HomeMy Public PortalAboutPublic Comment #063 (Holan)November 19, 2014
To: Denyelle Nishimori, Senior Planner
10183 Truckee Airport Rd.
Truckee, CA 96161
dnishimori@townoftruckee.com
Re: Comments for Canyon Springs RDEIR
Dear Denyelle,
As a professional biologist and a 14-year resident of Truckee, I continue to have serious
concerns about the Revised DEIR for the proposed Canyon Springs development.
The location of the proposed project site adjacent to the Glenshire neighborhood and in
proximity to open water (Glenshire Lake) with its associated large dry and wet meadows,
and to the Truckee River makes the project site a very desirable habitat for wildlife to
concentrate. As such, proposed development needs to be sensitive to the land’s role in the
local ecosystem and mitigation measures must be responsible and realistic. The proposed
high-density plan for 185 units at the periphery of the Town covering virtually all
buildable land is neither sensitive to its current ecological functions, nor in keeping with
the surround level of development and land use. I have significant concerns about many
assessments of “less than significant impacts” to avoid mitigation measures, and about
the inadequacy of mitigation measures where they do exist.
My most serious concerns with the RDEIR fall into three categories:
i) incomplete biological survey data
ii) inaccurate assessments of impacts
iii) inadequate mitigation measures
i) Inadequate biological survey data
As noted in my previous comments on the DEIR (March 5, 2013) and unsatisfactorily
addressed by the RDEIR, surveying was conducted primarily in the atypically wet year of
2011 (April 5, May 3, June 8 and 30, July 6 and 11). In the RDEIR, additional surveys
from 2010 (Aug 30, Sept 1 and 2, Oct-Dec) and 2013 (Nov 13) have been included,
however, the surveys from 2010 and 2013 were too late in the year to identify many plant
species. Most notably, the California rare and endangered Plumas ivesia was specifically
surveyed for in June of 2011 when another known population was blooming and readily
identifiable. As noted, 2011 was an exceptionally wet spring, and Plumas ivesia prefers
mesic (not wet) conditions. Plants are sensitive to hydrologic conditions and their
presence and abundance can vary greatly from year to year. A single-year survey
conducted in an atypical year is likely not representative of the typical flora of the area.
Surveys conducted in alternate years will likely produce different observations, however
the surveys conducted in 2010 and 2013 were too late in the year to identify Plumas
ivesia (and many other plant species) because they have already senesced by the end of
August and certainly by November. Because of the inter-annual variation of
environmental conditions and the biota that respond to these conditions, single-year
surveys are not accurate enough or comprehensive enough to be acceptable in even basic
scientific studies. Thus, the designation of “U” (“Unexpected”, Table 4.4-2) for Plumas
ivesia is not sound given the focused survey was conducted in a “wet” year and the other
survey were not conducted in the appropriate season. This species has the potential to
occur on the site, and in fact have been observed adjacent to the site, so a single season of
survey data are not sufficient. The supplemental literature reviews of the general area
(Foothill Assoc., Inc., 2004; Eco-Analysts, 1990) do not provide sufficient resolution for
this specific site. Please provide site-specific and seasonally appropriate survey data
from typical as well as atypical (2011) survey years.
The intent to survey the site for fox dens and bird nests prior to construction is valid,
however, given that many birds and mammals can use the same nesting and den sites year
after year, surveying for active den or nest sites should have taken place prior to creating
the development plan. The applicants have created a development plan for which any
existing den or nest sites require mitigation, rather than surveying the site and accounting
for possible existing nest or dens sites. The mitigation measures outlined in the RDEIR,
in the case of Sierra Nevada red fox (BIO-1) consists of obtain a “take” permit which
could potentially terminate a breeding fox pair and their litter. To consider this strategy
“less than significant” is incredible. Surveying should already have taken place to
minimize the potential nest or den conflict with construction, and to avoid potentially
“taking” an entire red fox family.
ii) Inaccurate assessment of impacts
The proposed project site represents a large tract of undeveloped forest and meadow land.
It occurs adjacent to a productive body of shallow open water (Glenshire Lake) and its
associated large wetland meadow. Thus, the absence of water resources direct on the
development property does not preclude animals that nest, forage or roost near water.
Canyon Springs is likely the best location for many birds and mammals that can easily
travel between Glenshire Lake and wetland and the undeveloped land of Canyon Springs,
particularly since the lake and Canyon Springs are connected by a greenbelt corridor.
Several of the impact assessments (goshawks, bald eagles, bats) and subsequest lack of
mitigation measures rest on the absence of water on the project site but fail to appreciate
that there is large meadow, wetland and year-round waterbody within only several
thousand feet of the project site, and Truckee River within 1 mile. For flying animals like
bald eagles, goshawks and bats, these distances are well within the foraging range of a
nest or roost site, making Canyon Springs a very desirable location for breeding.
However, as stated in the RDEIR:
B a l d e a g l e s f o r a g e i n l a r g e b o d i e s o f w a t e r & f e e d s p r i m a r i l y o n f i s h b u t w i l l e a t s m a l l
m a m m a l s , w a t e r f o w l , s e a b i r d s , a n d c a r r i o n . B a l d e a g l e s b u i l d l a r g e s t i c k n e s t s i n t a l l
t r e e s o r o n c l i f f s , u s u a l l y w i t h i n o n e m i l e o f w a t e r & N o s u i t a b l e n e s t i n g o r w i n t e r i n g
h a b i t a t i s p r e s e n t o n t h e p r o j e c t s i t e & m a r g i n a l f o r a g i n g h a b i t a t p r e s e n t , [ s o ] t h e r e i s l o w
p o t e n t i a l f o r b a l d e a g l e t o o c c u r o n t h e p r o j e c t s i t e
B a l d E a g l e s a r e a s s e s s e d a s L L o w P o t e n t i a l f o r O c c u r r e n c e ( T a b l e 4 . 4 - 2 )
G l e n s h i r e L a k e i s j u s t � m i l e f r o m t h e w e s t e r n s i d e o f t h e p r o j e c t s i t e , w h e r e b a l d e a g l e s
h a v e b e e n o b s e r v e d h u n t i n g w a t e r f o w l , a n d T r u c k e e R i v e r i s 1 m i l e a w a y , w h e r e b a l d
e a g l e s c a n r e g u l a r l y b e o b s e r v e d . I s t r o n g l y d i s a g r e e w i t h t h e a s s e s s m e n t t h a t b a l d
e a g l e s h a v e l o w p o t e n t i a l t o o c c u r ( o r e v e n n e s t ) o n t h e p r o j e c t s i t e .
A d d i t i o n a l l y i n t h e R D E I R :
G o s h a w k s n e s t i n c o n i f e r o u s f o r e s t * , u s u a l l y o n n o r t h - f a c i n g s l o p e s * * n e a r w a t e r * * * ,
a n d i s e x t r e m e l y d e f e n s i v e o f n e s t i n g t e r r i t o r y . L a c k o f n o r t h - f a c i n g s l o p e s a n d
p e r m a n e n t w a t e r p r e c l u d e s g o s h a w k s f r o m n e s t i n g o n t h e p r o j e c t s i t e & D u e t o t h e l a c k
o f s u i t a b l e n e s t i n g h a b i t a t , t h e r e i s l o w p o t e n t i a l f o r g o s h a w k t o o c c u r o n t h e p r o j e c t s i t e
* J e f f e r e y p i n e i s t h e m o s t c o m m o n p l a n t c o m m u n i t y o n t h e p r o j e c t s i t e ( s e c 2 . a . 1 .
S e t t i n g , P l a n t C o m m u n i t y )
* * T h e p r o j e c t s i t e i s a f o r e s t e d a r e a w i t h m e a d o w s a n d w e t l a n d s t h a t t r e n d n o r t h -
w e s t e r l y t h r o u g h t h e c e n t r a l a n d s o u t h e r n p o r t i o n s o f t h e s i t e . ( s e c t i o n 2 . S e t t i n g ) t h i s
r e s u l t s i n r i d g e s s l o p e s w i t h n o r t h e a s t a s p e c t s .
* * * G l e n s h i r e L a k e i s j u s t � m i l e f r o m t h e w e s t e r n s i d e o f t h e p r o j e c t s i t e
P l e a s e c l a r i f y h o w t h e p r e s e n c e o f p r e d o m i n a n t l y c o n i f e r f o r e s t w i t h n o r t h e a s t -
f a c i n g s l o p e s a n d p r o x i m i t y t o w a t e r r e s u l t i n L o w P o t e n t i a l f o r O c c u r r e n c e o f
g o s h a w k s .
S i l v e r - h a i r e d b a t s , L e w i s w o o d p e c k e r , y e l l o w w a r b l e r a n d w i l l o w f l y c a t c h e r a r e l i s t e d a s
M ( M o d e r a t e p o t e n t i a l f o r O c c u r r e n c e o n t h e s i t e )
G i v e n t h e m o d e r a t e l i k e l i h o o d o f s i l v e r - h a i r e d b a t s , L e w i s w o o d p e c k e r , y e l l o w w a r b l e r
a n d w i l l o w f l y c a t c h e r a n d t h e u n d e r r e p r e s e n t e d p o s s i b i l i t y o f b a l d e a g l e s a n d g o s h a w k s
o n t h e s i t e , t h e R D E I R r e c o g n i z e s t h a t I m p l e m e n t a t i o n o f t h e p r o j e c t w o u l d r e s u l t i n t h e
r e m o v a l o f ~ 2 8 a c r e s o f J e f f e r e y p i n e c o m m u n i t y , ~ 7 . 2 5 a c r e s s a g e b r u s h , ~ 2 6 s n a g s .
T h e s e c o m m u n i t i e s p r o v i d e p o t e n t i a l h a b i t a t f o r S i e r r a N e v a d a r e d f o x , L e w i s
w o o d p e c k e r , g o s h a w k , w i l l o w f l y c a t c h e r , a n d y e l l o w w a r b l e r , a n d r e m o v a l o f t h i s h a b i t a t
c o u l d i m p a c t t h e s e s p e c i e s i f t h e y a r e p r e s e n t o n t h e p r o j e c t s i t e d u r i n g c o n s t r u c t i o n [ 1 .
P r o j e c t I m p a c t s , 4 . 4 - 3 7 ] R e m o v a l o f t h e h a b i t a t i s p e r m a n e n t , a n d a f f e c t s t h e s e s p e c i e s
p e r m a n e n t l y . A n a d d i t i o n a l ~ 7 7 a c r e s & w o u l d o c c u r w i t h i n t h e r e s i d e n t i a l a n d
r e c r e a t i o n l o t s & . A n d c o u l d r e s u l t i n t h i s h a b i t a t b e c o m i n g l e s s s u i t a b l e f o r t h e s e
s p e c i e s . T h e e n t i r e p r o j e c t s i t e w i l l b e s u b j e c t t o i n c r e a s e d h u m a n a n d p e t p r e s e n c e ,
m a k i n g i t l e s s s u i t a b l e f o r t h e s e s p e c i e s , p e r m a n e n t l y .
Additionally, the RDEIR states “The proposed project would have a significant impact
with regard to biological resources if it would: have a substantial adverse effect, either
directly or through habitat modifications, on any species identified as a candidate,
sensitive or special status species…” [4.4-35] or “interfere substantially with the
movement of any native resident or migratory fish or wildlife species or with established
native resident or migratory wildlife corridors or impede the use of native wildlife
nursery [including nesting] sites” [4.4-36]
It is established that the project site represents a desirable and potential habitat for a
diversity of species, including but not limited to Sierra Nevada red fox, silver-haired bats,
bald eagle, Lewis’ woodpecker, goshawk, willow flycatcher, and yellow warbler.
Responsible and realistic mitigation measures are therefore required by the RDEIR.
iii) Inadequate mitigation measures
4.4-50 BIO-1. “Potential impacts to (Sierra Nevada red fox) individuals or denning
habitat would be significant”.
In the case of Sierra Nevada red fox, mitigation (BIO-1) consists of obtain a “take”
permit which could potentially terminate a breeding fox pair and their litter. To consider
this strategy “less than significant” is incredible.
4.4-53 BIO-4. Any trees that cannot be excluded as bat roots shall be surveyed by a
qualified biologist to determine if bats are present…[or]an emergency survey shall be
conducted to determine if roosting bats are present.”
No actual mitigation proposed here. What if bats are found to be present in these surveys?
(Does the biologist have authority to stop construction?) “Significance after mitigation
[which is not provided] – less than significant
“Impacts to northern goshawk… could include loss of foraging and migration habitat.
Due to the vast area of Jefferey pine and sagebrush communities in the region compared
to the amount of these communities that would be removed or degraded on the project
site, the loss of habitat for (this) species would be less than significant”. Assessment
incorrect, there is a large potential for nesting habitat due to being a large undeveloped
tract of land with north-facing slopes and proximity to water.
- b. (riparian habitat 4.4-41) the proposed project sets building envelopes within the 100-
foot setback from 100 year floodplain of the Buck Spring wet meadow (the largest on the
project site), against the recommendation of CDFW
b. (riparian habitat 4.4-38-41) and reiterated in c. (wetlands – 4.4-41&42)
“Implementation of the proposed project would not directly impact the wet meadow
community or the riverine emergent wetlands on the project site…. Therefore impacts to
these species would be less than significant” – while the proposed project does not intend
to build directly in these jurisdictional waters, the project encompasses the northern
drainage for the entire length of the property, and borders the Buck Spring meadow on
one side for almost that meadow’s entire length. No runoff or stormwater management
plan is provided to show how the proposed development and impervious surfaces will
most certainly directly impact these jurisdictional waters. Impact to these waters and
wetlands come from more than just building on top of them, so “less than significant”
impact is impossible to determine with the information in the RDEIR.
- “Accordingly, the project would minimize the effects to upland surface hydrology
supporting the wet meadow community by limiting areas of impervious surface and
associated runoff which can result in erosion, sedimentation, and increased pollutants.”
No information is provided on a) how impervious surfaces will be limited, or b) what will
be done to mitigate effect of runoff that does occur.
- “The proposed project would result in minor indirect impacts to the wet meadows
through modification of surface hydrology…due to the introduction of impervious
surfaces; however, as a result of the project design features described above, this impact
would be less than significant” What design features described? (setbacks? Minimize
impervious surfaces? not building in the floodplain? No address of the effects of building
185 structures adjacent to jurisdictional waters, avoidance of mitigation measures by
incorrectly assessing impacts as “less than significant”
Mule deer – “the following disturbances would result in a potentially significant impact:
temporary disturbance in the form of noise, dust etc during project construction”
(estimates of 20 years duration for construction are not temporary by anyone’s
definition), “conditions in these plans will minimize impacts to wildlife from dust during
construction. Accordingly, the prolonged construction impacts to wildlife movement and
migration would be less than significant and no mitigation required.” Because there is a
dust plan? Please provide mitigation for the impacts of noise, heavy equipment, and
other construction disturbances.
- “the proposed project would implement Rural Suburban clustered development
consistent with Town of Truckee 2025 General Plan land Use Policy P7.3 to minimize
loss of natural habitat.” The project does not follow the Rural Suburban clustered
development requirements (see below, e.)
- 4.4-47 “…impacts {to Loyalton mule deer herd] from long-term disturbances associated
with permanent residents on the project site are considered significant” Mitigation
measures in BIO-5 are inadequate for this significant impact (see next).
4.4-53. BIO-5. Brochures (BIO-5a) are an inadequate mitigation to prevent long-term
human disturbance of local mule deer.
- Split-rail fencing (BIO-5b and 5d) will not prohibit the movement of dogs into the
southeast corner of the project site
- BIO-5e and 5f “no fencing of sufficient height or construction that would impede
wildlife movement shall be permitted to be installed” and “Canyon Spring HOA shall
require confinement fencing for those residents with domestic pets…[up to] 6 feet in
height”. This is contradictory.
“Significance (of long term human presence on mule deer) after mitigation (brochures,
fences, signage) less than significant” but this does not mitigate 20 years of construction
disturbance and the presence of 185 units in the midst of a migration corridor of a
threatened mule deer herd.
e. conflict with biological resources policy [4.4-48]
“Housing lots are designed to meet the Rural Suburban cluster requirements (i.e.
groupings of 10-30 dwellings separated by connected open space areas or greenways on
Residential land use designation peripheral to Town core, but generally not on sites
within the rural fringe).” According to Figures 4.4-3 and 4.4-4, there are 53 units in the
central cluster on the north portion of the site, and 103 units in the southern cluster.
Please clarify how this meets the Rural Suburban cluster requirements (i.e.
groupings of 10-30 dwellings separated by connected open space areas or
greenways…)”.
Thank you for seriously considering the many concerns of the citizens of Truckee
regarding the proposed Canyon Springs development. Please contact me with any
questions you may have about my comments and questions over the adequacy of the
RDEIR. I look forward to a thorough and considered reply to my concerns.
Sincerely,
Lisa Atwell Holan, MSc Ecology
10419 Eastbourne Ct, Truckee
412-2307
lisa@spiralmonkey.com
March 5, 2013
To: Denyelle Nishimori, Senior Planner
10183 Truckee Airport Rd.
Truckee, CA 96161
dnishimori@townoftruckee.com
Re: Comments for Canyon Springs DEIR
Dear Denyelle Nishimori,
As a 13-year resident of Truckee and a professional biologist, I have grave concerns
about the DEIR for the proposed Canyon Springs housing development.
There is the clear and direct conflict with the Town of Truckee 2025 General Plan for
development to be concentrated in the core and not in the “rural fringe”. Please explain
how the proposed development does not constitute “rural sprawl” when 200+ units
are to be located within the “rural fringe”.
The following are some of the goals from the 2025 General Plan that are not aligned with
the large Canyon Springs development proposed at the easternmost fringe of the Town:
COS-P1.5 “…Preserve open space that, to the greatest extent possible, occurs in large
blocks and is contiguous and connected... Provide maximum benefit in terms of habitat
preservation. Enhance the overall character of Truckee as a scenic, mountain
community.”
COS-1 “Preserve existing open space in Truckee, and increase the amount of desired
types of open space under permanent protection”
In addition to the proposed development’s conflicts with the General Plan, I have serious
concerns about the methods and sufficiency of the DEIR biological survey and about the
DEIR’s conclusions regarding the Verdi mule deer subunit.
Biological survey insufficiencies
As documented below, the biological site surveys were not sufficient because they 1)
were conducted in a single, atypical year; 2) were biased against winter-occurring species
and nocturnal species; 3) made use of flawed survey methods.
Single, atypical year survey:
The year the focused plant survey was conducted (2011) was an unusually wet spring
following a high-snow winter. Plants specifically are sensitive to hydrologic conditions
and their presence and abundance can vary greatly from year to year. A single-year
survey conducted in an atypical year is likely not representative of the typical flora of the
area. Surveys conducted in alternate years will likely produce different observations.
Because of the inter-annual variation of environmental conditions and the biota that
respond to these conditions, single-year surveys are not accurate enough or
comprehensive enough to be acceptable in even basic scientific studies. For example, the
designation of “U” (“Unexpected”, Table 4.4-2) for the California rare and endangered
species Ivesia sericoleuca (which prefers drier “mesic” conditions; Table 4.4-2) is not
sound given the focused survey was conducted in a “wet” year. This species has the
potential to occur on the site, and in fact have been observed adjacent to the site, so a
single season of survey data are not sufficient. The supplemental literature reviews of the
general area (Foothill Assoc., Inc., 2004; Eco-Analysts, 1990*) do not provide sufficient
resolution for this specific site. Please provide site-specific survey data from typical as
well as atypical (2011) survey years.
*Eco-Analysts, 1990 – there is no full reference given for this source.
No survey of winter-occurring species or nocturnal species
As stated on page 4.4-9 (“b. Field Surveys”): “Current field surveys were conducted in
the spring and summer of 2011 by Foothill Associates on April 5, by HEC from May 3 to
July 6, and by LSA June 8, June 30, and July 11. HEC also conducted surveys in 2010 on
August 30, September 1-2, and between October 13 and December 16.”
First, no information is provided for the number of surveys conducted “from May 3 to
July 6” or “between October 13 and December 16”. How many surveys were conducted
between these dates? One? Five? Weekly? Monthly? Please provide more detailed
information on the number and dates of site surveys so that survey findings can be
adequately assessed.
Second, no surveys were conducted between Dec 16 and April 5 (most of the winter
month with snow occurring). Many species of birds and mammals change location and
alter foraging behavior in winter. These animals do not respond to the human calendar
but to environmental cues like snow accumulation. Deer, for example, often change
location in response to snow depth and often not until late December even in locations
with severe winter conditions (Nelson, 1995. Canadian Journal of Zoology, 73(6): 1069-
1076). Since Truckee often does not have significant snow accumulation until December
or later, the winter use of the proposed development site by animals has not been
captured by these surveys. Please provide adequate biological survey coverage for the
winter months.
Third, as stated on page 4.4-29 “…lack of records (of bats) is likely due to a lack of
survey effort... No bats… were observed during site surveys, but due to the presence of
suitable roosting and foraging habitat, there is a moderate potential for bats to occur on
the project site.”
There appears to be no site-specific data regarding use of the site by bats and other
nocturnal species. Were night surveys conducted? How is use of the site by bats and
other nocturnal species determined?
Why is the potential for bats to occur only moderate if both suitable roosting habitat and
foraging habitat is present? It appears that designations for species occurrence on the
proposed development site are biased favorably toward the developer. Please explain the
criteria for species potential occurrence to be low, moderate or high. Please explain
why there is only moderate potential for the silver-haired bat to occur on at this
suitable site.
Please provide adequate biological survey coverage for nocturnal species.
Flawed survey methods
As stated on page 4.4-9 (“b.i. General Biology and Focused Plant Surveys”): “The June
8, 2011 survey was conducted by walking meandering transects through the project site
and documenting site conditions…” “The surveys [on June 30 and July 11, 2011 for
Ivesia sericoleuca] were conducted by walking meandering transects through suitable
habitats…”
Meandering transects have been shown to provide biased estimates of biological
densities, and are not an accurate survey tool when used alone (i.e. without corroborative
analytical survey methods; Boafo et al., 2009. Pachyderm no. 45). Please provide
corroborative observations for the meandering transect survey data for the June
2008 general survey, and the June 30 and July 11 focused plant survey.
In summary, the DEIR biological survey fails to:
- address inter-annual variability;
- cover all seasons;
- cover nocturnal species;
- use accurate survey methods.
Illogical conclusions regarding Verdi mule deer subunit
Lastly, the conclusions and recommendations of the DEIR regarding the Verdi mule deer
herd are inherently flawed, illogical and completely unsupported. The DEIR first
enumerates the importance of the project site to the Verdi mule deer subunit as well as
the site’s prominent location within the deer migration corridor:
Page 4.4-27: “Movement and migration corridors are an essential element of home ranges
of a variety of wildlife, including the Verdi subunit of the Loyalton-Truckee mule deer
her. 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.”
Page 4.4-31: “… the CDFG 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.”
Page 4.4-32: “Critical fawning habitat for this heard occurs near Dry Lake, located
approximately 1.5 miles south of the project site…”
Page 4.4-32: “According to the 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.”
Page 4.4-33: “Bitterbrush, found on the project site, is the most important browse (graze)
species, and fawn survival is closely correlated to browse production…As illustrated in
the 2009 and 2001 mule deer reports, there is a high potential for this mule deer herd to
utilize the project site and surrounding area for foraging, movement, and migration.”
The DEIR further states that the mule deer subunit is of concern because it is declining
due to anthropogenic impacts:
Page 4.4-33: “The various causes for the reduction in deer populations are likely from
habitat loss, fires, development, dams, vehicle collisions, and both grazing and
overgrazing by introduced livestock… The protection and enhancement of key mule deer
winter, foraging migratory and fawning habitat are vital to their long-term survival.”
Please explain how the proposed development is not in direct contradiction to the
protection and enhancement of a key mule deer habitat.
The DEIR then, strangely, seems to claim that the development will not substantially
impact the mule deer subunit:
Page 4.4-33: “However, the critical fawning habitat for this deer herd occurs in two
distinct locations approximately 1.5 miles south and approximately 7 miles southwest of
the project site; therefore there is a low potential for fawning habitat for this mule deer
herd on the project site.”
The importance of the proposed development site has never been as a fawning site for
mule deer, which makes this argument irrelevant.
And:
Page 4.4-32: “However, recent data suggest that only a few individuals use the site as a
corridor or for forage at any time.”
The DEIR uses the strange logic that the site may be less important to the declining deer
subunit because there are fewer deer using it. For a population under pressure, remaining
undisturbed habitat becomes, in fact, more important.
This population is declining due to anthropologic pressures. Please explain how
developing this key habitat (thereby exacerbating habitat loss, vehicle collisions and
disturbance, and reducing forage and migration access) does not negatively impact
the long-term survival of the remaining mule deer subunit.
To frame the proposed development as innocuous to the survival and persistence of the
Verdi mule deer subunit is completely contradictory to the Report’s own text which states
that the site is critically important to the deer for forage and migration. The Report also
states that deer are declining due to development and human impacts and protection of
their habitat is vital to their persistence. The Report also states that the entire Canyon
Springs proposed development is within the deer’s major migration corridor and forage
habitat. The Report then vaguely and confusingly claims that only a few individuals make
use of the site, and that it is not a fawning site and therefore mitigation of the proposed
development’s impact on migration or forage is not required.
The DEIR in no way addresses the proposed development’s impact on the Verdi mule
deer population. Designation of unbuilt areas as open space that the deer can use is
completely inadequate when almost the entire site lies within their migration corridor.
Pregnant females in particular – critically important to the persistence of the population –
are most sensitive to disturbance and development. The fawning site at Dry Lake is less
than 2 miles away, meaning pregnant females and young deer are very likely to use the
proposed development site to forage. Additionally, they must migrate through the
proposed development site in spring (pregnant females) and in fall (young of the year). It
has been shown that “[mule] deer avoided human developments in all seasons...
Migratory females were farther from human disturbance … than nonmigratory
conspecifics.” (Nicholson et al., 1997. Journal of Mammology, 78(2): 483-504).
According to Figures 4.4-3 and 4.4-4, there appears to be no access from the north to the
fawning sites south (Dry Lake) and southwest (Lookout Mountain) of the proposed
development site without crossing both roads and high-density residential property.
As stated on page 4-4.46, “…it is well documented that the Verdi subunit…utilize the
project site and surrounding area for foraging, movement, migration and that critical
fawning habitat occurs approximately 1.5 miles south… Furthermore, there is no direct
evidence that the deer use the site for critical winter habitat or that known major
migratory routes (i.e. migration in substantial numbers) for this mule deer herd… exist
within the project site.” The second sentence appears to contradict the first – and indeed
the rest of the Report – regarding the importance of the site to mule deer. Additionally,
the reason the mule deer subunit no longer uses the migration corridor in substantial
numbers is because they no longer exist in substantial numbers. Is this an argument to
discount their importance because there are few left? Because “According to the CDFG,
impacts resulting from residential development and recreational use are currently the
biggest concern for the future of this deer herd.” (pg 4.4-47).
The Report describes “Temporary [wildlife] disturbance during project construction”,
however “buildout of future homes is anticipated to take 20 or more years”, which is not
temporary by any definition. The Report claims “there would be adequate undisturbed
areas for wildlife throughout the 20-year buildout period” (please define and support
what is “adequate” undisturbed area) “therefore the prolonged construction impacts to
wildlife would be less than significant and no mitigation measures are required.”
Please explain how 20 or more years of ongoing construction within critical
migration and forage habitat would be “less than significant” to the mule deer
subunit. The claim that no mitigation should be required seems an egregious
contradiction to the many statements made within the Report itself about the importance
of the site to mule deer.
Last, the Report uses no studies, no references, no evidence, nor gives any explanation of
the adequacy of the proposed 50-foot setback (pg. 4.4-48) from wildlife corridors. How
does the floodplain relate to the wildlife corridor – does it contain the corridor, or is it
contain by the corridor? Why 50 feet? It sounds like an arbitrary round number that has
no real bearing on wildlife impacts. Where is evidence that this is sufficient to reduce
impact on wildlife using the corridor? Please explain and support the choice of 50 feet
from the floodplain as an adequate setback to prevent disturbance of wildlife using
the corridor.
The following are goals regarding habitat use and protection from the 2025 General Plan
that are at odds with the proposed Canyon Springs development:
LU-P7.2 from the General Plan states: “Residential development shall be clustered to
avoid areas of significant natural resources, including wildlife habitat and migration
corridors”
COS-4 “Protect areas of significant wildlife habitat and sensitive biological resources.”
COS-P4.1 “Provide for the integrity and continuity of biological resources, open space,
habitat, and wildlife movement corridors and support the permanent protection and
restoration of these areas, particularly those identified as sensitive resources.”
COS-P4.2 “Protect sensitive wildlife habitat from destruction and intrusion by
incompatible land use… [and] should consider: Prevention of habitat fragmentation and
loss of connectivity
COS-5 “Maintain biodiversity among plants and animal species in the Town of Truckee
and surrounding area, with special consideration of species identified as sensitive, rare,
declining, unique, or representing valuable biological resources.”
COS-P9.1 “Provide for links between open space areas, both with Truckee and beyond
the Town limits, to create contiguous habitat areas…”
Thank you for seriously considering the many concerns of the citizens of Truckee
regarding the proposed Canyon Springs development. Please contact me with any
questions you may have about my comments and questions over the adequacy of the
DEIR. I look forward to a thorough and considered reply to my concerns.
Sincerely,
Lisa Atwell Holan, MSc Ecology
12089 Highland Ave, Truckee
412-2307
lisa@spiralmonkey.com
Lisa Atwell Holan
10419 Eastbourne Ct
Truckee CA 96161
phone 530¬412¬2307
e «mail lisa@spiralmonkey.com
objective
I wish to apply myself to challenging and varied work in the field of ecology. My
specific interests lie in the application of stable-isotope analysis to a variety of
ecological questions. Additionally, I have a strong background in biostatistics and
wish to collaborate with researchers from diverse fields on experimental design
and data analysis. I also enjoy both formal and informal science writing, teaching,
and ‘translating’ hard science for a general audience.
special interests
stable-isotope applications to ecology ¬ experimental design and biostatistical
analysis ¬ evolutionary biology ¬ aquatic ecology ¬ writing (formal and
creative) ¬ teaching ¬
education
Master of Science, Biology. University of Saskatchewan, SK, Canada. 2000.
Thesis: Stable carbon and hydrogen isotopes in breeding redhead ducks and
duck eggs.
Honours Bachelor of Science, Biology. University of Waterloo, ON, Canada.
1996. Senior honours thesis: The occurrence of beaver in the summer diet of
wolves, Algonquin Provincial Park.
academic experience
RESEARCH ASSOCIATE, University of Nevada, Reno, Limnology Laboratory (2006 to
present)
• Perform data analysis and bioenergetics modeling for various projects under
the lab umbrella
• Edit and write materials for publication and grant proposals; write peer-review
critiques of manuscripts
• Consult with graduate students regarding experimental design, data analyses
and interpretation of statistical results, as well as oral and poster presentations
• Assist with field work as needed, collecting fish and/or invertebrate samples
from lakes and streams
DATA ANALYST, Sierra Internal Medicine, Incline Village, NV (2003 to 2007)
• create and manage a database of patient results and information for a
physician specializing in Chronic Fatigue Syndrome and Human Herpes Virus
6 (HHV6)
• examine database for various trends, patterns and comparisons
• read extensively on virology, immunology, clinical research, Chronic Fatigue
Syndrome, HHV6 to become proficient in this new field for me
STABLE ISOTOPE LAB TECHNICIAN & RESEARCH ASSISTANT, National Hydrology
Research Institute Stable-Isotope Laboratory, SK, Canada (1997 – 2000)
• manual preparation of biological samples using vacuum line to separate gases
for deuterium, carbon and nitrogen isotopic measurement
• statistically analyzed data
• prepared figures and preliminary text drafts for publication
• critiqued manuscripts sent to our lab for peer review and edited manuscripts of
senior scientists
• assisted in the organization and realization of the 1st International Conference
on the Applications of Stable-Isotope Techniques to Ecological Studies
SYMPOSIUM ORGANIZER, 1st International Conference on the Applications of Stable-
Isotope Techniques to Ecological Studies, Saskatoon, SK (1998).
• assisted in planning and organizing presentations, posters, abstracts &
proceedings book, registration and logistics for over 200 participants
FIELD RESEARCH ASSISTANT, Atlantic-salmon food-web study using isotopes of
carbon and nitrogen. University of Waterloo, ON, Canada (1995).
• gathered juvenile Atlantic salmon, aquatic insects and other organic and
inorganic stream material from streams in New Brunswick (Canada), France
Scotland, and Norway
• identified insects to level of Family
• prepared all samples for mass-spectrometer analysis
FIELD RESEARCH ASSISTANT, Investigation of the diet and territories of wolf packs in
Algonquin Provincial Park. University of Waterloo, ON, Canada (1994)
• trapped, radio-collared, and sampled blood from an isolated population of
wolves in Ontario, Canada
• located wolves from ground and air using radio-telemetry, ground tracking,
and howling searches
• collected samples for my senior honors thesis (analyzing prey-hair found in
scat)
LABORATORY RESEARCH ASSISTANT, Effects of nerve-growth factor (NGF) and anti-
NGF on neurons of the central- and peripheral nervous system. McMaster
University, Neurology Division, ON, Canada (1991-1993)
• assisted senior researchers in many aspects of their research: experimental
design, histological and chemical preparation, small-animal surgery,
behavioural testing, bioassay procedures, microscopy, photography and dark
room developing/printing, data analysis, preparation of figures, write-up
• designed, conducted and reported my own experiments under the direction of
a senior researcher
teaching experience
LECTURER, Sierra Nevada College, Incline Village, NV
Biostatistics & Experimental Design, senior level, (2002, 2003 & 2005)
Conservation Biology, senior level, (2002)
Introduction to Statistics, (2003)
• designed curricula, researched current literature for relevant topics and new
findings, prepared and presented 4 lectures weekly, created and marked tests
and assignments for senior student (many of whom were continuing on to
graduate school)
TEACHING ASSISTANT
Population Ecology (senior level, University of Waterloo, 1995 & 1996)
Statistics & Experimental Design (senior level, University of Waterloo, 1996)
Advanced Vertebrate Zoology (senior level, University of Waterloo, 1995)
Introduction to Biology (University of Saskatchewan, 1997-1999)
Introduction to Ecology (University of Waterloo, 1993)
publications
Ginatullina E, Atwell L, Saito L. (submitted). Resilience and resistance of
zooplankton communities to drought-induced salinity in freshwater and saline
lakes. Freshwater Biology.
Crootof A, Mullabaev N, Saito L, Atwell L, Rosen M, Bekchonova M,
Ginatullina E, Scott J, Chandra S, Nishonov B, Lamers J, Fayzieva D. (submitted)
Hydroecological condition and potential for aquaculture in lakes of the arid
region of Khorezm, Uzbekistan. Journal of Arid Environments.
Kolosovich AS, Chandra S, Saito L, Davis CJ, and Atwell L. 2012. Short-term
survival and potential grazing effects of the New Zealand mudsnail in an
uninvaded Western Great Basin watershed. Aquatic Invasions 7(2): 203-209.
Saito L, Redd C, Chandra S, Atwell L, Fritsen CH, and Rosen MR. 2007.
Quantifying foodweb interactions with simultaneous linear equations: stable
isotope models of the Truckee River, USA. Journal of the North American
Benthological Society 26(4): 642-662.
Peterson D and Atwell L. 2006. HHV-6 in Chronic Fatigue Syndrome in Human
Herpesvirus-6: General Virology, Epidemiology and Clinical Pathology,
Perspectives in Medical Virology, Krueger G and Ablashi D [eds]. Elsevier. Pp
255-267.
Hobson KA, Atwell L, Wassenaar L, and Yerkes T. 2004. Estimating endogenous
nutrient allocations to reproduction in Redhead Ducks: a dual isotope approach
using dD and d13C measurements of female and egg tissue. Functional Ecology
18: 737-745.
Hobson KA, Atwell L, and Wassenaar LI. 1999. Influence of drinking
water and diet on the stable-hydrogen isotope ratios of animal tissues.
Proceedings of the National Academy of Science 96: 8003-8006.
Atwell L, Hobson KA and Welch HE. 1998. Biomagnification
and bioaccumulation of mercury in an arctic food web: insights from
stable-isotope analysis. Canadian Journal of Fisheries and Aquatic
Science 55: 1114-1121.
conference presentations ¬ oral
Using dD and d13C as markers of endogenous nutrients in migrating waterfowl:
implications for determining nutrient allocations in eggs. 1st International
Conference on the Applications of Stable-Isotope Techniques to Ecological
Studies, Saskatoon, SK, 1998
conference presentations ¬ poster
Influence of drinking water and diet-tissue fragmentation on dD values of avian
tissue. 1st International Conference on the Applications of Stable-Isotope
Techniques to Ecological Studies, Saskatoon, SK, 1998
Using stable isotopes of deuterium and carbon as markers of endogenous
nutrients in migrating waterfowl. Comparative Nutrition Society Symposium,
Banff, AB, 1998.
awards
Graduate student full scholarship; University of Saskatchewan, 1997-1999
inclusive.
Best graduate student poster at the Comparative Nutrition Society Symposium,
Banff, AB, 1998. Using stable isotopes of deuterium and carbon as markers of
endogenous nutrients in migrating waterfowl.
other experience
AQUATIC ECOLOGY VOLUNTEER INSTRUCTOR, Brightwater Outdoor Education
Centre, Saskatoon, SK (1997-2000)
OUTDOOR EDUCATOR, Tawingo Outdoor Centre, Huntsville, ON (1992)
ROCK-CLIMBING GUIDE, Mountain Adventure Seminars, Bear Valley CA (1999 –
present)
YOGA TEACHER, Yogic Arts Center (Tahoe City, CA) and Tahoe-Donner Parks
and Recreation (Truckee, CA) (2001 – present)
SUSHI CHEF, Yama Sushi, Tahoe City, CA (2001)
personal interests
Travel (Asia, Europe, North America) ¬ Telemark skiing ¬ Skate skiing ¬
Cooking ¬ Reading ¬ Mountain biking ¬ Drawing & Painting ¬ Yoga ¬
Swimming ¬ Creative writing ¬ Knitting ¬ Rock- and ice climbing ¬
references
Dr Keith Hobson (graduate supervisor), Canadian Wildlife Service, Saskatoon, SK
ph. 306 ¬ 975 ¬ 6102
e¬mail Keith.Hobson@ec.gc.ca
Dr Daniel Peterson (previous employer), Sierra Internal Medicine, Incline Village, NV
ph. 775 • 832 • 0989
e • mail dan@ishere.com
Dr Sudeep Chandra (Limnology Lab supervisor), University of Nevada, Reno, NV
ph. 775 • 784 • 6221
e • mail sudeep@cabnr.unr.edu
Dr Laurel Saito (colleague), University of Nevada, Reno, NV
ph. 775 • 784 • 1921
e • mail lsaito@cabnr.unr.edu