Resources, Goal COS- P1.5 states Preserve open space that, to the greatest possible extent, occurs in large blocks and is contiguous and connected. The proposed project ruins open space corridors by placing 185 high-density clustered housing lots throughout the parcel, which disturbs the current wildlife corridor that occurs on the project site. The DEIR should be revised to include a project alternative that abides by COS-P1.5, while preserving large blocks of open space in the project parcels. Biological Mitigation Measures and Impacts: 1. Mitigation Measure BIO-3 in RDEIR is invalid. Impacting wetlands is a direct violation of the Clean Water Act, section 404. Purchasing credits or paying in-lieu fees for the associated impact does nothing for the immediate environmental benefits of where the direct impact is taking place. RDEIR needs to be revised to include an alternative to impacting these resources. 2. Mitigation Measure BIO-5a, is invalid and contradicts the EIR consultants statements that there is a less than significant impact on wildlife, especially the deer herd. Utilizing HOA educational pamphlets to deal with the loss of wildlife habitat is completely inadequate. Development in this region will destroy the herd that utilizes it to migrate to Martis Valley, HOA brochures are not going to mitigate this issue. The RDEIR mitigation measure is invalid. 3. Mitigation Measure BIO-5b, is inadequate. The deer herd will not just stay concentrated in the south east corner of the project site. Fencing and signage will not deter the migration pattern. DEIR needs to be revised to include a realistic mitigation measure that protects the habitat the deer utilize, without fencing and signage. 4. Mitigation Measure BIO-5e & 5f, are invalid and contradict each other. Domestic pets need to be confined by 6 foot fences, yet there shall not be fences that impede wildlife movement on residential lots. These mitigation measures make no sense and would not minimize impacts for the wildlife corridor. They further re-instate that there is an associated impact with the project and diminish habitat for the Loyalton-Truckee deer herd, as stated in CDFW/NDOW findings and studies. 5. Mitigation Measure BIO-5g is inadequate, educational materials for the HOA will not minimize the impact to the loss of habitat for the Loyalton-Truckee Deer herd. DEIR needs to re- analyze the impact development will have on the loss of the habitat for deer, and provide an alternative. 6. Mitigation Measure BIO-5i, contradicts the EIR consultants statement that there is no migration corridor by providing mitigation to create signage to raise awareness of the corridor to vehicular traffic. It is Not feasible for a small HOA to have the capacity to implement all of the Bio-5 suggested inadequate mitigation measures. Enforcement would be impossible and still wouldn’t be adequate. This mitigation measure is invalid. Project Alternatives: 1. High Density Alternative, RDEIR states this is infeasible. Considering each lot at Canyon Springs could allow an additional unit/mother-in-law unit, which would create 400+ units. It is already a high density development proposal with more housing than suited for the project site 2. Rural Residential Alternative, RDEIR considers this infeasible when it actually aligns with the existing development in Glenshire, similar to the meadows. 3. RDEIR needs to re-analyze and include additional data to verify how this alternative is infeasible. After reviewing the RDEIR Project Alternatives, SOSG feels additional alternatives need to be analyzed in order to better protect sensitive resources within the project site. RDEIR notes that Alternative E is the environmentally superior alternative with only 88 lots proposed creating more open space. Yet much of the Alternative E development footprint is concentrated in the areas of the parcel with sensitive environmental features are located such as water resources and steep slopes. A RDEIR needs to analyze a project alternative with a more than 50% reduction, while locating proposed dwelling units away from sensitive slopes, wetlands or wildlife habitat. 4. Other Alternatives should be discussed: a. Air Quality-- There is still no appropriate mitigation for impacts. Project applicant should be required to submit a ‘Climate Program Plan’ like other projects in the Town of Truckee have been required to create, and submit when a project exceeds the regional standard. b. Development in this area of downtown fits better with high density, clustered development near the core of Town. c. Alternate Land Use, project could be conserved as open space and densities for development transferred to areas that are more suitable for development The RDEIR for Canyon Springs is not adequate, and much of the information is not substantiated. This project is not environmentally sound, nor is it consistent with Truckee's General Plan. Thank you for your time. Sincerely, Kathy Echols SOS Glenshire kathyechols@sbcglobal.net