HomeMy Public PortalAboutPublic Comment #059 (Kelley)November 19, 2014
To: Denyelle Nishimori, Senior Planner
10183 Truckee Airport Rd.
Truckee, CA 96161
dnishimori@townoftruckee.com
Re: Comments for Canyon Springs Revised DEIR
Dear Denyelle,
The following are comments and concerns regarding the adequacy of the RDEIR for the proposed Canyon
Springs housing development:
Biological Resources
Town of Truckee 2025 General Plan, Goal LU-3, Policy P3.3 states: To provide for projected population
growth in an efficient manner, accommodate development at the highest densities in infill areas, consistent
with goals for environmental protection and land use compatibility. The Canyon Springs proposed
development plan is inconsistent with this GP Goal/Policy in many areas. The RDEIR needs to be revised
to include measures to adequately meet Truckee goals for environmental protection.
P4.4-25 d. of RDEIR states regarding Verdi subunit of the Loyalton-Truckee mule deer herd: “This subunit is
known to utilize the project site and surrounding area for foraging, movement and migration. The project
site and surrounding area includes open space habitat to accommodate wildlife movement”. The first
sentence of this statement supports the project site as a migration corridor; therefore warranting only
interpretation of data by the herd’s qualified managers, California Department of Fish and Wildlife (CDFW).
The second sentence is not credible and infeasible, as the open space on the project cannot be deemed as
adequate space for the deer movement, especially given the deer being a high fidelity animal.
Migration map: There is a 2/1988 CDFG map of the Loyalton-Truckee Deer Herd, indicating a migration
corridor going through the Canyon Springs project site. This information has not changed; therefore, the
RDEIR needs to address measures to protect this designated corridor. The current/ongoing collaring studies
are still in progress and not fully interpreted by CDFW at this point so should not be the only source used to
designate important areas to protect for this deer herd. This map was re-created in an updated fashion based
on the CDFG 2/88 map information. (Please see updated map attached).
Collared deer on project site: There are many not yet interpreted data files from CDFW along with many
photos during the 2010 to present indicating collared deer on the project site, including southwest and
northwest areas. This conflicts with RDEIR statements.
New data from CDFW not disclosed: The Town of Truckee indicated in their Notice of Availability
Errata that they received new collaring data from CDFW on 9/22, but did not use in the RDEIR
due to data being raw, etc. I made a public request for this data and below Town’s response.
The information you are requesting was provided by CDFW. That particular information was proprietary
draft information and not allowed for public disclosure. The Public Records Act, CGC 6250, in
particular; CGC6254, states items not required to be disclosed include 3(a)” preliminary drafts, notes or
interagency or intra-agency communications prepared by, on behalf of or for the use of, any state agency
…” and (4)” information received in confidence by any state agency”.
I believe CGC6154 does not apply to factual data. Further, this information is public per the CDFW. I am
concerned the RDEIR may be lacking some vital information due to omitting this data and feel it should be
part of the RDEIR analyses as well as the ongoing data from the collaring study.
Wetlands/Hydrology: The RDEIR needs to address the wetlands and Glenshire Pond/Lake impacts from
project, based on comments and input from Army Corp, Lahontan Water Quality Control Board and other
governing agencies.
Hydrology comment for the record, due to new information learned
Glenshire Pond/Lake: New information learned regarding the Glenshire Pond, which is a tributary to the
Truckee River. The Glenshire Devonshire Homeowners Association could be required by the state
governing agencies to do clean-up and abatement if the pond got to an unacceptable level. This could cost
the Glenshire homeowners millions. A revised and/or final DEIR needs to address this and how Canyon
Springs owners would indemnify the Glenshire Devonshire Residents Association in any clean-up and
abatement order due to the project sediment run-off.
Repeated Comments to previous 2012 Canyon Springs DEIR: I feel the RDEIR does not adequately
address my prior comments to the 2012 Canyon Springs DEIR; therefore, I am repeating them below.
BIOLOGICAL RESOURCES
Plant Communities
Sawyer and Keeler-Wolf 1995 reference used for analyses in the DEIR is outdated. This has been
updated in 2009 and analyses need to be done with the updated reference.
The updated/current 2010 Alliances and Associations of Habitats on the CDFW website need to be
used in the DEIR analyses.
Biological Resources
Plant Communities
Sawyer and Keeler-Wolf 1995 reference used for analyses in the DEIR is outdated. This has been
updated in 2009 and analyses need to be done with the updated reference.
The updated/current 2010 Alliances and Associations of Habitats on the CDFW website need to be
used in the DEIR analyses.
Snags
P4.4-26: These microhabitats provide feeding habitat for woodpeckers and nesting and roosting
habitat for cavity nesters, including owls, woodpeckers, and bats. Approximately 72 snags occur on the
project site.
P4.4-40: Project impacts: Implementation of the project would result in removal of approximately
27.92 acres of Jeffrey pine community, approximately 7.25 acres of sagebrush community, and removal of
approximately 26 snags. These communities provide potential habitat for Sierra Nevada red fox, goshawk,
willow fly-catcher, and yellow warbler, and removal of this habitat could impact these species if they are
present on the project site during construction. An additional approx. 76.68 acres of these combined
communities would occur within the residential and recreation lots subject to increased human presence, and
could result in this habitat becoming less suitable for these species.
Figure 4.4-43: Indicates approximately 17 snags will be removed on southern portion of project, just
to accommodate a few parcels. The DEIR does not indicate on the map which snags will be removed, and
puts the reader in the position of making assumptions. Further, it appears that 10 of the 72 existing snags on
site are the only 10 on the upper north half of the project site. Figure indicates that all but possibly 2 or 3 of
these snags would be removed to accommodate the placement of lots/roads. This snag removal along with
the proposed deer and other wildlife habitat removal would basically destroy the possibility of wildlife
thriving in this upper portion of the site, making this impact “significant”. How will the DEIR amend the
project to lessen this impact to “insignificant”?
DEIR goes on to say that most of the potential impacts to wildlife that feed or nest off of the
proposed habitat and snags to be removed or cut up by residences and trails, would be “less than significant”.
There needs to be more study data, under direction and supervision of the CDFW, especially for the removal
of the snags – this could be detrimental to many species in the region. There needs to be further research on
how waiting to cut trees down until after nesting season, will the birds return? I understand that birds did not
return to The Old Greenwood project in Truckee, after cutting trees down.
Special-Status Wildlife
Bats
P4.4-56 Impact BIO4: Removal of Jeffrey pine habitat and snags could potentially disturb roosting
bats if active roosts are present on the project site.
P4.4-56 Mitigation Measure BIO-4: At least two days prior to removal of snags and potential roost
trees, construction activities shall commence in the vicinity of the potential roosts to expose bats potentially
using the roosts to the sounds and vibrations of equipment with the intention of causing the bats to leave the
roost, thus avoiding potential injury when the roost is removed.
DEIR contradicts itself, wherein Impact BIO4 states removal of habitat and snags could potentially
disturb roosting bats, but then suggests a mitigation measure that would definitely disturb roosting bats by
imposing the sounds and vibrations of equipment onto them with the intention of causing bats to leave the
roost, thus avoiding potential injury when the roost is removed. While removing snags after forcing the bats
out of their roost may avoid potential injury when a roost tree or snag is removed, the alternative of the
trauma caused by to forcing them out of their roost with loud construction noise pollution, basically “bullying”
them out of their roost, deems this not an acceptable mitigation. This scare tactic and removal of trees/snags
would likely initiate a decline in the bat population in the region, by virtually removing one of their roosting
areas. The response from my friend’s daughter when she heard about this so called “mitigation measure” for
the bats sums this up (this came from what she learned in an anti-bullying project at school). Her comment:
“I think the developers need to put themselves in the bats’ shoes!”
This proposed mitigation measure for bats is inhumane and dangerous to the species. The DEIR
needs to readdress this. The only acceptable mitigation measure is to leave the wildlife habitat in place and
devise a way to develop around the habitat. (Put yourself in their shoes!)
Got off track a bit here, but the wildlife habitat and snag destruction is not necessary; please address how it
can be preserved while still developing this site?
Back on track…this unnecessary removal of Jeffrey Pine habitat and Snags conflicts with Town
General Plan Goal COS-5, Policy P5.3: Protect to the extent possible federal or State-designated endangered,
threatened, special status or candidate species. This COS-5, P5.3 is conflicted with in many areas of the
biological section of this DEIR. Removal of wildlife habitat and snags will be detrimental to the bird
population in the region, causing a severe decline.
Bald Eagle
P4.4-29: No bald eagles were observed on or near the project site during previous surveys.
There have been many sightings of bald eagles on the site and in the vicinity (within one mile),
especially due to bodies of water in the vicinity.
Loyalton-Truckee Verdi sub-unit deer herd
The Loyalton-Truckee Verdi sub-unit deer herd (VSU) is known for utilizing the project site for their
spring and fall migration, as well as summer foraging. This area is vital to the herd in order for them to get to
their fawning grounds in the spring, forage in the summer to help maintain a healthy state, then to return to
their wintering grounds in the fall.
The project conflicts with the Town General Plan (GP) Goal COS4-P4.1 – in that the plan does not
adequately provide for the integrity and continuity of biological resources open space, habitat and wildlife
movement corridors, as the open space proposed would be interrupted by trails, roads, humans and dogs,
including removal of habitat, and is not contiguous or large enough.
The project conflicts with the Town GP Goal COS4-P4.2 – in that the plan does not protect
sensitive wildlife habitat from destruction by incompatible land uses where appropriate, i.e. movement
corridors are being disrupted by too much habitat removal, development, 20+ years of noise and air pollution,
and disrupting connectivity of the VSU herd.
The project conflicts with the Town GP Goal COS-5 – in that the CDFW deems the VSU as a
declining and valuable biological resource.
P4.4-27states (In reference to the Verdi sub-unit (VSU): “This subunit is known to utilize the project
site and surrounding area for migration purposes. Wildlife corridors are within the project area designated as
open space”. This statement makes an assertion that the deer use only the open space of the project, when
cameras and sightings in other areas of the DEIR indicate they also use portions of the project that is
proposed to be developed on. How can it be proved they do not use any parts of the proposed project other
than the designated open space?
P4.4-32 states “According to CDFG in their 1988 Loyalton-Truckee Deer Herd Plan Update, the
majority of the Canyon Springs site is located within a major migration corridor of the Loyalton-Truckee deer
herd”. Then makes assumption: “However, recent data suggests that only a few individuals use the site as a
corridor or for forage at any given time”. This assumption includes no verbiage following it indicating the
support for this assumption (not easy for the reader to find these materials). The DEIR clearly dismissed
1988 plan due to their current small study data. Their data gathering is relying on insufficient data.
DEIR Conclusion section of Appendix E, 4-13 states: “Given the size of the population of mule
deer in the region, very few of them utilize the Canyon Springs site during the time period when migration is
expected to occur”. This statement is proven to be inaccurate: see pg 3-3 and 3-6 in Appendix E: camera
study results of the DEIR biologist indicate 151 deer detections on the site during the VSU fall 2010/spring
2011 migration periods. Per the DEIR, the estimated count of the VSU herd is approximately 800, therefore
151 camera detections on the site equates to approximately 20% of the total herd count. This study data
indicates many of the deer utilize the Canyon Springs site during times when migration is expected to occur.
This is especially true given the cameras were out for only two 65 day periods, at only four stations of each
corner of the site, and on only 283 acres! (If the count were only10% of the herd utilizing this site, it would
be very significant!) .
Conflicting statements in DEIR, section 4.2 of appendices, first paragraph, it is stated the LTDH
uses the general vicinity of the Canyon Springs site and other areas in the vicinity during migration. Last
paragraph states the site is not a major deer migration corridor.
Have the DEIR consultants given the project owner’s deer report any independent peer review or
consulted any other experts for other information or possible dissenting opinions. The deer analysis appears
to be biased due to conflict of interest and needs more factual and recent data.
Has John Heal consulted in the capacity directly for any of the project owners, developers, engineers
or other related parties? If so, this warrants a peer review of his research and studies before the project goes
before the Planning Commission for approval.
P4.4-38: states “the project would also include the installation of approximately 2,600 linear feet of
new off-site water mains adjacent to existing roadways in the Glenshire residential area located to the west of
the project. It does not state the exact location or what seasons this would occur in. This could have a
significant impact on the VSU deer herd due to documented camera sightings. What wildlife studies will be
done in conjunction with Town GP Goal COS-4 and 5 to protect sensitive wildlife habitat from destruction
and intrusion by incompatible land uses, maintain biodiversity with special consideration of the VSU , a
valuable biological resource, etc.? The DEIR needs to fully disclose details and deploy strict mitigation
measures to eliminate any “significant impacts” this water main project installation would cause to the VSU
and other wildlife.
Per February 2013 phone communication I had with Sara Holm, Wildlife Biologist with California
Department of Fish and Wildlife (CDFW):
1. Sara Holm stated the DEIR biologist camera study count of 151 indicated significant use of this site
by the VSU in migratory seasons.
2. Hundreds of deer occurrences were captured on 16 CDFW cameras deployed adjacent to and on the
border of Canyon Springs site, including bucks, does, fawns, and collared deer Sara stated this is
significant when cameras were placed randomly, not knowing where most of deer had been cited.
Cameras were placed along top northwest corner and south & southwest corners and over an
approximate two year period (winter not included). Significant deer usage was recorded at edge of
both north & south project site.
3. CDFW and Nevada Department of Wildlife (NDOW) collaring study for the deer herd has been
underway since fall 2009 and still has 3 collars to deploy in spring 2013. There was 1 collared deer
between 11/5/11 & 11/6/11 recorded going through Canyon Springs property (definitely
migrating), along with two others on the Canyon Springs property. This is significant, as these 3
deer were collared randomly and away from Canyon Springs, so anticipating the new collar data to
show more.
4. The deer are site faithful - like to use the same path, and use same summer and winter ranges. Last
set of collars proved they followed same paths, and when a change happens, it affects their
energetics, wasting energy, does are pregnant when they arrive - they are already energetically taxed
when they go through the winter - it can affect their ability to survive. Deer spend majority of their
time on summer range, if they have does in poor condition and they cannot have new fawns, the
herd will not maintain themselves. This is a migrating herd of deer, and can’t just look at any one
part of their life cycle, as they won’t survive one cycle without the other. All 4 phases are as vital as
the other – Winter Range, Migrating, Summer Range, and Fawning Grounds.
5. Existing satellite collars indicate the deer use very small summer ranges, within 1 – 2 square miles. So,
this indicates that home ranges are so small that to document any significant Canyon Springs deer
usage, the collaring would have had to been on or very near the Canyon Springs site. Preliminary
reports John Heal acquired from NDOW (appendix E, pg 4-23) were collared on the wildlife area,
not the Glenshire area. If deer were collared on the Canyon Springs site, Sara would expect them to
use the site extensively, and not much on other land.
6. When asked why deer were not collared on the Canyon Springs site, Sara replied because there was a
difference of opinion on how data would be used, as the land owners wanted exclusive use of the
data. The owners were initially willing to allow collaring, but the department wasn't willing to give
them exclusive rights to the data. So, they were collared adjacent to the property, along with 16
cameras deployed.
7. The 14 satellite collars out will not come off until 2014. No final write up being done due to still
actively collecting data. Probably no reports until early 2015, for whole picture for Verdi sub-unit.
Based on my above comments and outlined communication with Sara Holm regarding the Loyalton-
Truckee Verdi sub-unit Deer Herd, please note the following:
DEIR conflicts with many Truckee General Plan Goals and Policies.
DEIR clearly misrepresents the current VSU usage of the Canyon Springs site, as well as the
importance of this site to the overall herd vitality (per relying on inadequate data, assumptions, and
conflicting statements).
DEIR omits the significant impacts the proposed development would have on the VSU due to
habitat removal, building where they have site fidelity (same paths of movement), interrupting connectivity
and foraging grounds.
DEIR states there is no direct evidence that the deer use the site or critical migration in substantial
numbers – Critical Migration is not explained.
DEIR does not give direct evidence that deer DO NOT use the site for migration.
DEIR discounts summer range, as it is just as critical as the other phases: wintering range, migration
corridors and fawning areas, which is why CDFW and NDOW, the herd’s winter range managing entity, are
working together on the current collaring study.
Per CDFW and NDOW, recent deer activity has been recorded on the Canyon Springs site.
The fact that the CDFW/NDOW current collaring study indicates deer activity on the Canyon
Springs site and being the only comprehensive state wildlife agency study underway for the VSU herd since
1988, 25 years ago, it is highly warranted to extend this EIR process until the study is completed and reports
prepared. It would be a detriment to the declining valuable VSU deer herd and a vital omission in this EIR
process to continue to the approval stage of this project that is being proposed in the middle of their corridor
without gaining the information from the completed collaring study. The wildlife need a voice. We (the
public, developers and the Town) are their voice.
All of the above deems the project as proposed to be a “significant impact” to the VSU deer herd.
DEIR needs to be amended to address all above inadequacies.
P4.4-26: These microhabitats provide feeding habitat for woodpeckers and nesting and roosting habitat for
cavity nesters, including owls, woodpeckers, and bats. Approximately 72 snags occur on the project site.
P4.4-40: Project impacts: Implementation of the project would result in removal of approximately
27.92 acres of Jeffrey pine community, approximately 7.25 acres of sagebrush community, and removal of
approximately 26 snags. These communities provide potential habitat for Sierra Nevada red fox, goshawk,
willow fly-catcher, and yellow warbler, and removal of this habitat could impact these species if they are
present on the project site during construction. An additional approx. 76.68 acres of these combined
communities would occur within the residential and recreation lots subject to increased human presence, and
could result in this habitat becoming less suitable for these species.
Figure 4.4-43: Indicates approximately 17 snags will be removed on southern portion of project, just
to accommodate a few parcels. The DEIR does not indicate on the map which snags will be removed, and
puts the reader in the position of making assumptions. Further, it appears that 10 of the 72 existing snags on
site are the only 10 on the upper north half of the project site. Figure indicates that all but possibly 2 or 3 of
these snags would be removed to accommodate the placement of lots/roads. This snag removal along with
the proposed deer and other wildlife habitat removal would basically destroy the possibility of wildlife
thriving in this upper portion of the site, making this impact “significant”. How will the DEIR amend the
project to lessen this impact to “insignificant”?
DEIR goes on to say that most of the potential impacts to wildlife that feed or nest off of the
proposed habitat and snags to be removed or cut up by residences and trails, would be “less than significant”.
There needs to be more study data, under direction and supervision of the CDFW, especially for the removal
of the snags – this could be detrimental to many species in the region. There needs to be further research on
how waiting to cut trees down until after nesting season, will the birds return? I understand that birds did not
return to The Old Greenwood project in Truckee, after cutting trees down.
Special-Status Wildlife
Bats
P4.4-56 Impact BIO4: Removal of Jeffrey pine habitat and snags could potentially disturb roosting
bats if active roosts are present on the project site.
P4.4-56 Mitigation Measure BIO-4: At least two days prior to removal of snags and potential roost
trees, construction activities shall commence in the vicinity of the potential roosts to expose bats potentially
using the roosts to the sounds and vibrations of equipment with the intention of causing the bats to leave the
roost, thus avoiding potential injury when the roost is removed.
DEIR contradicts itself, wherein Impact BIO4 states removal of habitat and snags could potentially
disturb roosting bats, but then suggests a mitigation measure that would definitely disturb roosting bats by
imposing the sounds and vibrations of equipment onto them with the intention of causing bats to leave the
roost, thus avoiding potential injury when the roost is removed. While removing snags after forcing the bats
out of their roost may avoid potential injury when a roost tree or snag is removed, the alternative of the
trauma caused by to forcing them out of their roost with loud construction noise pollution, basically “bullying”
them out of their roost, deems this not an acceptable mitigation. This scare tactic and removal of trees/snags
would likely initiate a decline in the bat population in the region, by virtually removing one of their roosting
areas. The response from my friend’s daughter when she heard about this so called “mitigation measure” for
the bats sums this up (this came from what she learned in an anti-bullying project at school). Her comment:
“I think the developers need to put themselves in the bats’ shoes!”
This proposed mitigation measure for bats is inhumane and dangerous to the species. The DEIR
needs to readdress this. The only acceptable mitigation measure is to leave the wildlife habitat in place and
devise a way to develop around the habitat. (Put yourself in their shoes!)
Got off track a bit here, but the wildlife habitat and snag destruction is not necessary; please address how it
can be preserved while still developing this site?
Back on track…this unnecessary removal of Jeffrey Pine habitat and Snags conflicts with Town
General Plan Goal COS-5, Policy P5.3: Protect to the extent possible federal or State-designated endangered,
threatened, special status or candidate species. This COS-5, P5.3 is conflicted with in many areas of the
biological section of this DEIR. Removal of wildlife habitat and snags will be detrimental to the bird
population in the region, causing a severe decline.
Bald Eagle
(2012 DEIR) P4.4-29: No bald eagles were observed on or near the project site during previous
surveys.
There have been many sightings of bald eagles on the site and in the vicinity (within one mile),
especially due to bodies of water in the vicinity.
Loyalton-Truckee Verdi sub-unit deer herd
The Loyalton-Truckee Verdi sub-unit deer herd (VSU) is known for utilizing the project site for their
spring and fall migration, as well as summer foraging. This area is vital to the herd in order for them to get to
their fawning grounds in the spring, forage in the summer to help maintain a healthy state, then to return to
their wintering grounds in the fall.
The project conflicts with the Town General Plan (GP) Goal COS4-P4.1 – in that the plan does not
adequately provide for the integrity and continuity of biological resources open space, habitat and wildlife
movement corridors, as the open space proposed would be interrupted by trails, roads, humans and dogs,
including removal of habitat, and is not contiguous or large enough.
The project conflicts with the Town GP Goal COS4-P4.2 – in that the plan does not protect
sensitive wildlife habitat from destruction by incompatible land uses where appropriate, i.e. movement
corridors are being disrupted by too much habitat removal, development, 20+ years of noise and air pollution,
and disrupting connectivity of the VSU herd.
The project conflicts with the Town GP Goal COS-5 – in that the CDFW deems the VSU as a
declining and valuable biological resource.
P4.4-27states (In reference to the Verdi sub-unit (VSU): “This subunit is known to utilize the project
site and surrounding area for migration purposes. Wildlife corridors are within the project area designated as
open space”. This statement makes an assertion that the deer use only the open space of the project, when
cameras and sightings in other areas of the DEIR indicate they also use portions of the project that is
proposed to be developed on. How can it be proved they do not use any parts of the proposed project other
than the designated open space?
P4.4-32 states “According to CDFG in their 1988 Loyalton-Truckee Deer Herd Plan Update, the
majority of the Canyon Springs site is located within a major migration corridor of the Loyalton-Truckee deer
herd”. Then makes assumption: “However, recent data suggests that only a few individuals use the site as a
corridor or for forage at any given time”. This assumption includes no verbiage following it indicating the
support for this assumption (not easy for the reader to find these materials). The DEIR clearly dismissed
1988 plan due to their current small study data. Their data gathering is relying on insufficient data.
DEIR Conclusion section of Appendix E, 4-13 states: “Given the size of the population of mule
deer in the region, very few of them utilize the Canyon Springs site during the time period when migration is
expected to occur”. This statement is proven to be inaccurate: see pg 3-3 and 3-6 in Appendix E: camera
study results of the DEIR biologist indicate 151 deer detections on the site during the VSU fall 2010/spring
2011 migration periods. Per the DEIR, the estimated count of the VSU herd is approximately 800, therefore
151 camera detections on the site equates to approximately 20% of the total herd count. This study data
indicates many of the deer utilize the Canyon Springs site during times when migration is expected to occur.
This is especially true given the cameras were out for only two 65 day periods, at only four stations of each
corner of the site, and on only 283 acres! (If the count were only10% of the herd utilizing this site, it would
be very significant!) .
Conflicting statements in DEIR, section 4.2 of appendices, first paragraph, it is stated the LTDH
uses the general vicinity of the Canyon Springs site and other areas in the vicinity during migration. Last
paragraph states the site is not a major deer migration corridor.
Have the DEIR consultants given the project owner’s deer report any independent peer review or
consulted any other experts for other information or possible dissenting opinions. The deer analysis appears
to be biased due to conflict of interest and needs more factual and recent data.
Has John Heal consulted in the capacity directly for any of the project owners, developers, engineers
or other related parties? If so, this warrants a peer review of his research and studies before the project goes
before the Planning Commission for approval.
P4.4-38: states “the project would also include the installation of approximately 2,600 linear feet of
new off-site water mains adjacent to existing roadways in the Glenshire residential area located to the west of
the project. It does not state the exact location or what seasons this would occur in. This could have a
significant impact on the VSU deer herd due to documented camera sightings. What wildlife studies will be
done in conjunction with Town GP Goal COS-4 and 5 to protect sensitive wildlife habitat from destruction
and intrusion by incompatible land uses, maintain biodiversity with special consideration of the VSU , a
valuable biological resource, etc.? SOS Glenshire has shared data from a wildlife camera study that indicates
hundreds of deer sightings in a concentrated stretch along Glenshire Drive west of the project sight over
spring-fall 2011 and 2012, 398 in one area and this was with one of the two cameras failing for about half of
the deployed time. The DEIR needs to fully disclose details and deploy strict mitigation measures to
eliminate any “significant impacts” this water main project installation would cause to the VSU and other
wildlife.
Per February 2013 phone communication I had with Sara Holm, Wildlife Biologist with California
Department of Fish and Wildlife (CDFW):
8. Sara Holm stated the DEIR biologist camera study count of 151 indicated significant use of this site
by the VSU in migratory seasons.
9. Hundreds of deer occurrences were captured on 16 CDFW cameras deployed adjacent to and on the
border of Canyon Springs site, including bucks, does, fawns, and collared deer Sara stated this is
significant when cameras were placed randomly, not knowing where most of deer had been cited.
Cameras were placed along top northwest corner and south & southwest corners and over an
approximate two year period (winter not included). Significant deer usage was recorded at edge of
both north & south project site.
10. CDFW and Nevada Department of Wildlife (NDOW) collaring study for the deer herd has been
underway since fall 2009 and still has 3 collars to deploy in spring 2013. There was 1 collared deer
between 11/5/11 & 11/6/11 recorded going through Canyon Springs property (definitely
migrating), along with two others on the Canyon Springs property. This is significant, as these 3
deer were collared randomly and away from Canyon Springs, so anticipating the new collar data to
show more.
11. The deer are site faithful - like to use the same path, and use same summer and winter ranges. Last
set of collars proved they followed same paths, and when a change happens, it affects their
energetics, wasting energy, does are pregnant when they arrive - they are already energetically taxed
when they go through the winter - it can affect their ability to survive. Deer spend majority of their
time on summer range, if they have does in poor condition and they cannot have new fawns, the
herd will not maintain themselves. This is a migrating herd of deer, and can’t just look at any one
part of their life cycle, as they won’t survive one cycle without the other. All 4 phases are as vital as
the other – Winter Range, Migrating, Summer Range, and Fawning Grounds.
12. Existing satellite collars indicate the deer use very small summer ranges, within 1 – 2 square miles. So,
this indicates that home ranges are so small that to document any significant Canyon Springs deer
usage, the collaring would have had to been on or very near the Canyon Springs site. Preliminary
reports John Heal acquired from NDOW (appendix E, pg 4-23) were collared on the wildlife area,
not the Glenshire area. If deer were collared on the Canyon Springs site, Sara would expect them to
use the site extensively, and not much on other land.
13. When asked why deer were not collared on the Canyon Springs site, Sara replied because there was a
difference of opinion on how data would be used, as the land owners wanted exclusive use of the
data. The owners were initially willing to allow collaring, but the department wasn't willing to give
them exclusive rights to the data. So, they were collared adjacent to the property, along with 16
cameras deployed.
14. The 14 satellite collars out will not come off until 2014. No final write up being done due to still
actively collecting data. Probably no reports until early 2015, for whole picture for Verdi sub-unit.
Based on my above comments and outlined communication with Sara Holm regarding the Loyalton-
Truckee Verdi sub-unit Deer Herd, please note the following:
DEIR conflicts with many Truckee General Plan Goals and Policies.
DEIR clearly misrepresents the current VSU usage of the Canyon Springs site, as well as the
importance of this site to the overall herd vitality (per relying on inadequate data, assumptions, and
conflicting statements).
DEIR omits the significant impacts the proposed development would have on the VSU due to
habitat removal, building where they have site fidelity (same paths of movement), interrupting connectivity
and foraging grounds.
DEIR states there is no direct evidence that the deer use the site or critical migration in substantial
numbers – Critical Migration is not explained.
DEIR does not give direct evidence that deer DO NOT use the site for migration.
DEIR discounts summer range, as it is just as critical as the other phases: wintering range, migration
corridors and fawning areas, which is why CDFW and NDOW, the herd’s winter range managing entity, are
working together on the current collaring study.
Per CDFW and NDOW, recent deer activity has been recorded on the Canyon Springs site.
The fact that the CDFW/NDOW current collaring study indicates deer activity on the Canyon
Springs site and being the only comprehensive state wildlife agency study underway for the VSU herd since
1988, 25 years ago, it is highly warranted to extend this EIR process until the study is completed and reports
prepared. It would be a detriment to the declining valuable VSU deer herd and a vital omission in this EIR
process to continue to the approval stage of this project that is being proposed in the middle of their corridor
without gaining the information from the completed collaring study. The wildlife needs a voice. We (the
public, developers and the Town) are their voice.
All of the above deems the project as proposed to be a “significant impact” to the VSU deer herd.
DEIR needs to be amended to address all above inadequacies.
TRANSPORTATION AND TRAFFIC
DEIR indicates no accident data for the portion of Glenshire Drive from Donner Pass to the West
entrance of Glenshire. This information needs to be included and the analysis of traffic impacts re-done
utilizing this information. Many accidents and deer/vehicle collisions have been observed on this portion of
Glenshire Drive. Further, mitigation measures need to be implemented for the already failing intersections of
Glenshire Drive and Olympic Dr, and Glenshire Drive and Highland. What mitigation measures will be
implemented?
P4.14-58 ii: “The roadway segment of Glenshire Drive east of Martis Peak Road as a steep grade of
about nine percent. The existing pavement width accommodates 11 ft travel lanes with no shoulder in some
locations…Therefore, as this segment of Glenshire Drive does not meet the design standards, it is considered
to have an existing geometric deficiency.” The Glenshire Drive east of Martis Peak Rd roadway segment on
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…”
The above-referenced road/traffic information indicates the roadway segment of Glenshire Drive
east of Martis Peak road is a significant impact by being dangerous and hazardous. The stretch of Glenshire
Drive indicates the possibility of the same; however, study data needs to be retrieved before this analysis can
be made. The only analysis I have is on the ground residents observing many accidents in this section of
roadway.
Information listed in the Wildlife Vehicle Collision Reduction Study – Report to Congress, August
2008 clearly indicates Glenshire Drive, Hirschdale Road and Martis Peak rate high for Wildlife Vehicle
Collisions:
The increase in Wildlife Vehicle Collisions (WVCs) appears to be associated with an increase in vehicle miles
traveled (VMT).
The occurrence of WVCs, however, is associated with many more factors, as reflected by their characteristics,
which include:
•More than 98 percent of WVCs are single-vehicle crashes.
•89 percent of WVCs occur on two-lane roads.
•WVCs occur more frequently on low-volume roads.
• Compared to all motor vehicle collisions, WVCs occur more frequently on straight roads with dry road
surfaces.
" W V C s o c c u r m o r e f r e q u e n t l y i n t h e e a r l y m o r n i n g ( 5 9 a . m . ) a n d e v e n i n g ( 4 p . m . 1 2 a . m . ) , w h e n d e e r a r e
m o r e a c t i v e a n d t r a f f i c v o l u m e i s r e l a t i v e l y h i g h .
" W V C s o c c u r m o r e f r e q u e n t l y i n s p r i n g a n d e s p e c i a l l y i n f a l l , w h e n a n i m a l s m o v e a r o u n d m o r e d u e t o
m i g r a t i o n , m a t i n g , o r h u n t i n g s e a s o n s .
" T h e v a s t m a j o r i t y ( a s h i g h a s 9 0 p e r c e n t i n s o m e s t a t e s ) o f r e p o r t e d W V C s i n v o l v e d e e r .
W h a t a r e t h e c o n s e q u e n c e s a n d i m p a c t s t o d r i v e r s a n d a n i m a l s ? T h i s n e e d s t o b e a d d r e s s e d t h r o u g h s t u d i e s
a n d m i t i g a t i o n m e a s u r e s . W h a t w i l d l i f e a n d r o a d w a y s t u d i e s w i l l b e d o n e t o a d d r e s s t h i s s i g n i f i c a n t i m p a c t ?
F u r t h e r , I h a v e o b t a i n e d S O S G l e n s h i r e d a t a f r o m t h e i r r e c e n t w i l d l i f e / r o a d w a y c a m e r a s t u d y i n t h e
a r e a f o r t w o s p r i n g - f a l l s e a s o n s o f 2 0 1 1 a n d 2 0 1 2 . T h e d a t a i n d i c a t e s v e r y h i g h d e e r u s a g e o n o r n e a r a r e a s o f
G l e n s h i r e D r , H i r s c h d a l e R d , M a r t i s P e a k R d a n d E d i n b u r g h a s f o l l o w s :
1 . E a s t e r n p o r t i o n o f G l e n s h i r e D r i v e a r e a b e t w e e n M a r t i s P e a k a n d H i r s c h d a l e R d : 3 1 4 d e e r d e t e c t i o n s
2 . M a r t i s P e a k R o a d , j u s t w e s t o f t h e p r o j e c t s i t e : 2 7 4 d e e r d e t e c t i o n s
3 . G l e n s h i r e D r i v e , w e s t o f t h e m i d d l e o f t h e p r o j e c t s i t e : 3 9 8 d e e r d e t e c t i o n s
4 . G l e n s h i r e D r i v e , w e s t o f G l e n s h i r e e n t r a n c e : 1 6 4 d e e r d e t e c t i o n s
5 . E d i n b u r g h : 9 9 d e e r d e t e c t i o n s ( n o t e : c a m e r a i n d i c a t e d t h i s a r e a i s h i g h l y u t i l i z e d b y m a n y o t h e r w i l d l i f e
s p e c i e s a s w e l l )
N O T E : T h e r e w e r e s o m e c a m e r a / b a t t e r y m a l f u n c t i o n s a t l o c a t i o n s 1 - 3 a b o v e , s o t h e r e i s a s l i g h t
u n d e r s t a t e m e n t , a n d s i g n i f i c a n t m a l f u n c t i o n s a t l o c a t i o n 4 a n d 5 , s o p r o b a b l y a h i g h u n d e r s t a t e m e n t .
N O T E : T h e m a p p i n g o f t h i s d a t a i s n o t y e t c o m p l e t e d a n d s h o u l d b e a v a i l a b l e e a r l y s p r i n g 2 0 1 3 .
N O T E : T h e f o l l o w i n g i n f o r m a t i o n c a m e f r o m a r e s i d e n t a t G l e n s h i r e a n d W h i t e H o r s e R o a d i n t e r s e c t i o n o n
M a r c h 5 , 2 0 1 3 : S u m m e r a n d f a l l a r e t h e b u s i e s t w i t h d e e r a c t i v i t y . I c a n c o n f i d e n t l y s a y t h a t i n t h e s u m m e r a n d f a l l i t ' s a
d a i l y s i g h t i n g . T h e y l i k e t o g r a z e a c r o s s t h e s t r e e t l a s t F a l l / S u m m e r s e e m e d t o b e e x c e p t i o n a l l y b u s y w i t h d e e r u p G l e n s h i r e
D r i v e o n m y w a y h o m e f r o m w o r k . R e a l l y h a d t o w a t c h i t . D o e s n ' t s u r p r i s e m e t h a t t h e F a w n S i g n w e n t u p , b u t a f e w w e r e
k i l l e d .
P E S 4 , # 4 o f T r a f f i c A p p e n d i x : ( R e : G l e n s h i r e D r i v e e a s t o f M a r t i s P e a k R o a d ) : I t i s r e c o m m e n d e d
t h a t t h e p r o j e c t a p p l i c a n t c o n t r i b u t e u p t o $ 5 0 , 0 0 0 t o f u n d a s a f e t y s t u d y a s w e l l a s i m p l e m e n t a t i o n o f s a f e t y
i m p r o v e m e n t s a l o n g t h i s r o a d w a y s e g m e n t .
T h e a b o v e w i l d l i f e / r o a d w a y d a t a w a r r a n t s t h e s a m e r e c o m m e n d a t i o n f o r a w i l d l i f e / r o a d w a y s a f e t y
s t u d y a n d i m p r o v e m e n t s a l o n g t h i s r o a d w a y . A n a l y s i s s h o u l d b e i m p l e m e n t e d t o c a l c u l a t e s u c h c o n t r i b u t i o n
b y t h e a p p l i c a n t . P e r m a n y c o m m u n i c a t i o n s w i t h w i l d l i f e b i o l o g i s t s o f t h e H i g h w a y 8 9 S t e w a r d s h i p T e a m ,
s i g n s a r e n o t a n e f f e c t i v e m i t i g a t i o n m e a s u r e s . F e n c i n g a n d c r o s s i n g s a r e h i g h l y r e c o m m e n d e d .
B a s e d o n t h e a b o v e i n f o r m a t i o n , i t i s i m p e r a t i v e a w i l d l i f e / v e h i c l e c o l l i s i o n s t u d y b e p e r f o r m e d , a s
w e l l a s a w i l d l i f e / r o a d w a y s t u d y f o r t h e r o a d s t h a t w o u l d b e i m p a c t e d b y t h e p r o p o s e d d e v e l o p m e n t p r o j e c t .
S O S G l e n s h i r e c a m e r a s t u d y d a t a s e e m s t o b e a d e q u a t e i n p r o v i n g s i g n i f i c a n t d e e r u s a g e o n t h e m a i n
r o a d w a y s t h i s p r o j e c t w o u l d i m p a c t . L a c k o f a d d r e s s i n g t h e s e i s s u e s i s a g r o s s o m i s s i o n i n t h e D E I R . W h a t
s t u d i e s a n d m i t i g a t i o n m e a s u r e s w i l l b e d o n e t o a d d r e s s t h e s i g n i f i c a n t i m p a c t s t h i s p r o j e c t w o u l d h a v e o n
W V C s ?
T h a n k y o u f o r a l l o w i n g m e t o a d d r e s s m y c o n c e r n s r e g a r d i n g t h e R D E I R f o r C a n y o n S p r i n g s . P l e a s e f e e l f r e e
t o c o n t a c t m e w i t h q u e s t i o n s r e g a r d i n g m y c o m m e n t s a n d c o n c e r n s a d d r e s s i n g t h e a d e q u a c y o f t h e R D E I R .
S i n c e r e l y ,
L o r i K e l l e y
L o r i K e l l e y
l k e l l e y l @ s b c g l o b a l . n e t
S O S G l e n s h i r e M e m b e r