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HomeMy Public PortalAboutPublic Comment #048 (Riley)1 November 19, 2014 Denyelle Nishimori, Senior Planner Truckee Community Development Department 10183 Truckee Airport Road Truckee CA 96161 Re: Canyon Springs RDEIR Comments Dear Denyelle: Please see my responses to the Canyon Springs’ Revised Draft Environmental Impact Report (RDEIR) below. If you have any questions feel free to contact me at any time. In my letter dated, March 5, 2013, I responded critically to the level and quality of analysis provided by the DEIR consultant (D, C & E; aka Placeworks) and the subsequent mitigation measures proposed to deal with the numerous and detrimental impacts this project would create if allowed to move forward as proposed. Unfortunately the RDEIR failed to address the many issues brought forth by myself and many other concerned citizens in response to the DEIR, despite many requests for a complete overhaul of the document, including analysis of current traffic patterns and revised, up to date studies done during appropriate seasons and times of the year. The decision to focus solely on the Biology, Traffic and Alternatives Sections of the DEIR demonstrates a disconnect with the overwhelming number of issues raised regarding the inadequacy of the DEIR and an unwillingness to fully analyze the comments and provide a meaningful and environmentally sound review of this project and its impacts. This is a continuation of a flawed process and should be noted as such. I believe that the entire DEIR must be revised and redistributed in order to provide timely data that assesses the project in its correct location, current state and verifiable environmental impacts. Anything less is negligent and fails to assure the public that this project as proposed will not cause irreversible damage due to a lack of proper impact mitigation. INTRODUCTION It is unclear whether or not the Introduction to the RDEIR is taking the place of the original Introduction in the DEIR. As such, I am including the comments made that pertain to the Introduction as well as new comments that pertain to the RDEIR document. As a Planning Commissioner for the Town of Truckee during the entire 2025 General Plan Update, I participated in hundreds of hours of community workshops, public hearings and deliberations regarding the drafting and ultimately the final outcome of the Vision Statement, Guiding Principles, Policies and Action Items of the 2025 General Plan. 2 During the 2025 General Plan Update process, the community was unable to discuss the property currently known as Canyon Springs as there was an open application in the hands of the Town. In addition to this, the property referred to as PRD 2 or Planned Residential Development 2, located directly adjacent to the Canyon Springs Project Site, was off the table as it is located in unincorporated Nevada County and discussion of this property would require full involvement of the Nevada County Planning Staff and Board of Supervisors, despite being part of Truckee’s Sphere of Influence. Thus, the Vision, Guiding Principles, Policies and Action Items created and certified under the 2025 General Plan did not take into account these properties and were not discussed at a community level. In fact the last time these properties were up for a public discussion was at the time of the original Truckee General Plan in 1995. I believe there are direct conflicts with this project as proposed with respect to the 2025 General Plan. Specifically with regards to land use planning, density, green house gas emissions, hydrology, biology, safety and traffic/circulation. Overlay Area 6 was created during the 2025 General Plan Update to require development in this region to create a Planned Development that coordinated with adjoining neighborhoods, but it lacks clarity and specificity and was not discussed with respect to how its zoning designation was at odds with many of the guiding principles laid out in the 2025 GP Update. • Please explain how policies created during the 2025 GP Update without consideration for this property can be applied to this project. Specifically the desire to apply a minimum building density of 50% discussed in relation to development in the town core can be applied to a development proposed on the rural fringe, ie. the easternmost boundary of the Town of Truckee. • Does this Introduction dismiss the original Introduction of the DEIR? Or is this solely an introduction for the newly released and revised DEIR chapters? Please clarify as this was not effectively described. The original DEIR misidentified the project location as being 1.6 miles from the Town core. The project site is more than 7 miles from the Town core. I did a Google map search for the distance from Cabona’s Store on Commercial Row in Historic Downtown Truckee to the intersection of Glenshire Drive and Martis Peak Road and it came up with 7 miles. Incidentally it should be noted that the travel time from downtown Truckee to this location via Glenshire Drive is 12 minutes while the time to travel via Interstate 80 and Hirshdale Road is 13 minutes according to Google Maps, thus indicating a predilection for drivers to take Glenshire Drive instead of Hirshdale to and from Town. • The Project Location error must be changed and noted as many guiding principles from the General Plan are related to proximity to the Town core as well as development at the Rural Fringe. It is inappropriate to apply Goals and Policies related to the Town Core to locations at the Eastern Edge of Town. 3 • In the RDEIR section numbered 2 in the Environmental Review the document states that a “Neighborhood Meeting” was held on December 18, 2012 to discuss the DEIR process. This is a misnomer and should be represented as such. If it were a neighborhood meeting it would have been held in the Glenshire neighborhood, where most impacted residents live and not at a location quite far from the project site and during a winter storm, making attendance difficult. It should be noted that the Site Proposal History in the Report Summary Section does not accurately describe the project that the Nevada County Board of Supervisors approved in 1990. An 87 lot subdivision was approved, not the 285 lot subdivision the applicant had applied for and was denied. No project as proposed has yet to be approved at this location. Nor does it mention that the original zoning of this property had been changed in 1987 by the land owner from a Rural Forest Designation allowing up to 77 home sites to a Res 1 designation allowing 1 unit per acre. Under Project Characteristics, the Housing Lots description is at odds with the Truckee General Plan and its Inclusionary Housing Policy. The developer is required to provide at least 15% inclusionary housing which would result in a dedication of 25 home sites to be offered at an affordable price to local homebuyers or an equivalent offering yet to be determined. • Please explain how the developer can avoid fulfillment of the Inclusionary Housing Policy. • Please describe and locate the Recreational Amenities offered by this project yet never detailed on any maps or documents. • The Revised DEIR Introduction needs to provide detailed information related to what prompted the revised Traffic Studies. There is not accompanying data to explain why this took place, nor is it clear whether or not the traffic analysis was redone or simply had old data run through a new model. As much of the infrastructure must come from off-site locations, a descriptive map must be provided to indicate the locations of impact and to give a realistic layout of the required infrastructure needs. • Please provide an accurate layout of the proposed, off-site infrastructure requirements. It should be noted that the Homeowners’ Association will be responsible for snow removal, road maintenance and drainage maintenance, to name a few areas of accountability. As we have seen and experienced with past developments that have not yet reached revenue neutrality, the true areas of responsibility are vague and undefined. Elkhorn Ridge, located directly to the West of the proposed project has been the cause of destructive run off damage to surrounding neighbors. Unfortunately due to their financial situation no one is taking responsibility for the damage caused by poor drainage design. 4 • If the Canyon Springs’ HOA runs into financial despair, who will manage any potential impacts to the surrounding neighbors and the environment? TRANSPORTATION/TRAFFIC/CIRCULATION I have listed below some of the guiding principles for the General Plan’s Circulation Element. I believe the Canyon Springs project as proposed is in direct conflict with these principles and I have requested clarification on a number of issues. CIRCULATION ELEMENT GUIDING PRINCIPLES: 1. GUIDING PRINCIPLE: Maintain acceptable traffic operations on the Town's roads through application of Level of Service thresholds, and by conditioning new development on the ability of local roads and intersections to accommodate projected traffic impacts. Canyon Springs will be required to enact numerous costly and environmentally disturbing and damaging infrastructure changes to accommodate their proposed impacts to existing roads, specifically the addition of a third vehicle lane in multiple areas to accommodate safe turning actions. • Please explain how these requirements are not in contrast with the above stated guiding principle. The Traffic Analysis for this project is neither current nor relevant. Many of the data points were taken as long ago as 2004 with others completed in 2010 or early 2011 and the level of development in and around the project location has increased dramatically. The time, money and effort spent to create a new Traffic review for the RDEIR should have included revised data from 2014. This is negligent and does not provide an accurate assessment of current traffic numbers. • Please revise the Traffic Analysis to reflect the most current, on the ground vehicular movement in and around the project location. Including all previously studied locations as well as Edinburgh, Regency Circle, and Courtney Drive. There are no traffic counts for Edinburgh, Regency Circle or Courtenay Drive despite an assessment by LSC that these roadways were analyzed. Nor have the impacts from Elkhorn Ridge development been taken into account. • Please describe in detail what analysis was completed by LSC on the roads stated above. This is a network of small, tight knit roadways that differs greatly from that of Glenshire Drive. The impacts to Somerset Drive and Courtenay have not been adequately assessed. This intersection is used by Juniper Hill residents as well as Glenshire residents and is a main access point for parents driving their children to school from August to June. Most parents will avoid 5 the Somerset/Glenshire drive intersection when driving their children to school, preferring to use Courtenay and the back streets to get to Glenshire Elementary. • Please require an assessment and analysis of this specific intersection. 2. GUIDING PRINCIPLE: Minimize the negative impacts of transportation infrastructure upon Truckee’s community character, local neighborhoods, and the environment. The residents in and around Glenshire, including those who live in Olympic Heights and Hirshdale are poised to suffer through 20+ years of construction traffic, noise and pollution if this project moves forward as proposed and that is banking on a strong building environment, which is not the currently the case. • Please explain how Canyon Springs will minimize the negative impacts of transportation infrastructure on our community character, local neighborhoods and environment. • The building of new roads and bridges will require extensive construction equipment to transport and deposit materials. Who monitors the 7 ton load limit on roads to ensure that vehicles that exceed this limit will not travel Glenshire Drive from town or via I-80? 3. GUIDING PRINCIPLE: Ensure that new development minimizes impacts on the roadway network, is integrated into the existing transportation system and provides opportunities for use of alternate modes. Canyon Springs will impact our existing roadway network to unsustainable levels as the traffic analysis has indicated. (Pg 4.14-29 Traffic/Circulation Section DEIR; 2578 One way vehicle trips per day) This development proposes no alternate modes of transportation nor does it propose to create a new roadway infrastructure that would allow citizens to safely travel on bike into town from Glenshire. This project does not propose to complete the Legacy Trail or other modes of transportation to safely transport citizens from the eastern periphery of town into the downtown core. • Please explain how Canyon Springs will minimize its impacts on the roadway network or provide alternate modes of transportation. 4. GUIDING PRINCIPLE: Work cooperatively with adjacent jurisdictions to address regional traffic issues. • Please explain how the town of Truckee, the developer and Nevada County are working together to address the impacts this development will create with increased traffic on Glenshire Drive to Hirshdale and the Interstate 80 interchange. The traffic analysis failed to study the impacts to Interstate 80 (I-80). 5. GUIDING PRINCIPLE: Reduce automobile travel demand to reduce impacts on the Town's roadway system, lessen the need for new or expanded road facilities to accommodate increased demand, and decrease pollutants emissions from automobiles. 6 • Please explain how Canyon Springs will reduce automobile travel impacts to the Town’s roadway system and lessen the need for new or expanded road facilities to accommodate the increased demand and decrease pollutants emissions from the automobiles. • Please describe how the DEIR takes into account the required Downtown Traffic Study as stated on page 2.3 of the Circulation Element of the General Plan. I realize a traffic study was completed for the Railyard Master Plan. This took place many years ago and I do not feel it adequately addresses issues faced today with increased traffic from Pioneer Commerce Center, Pine Forest Housing Development, Spring Creek Housing, Henness Flats Housing, Alder Creek Middle School, Gray’s Crossing, the Catholic Church on Alder Drive, the new Truckee Parks and Recreation building and Frishman Hollow housing all utilizing Donner Pass Road to enter into the Downtown Core. On page 4-29 of the General Plan Circulation Element it states that, “The Glenshire Drive realignment will be a required component in the planning, design and development of the Railyard project. Other projects, outside of the Downtown Specific Plan Area, will contribute to the need for this improvement, and should be required to participate in its funding. The precise alignment, intersection configuration, and classification of this roadway will be determined during planning and development of the Railyard project, and the Downtown Traffic Study. • Please explain how Canyon Springs can be considered at this time without this infrastructure in place and/or how Canyon Springs plans to contribute financially to develop this required infrastructure. The DEIR also makes the assumption that this infrastructure will be in place and bases its traffic analysis on this assumption. The Railyard has made no indication it will be completing this required infrastructure in the near or distant future as they lack the necessary funds to make this a reality. • The existing Traffic Analysis for this project is neither current nor relevant. Please revise the traffic study to accurately assess the existing conditions at Glenshire Drive/Donner Pass Road without the Railyard Bypass. The traffic study says no need to evaluate traffic impacts at intersections outside Glenshire neighborhood during school hours-this is incorrect as Glenshire Drive is accessed by Pine Forest, Spring Creek, Henness Flats, Frishman Hollow, Coachland, Prosser Lakeview and Prosser Heights neighborhood families taking their kids to school and preschools. • Please revise study to include Glenshire Drive and Donner Pass Road during peak school drop off and pick up hours. 7 Despite accessing Martis Peak Road to leave the project site, those drivers taking their children to Glenshire Elementary school will inevitably continue to town on Glenshire drive via Glenshire and not turn around to take I-80. This was not taken into account in the traffic study. • This reality of school year traffic needs to be analyzed and the traffic study must be revised to include on the ground data. • Please revise the current traffic study to account for all intersections that access Olympic Heights from Glenshire Drive. At Build Out this project proposes to add 2578 vehicle trips on our roadways (Pg 4.14-29 Transportation/Traffic Section DEIR. • The Edinburgh location and its surrounding streets must be adequately studied with a traffic analysis if it is to be considered. It has not been studied to date according to the Traffic Analysis Appendices. • Please explain and provide detailed analysis to support the assumption that with the Edinburgh Drive Access Alternative there would be fewer than 1000 cars utilizing this street on a daily basis. The reality is that most, if not all traffic would utilize Glenshire Drive rather than Martis Peak Road to access town and the traffic numbers would be much higher. As half of the proposed development would be closer to Edinburgh Drive, I do not believe that less than one fifth of all car trips would utilize this access, as it is closer to town than Martis Peak Road. • Please explain how there is only an increase of 20 cars using a proposed Edinburgh Access from a 2011 project to a 2031 project levels, ie. supposed build out. The latter phases of Canyon Springs are located in closer proximity to access points at Edinburgh, not Martis Peak road. Please provide accurate and thorough analysis to prove the consultant’s assumption that there would only be an increase of 20 cars over 20 years. • Please conduct a safety study at Glenshire Drive and Somerset Drive. As a mother who takes her sons to the bus and picks them up at this location everyday during the school year I observe no less than 1/5 of all cars running the stop signs on a daily basis. This does not include the majority of drivers who do a roll-through the stop sign at a reduce speed. I called the police department to file a complaint and received no follow-up. I believe this will be exacerbated by the increase of cars that will result from Canyon Springs. There are no safe zones at the various bus stop locations along Glenshire Drive, Dorchester Drive and Manchester Drive to Glenshire Elementary and schools in downtown Truckee. The kids are forced to stand in the roadway as they wait for the bus to arrive. There is no plan or 8 acknowledgement for dealing with the 2600 additional vehicle trips added and how the safety of our children will be impacted. • Please acknowledge and address this issue with proper and adequate mitigation, including the creation of viable and safe locations for kids to wait for the school and to be dropped off afterschool. • Please address the safety issue regarding existing roadways that will be utilized from this development into downtown Truckee, as well as down Glenshire Drive to Hirshdale and Boca Reservoir and beyond. These two main thoroughfares are widely used by cyclists when the roads are clear of snow. As they exist today, these roadways are inadequate to accommodate both cyclists and motorists. It is a danger to cyclists and motorists in that there is not adequate room for a cyclist to safely ride their bike alongside a passing motorist. I did not see this addressed in the DEIR and believe this is an unacceptable omission. Canyon Springs must address the impact they will create with the addition of so many new motorists as well as new cyclists on the road. • What is developer’s plan for trail connectivity with the rest of the region, including the Truckee river legacy trail? The proposed trails on the site do not connect with existing, public trails. • Please describe in detail how the Traffic Analysis has properly followed the Minimum Contents Required for a Traffic Impact Study Report. The LSC Analysis has not adequately addressed all required sections, including a timely review of all impacted roadways. • Construction Traffic has not been adequately assessed. The Glenshire Drive repaving and widening completed this past summer/fall saw an average of 30 workers per day. The assumption of 12 construction workers per day to build Canyon Springs’ roadway, utility infrastructure, 4 bridges, etc would see more than 12 workers. This needs to be reanalyzed. I believe that if the Edinburgh Alternative is allowed it will create an excess of 1000 vehicle trips per day as well as provide many more than a 50% increase of existing vehicle trips per day. Both of these would render this Alternative invalid in the eyes of our General Plan policies regarding new development and traffic impacts which prohibit any developments that will add 1000 or more vehicle trips per day on the roadway OR increase the existing number of vehicle trips by 50%. It is incredible that this policy is being disregarded throughout the RDEIR. • Please address this issue and why it is not being discussed in light of General Plan Policies. 9 BIOLOGY I am greatly concerned regarding the potential loss of habitat on this property as well as the degradation of a sensitive watershed that drains not only to the Glenshire Lake but ultimately to the Truckee River. The impacts of building and construction cause lasting effects and much of the mitigation described in this section with regards to both flora and fauna is weak and insufficient. There is too great of a reliance on voluntary homeowner measures and nothing that requires the developer or homeowners to tread lightly with specific language. • The home sites that encroach on the wetland located in the southern most part of the property must be removed to adequately address their impacts. • Please do not allow for bridge construction to impact existing waterways. Design of bridges must avoid all waterways. • Please provide mitigation that restricts the removal of snags on site. This is a site heavily used by birds of prey. • Please conduct new watershed studies during spring when the wetlands are wet and full of season flora. The landscape changes dramatically from season to season. Assessments done during late summer/early fall demonstrate a negligence and do not account for an accurate picture of the sensitive sites. • Glenshire Lake is a heavily used site for migratory birds. Language must be included in the development to restrict the use of any pesticides or other toxic substances that could eventually travel into Glenshire Lake. • Please provide an assessment of how Canyon Springs will not impact the bi-state waters of the Truckee River and its biological habitat. • Continued disruption of the deer migratory corridor will have irreversible effects. Please do not rely upon voluntary homeowner measures to deal with this. A clearly defined, open space corridor from north to south must be maintained to provide access for this deer herd. Fragmented design and sprawling homes will further disrupt an already impacted deer herd. ALTERNATIVES While I realize that Project Alternatives are a required part of the CEQA process, I understand that they are never truly considered as viable alternatives to the Proposed Project. Despite this assessment, the time spent to include a new alternative as well as utilize the Edinburgh Access point is of great concern. There seems to be a great push to make the Edinburgh Alternative the Preferred Option despite its many red flags and conflicting issues. The Alternatives provided no not take into account the General Plan’s Guiding Policies in a number of areas. Primarily the LU-7 Chart in the Land Use Section of the General Plan explicitly defines a heavily clustered design of homes in excess of 6 groupings as sprawl when located at the Rural Fringe or Town’s Boundary. There is no mention of this policy throughout the DEIR or RDEIR indicating a further disconnect with the Town’s Vision, Goals, Policies and Programs created during the GP 10 2025 Update. This desire to apply policies regarding minimum densities in order to justify a sprawling subdivision on the Eastern Boundary of the Town of Truckee is negligent and reckless. • All of the Project Alternatives must be revised and reassessed to accurately and honestly reflect the policies of the 2025 GP. Edinburgh should not be considered as an access point in any of the Alternatives due to its direct conflict with our traffic and land use policies. • The Environmentally Superior Alternative, the lower density option should not be discounted due to its conflict with minimum density standards. Those minimum density standards were not created with properties located at the Rural Fringe or on the Town’s boundaries. • Please reconsider a Lower Density Alternative that maintains all home sites to the North End of the property, outside of any wetlands or drainage areas and off of any steep slopes. There do not need to be any bridges crossing this property and disrupting the migration corridors and wildlife habitat. The roadway can be designed to accommodate the Fire Department’s requirements without inflicting so much harm on the environment. • An Alternative that considers access at Woodbridge Court is another viable alternative. Please look at this location as a much more viable location for access than Edinburgh or anything that crosses the entire 285 acres. In closing I am hopeful that the public’s concerns will be taken seriously and a complete overhaul of the DEIR will be required. At this point, the DEIR and its “revised” chapters is not a comprehensive, accurate assessment of the project site and the many impacts created if allowed to move forward as proposed. Traffic Studies that use current vehicle trips, mitigation measures that have requirements to keep home sites out of the wetlands and an assurance to the public that we won’t be left cleaning up the damage inflicted by another blighted community in our backyard are the first steps towards demonstrating a true and honest environmental review of the Canyon Springs Project. Thank you for your time. Sincerely, Nikki Riley LEED AP Glenshire Resident Since 2003 Board President Mountain Area Preservation