HomeMy Public PortalAboutPublic Comment #049 (Stoner)11/20/14
To: Denyelle Nishimori, Planning Commission
Town Council, Town of Truckee
From: Linda Stoner, Truckee Resident
Re: Canyon Springs RDEIR comments
I am writing to comment on the recently released RDEIR for Canyon Springs. I know you have
received many very detailed and knowledgeable letters addressing the RDEIR faults, especially
those having to do with biology and traffic. I, therefore, am not going to reiterate those points.
Instead, I am addressing the alternatives to the project as outlined in the RDEIR.
1. Alternative A: no project
Per the RDEIR, CEQA 15126.6(a) states: "An EIR shall describe a range of reasonable
alternatives to the project, or to the location of the project, which would feasibly attain most of
the basic objectives of the project but would avoid or substantially lessen any of the significant
effects of the project."
The RDEIR asserts that there is "unauthorized" use of the land by hikers, bikers, etc in both
winter and summer. When my house was build in 1988, I was told that all the land east of
Glenshire was green belt and could never be developed. Until Elkhorn Ridge was developed, I
was never told differently. I know that others using the land were under the same impression,
and the existing dirt roads were from the Forest Service logging the area years ago. And there
is no evidence presented that the use in any way impacts the land negatively.
The Elkhorn Ridge project, just to the west of the Canyon Springs proposed project, has 8
houses that have been built in the past 10 years, leaving 59 vacant lots. The undeveloped
cul-de-sacs in the project have been used by people who drive up and smoke, drink, etc, leaving
cigarette butts (some stomped out, some thrown out burning), beer cans, vomit, condoms, trash,
and dog poop. In addition, the black plastic which was put up by Elkhorn Ridge to surround the
project has been left to rot, producing black plastic bits everywhere. You do not find such trash
currently on the Canyon Springs land. It is of grave concern that Canyon Springs will produce
an even greater environmental disaster before there is, if ever, an HOA and town involvement
that will prevent it. Therefore, alternative A, no project, is the only reasonable alternative that
will protect the environment.
2. Alternative B: same as project except open access from Edinburgh.
The RDEIR admits that this alternative would produce an increased number of car trips through
Glenshire, as "85% of the people would use Edinburgh, and 15% would use Martis Peak Road"
to enter/exit the project. Edinburgh is a very narrow 2-lane road, and the increase in traffic
would significantly increase the danger to children in the area, bikers, pedestrians with and
without dogs, etc. This is not a viable alternative when it puts people at greater risk and must
be eliminated as an alternative.
In addition, the RDEIR states that there would be "no decrease or elimination of the projects
'less that significant' impacts." Since the RDEIR already admits there are "potential" significant
biological and traffic impacts, that have not been sufficiently mitigated, the RDEIR must address
all impacts before considering that alternative B is a viable option. Currently, as written
alternative B is not a viable alternative.
3. Alternative C: 185 lots, no open space crossing.
This alternative provides gated access between the east and west of the project for emergency
vehicle use only. 64 lots would use the Edinburgh access, and 121 lots would use the Martis
Peak Road access. The RDEIR states that there would be a decreased number of trees on the
north side of the project, but there would be no change in the biological impacts. With less
trees, there would be a significant impact to the wildlife on the north (BIO-1, BIO-2, BIO-4 of the
RDEIR). The traffic that would be funneled through Edinburgh would still produce the dangers
to the residents living on the streets as outlined above.
In addition, BIO-5b, 5c, 5d, and 4.4-33, 4.4-35 of the RDER outlined mitigations to protect the
wildlife and jurisdictional waters on the project by decreasing activity in the southwest corner of
the project by Buck's Spring. Alternative C, with increased traffic through the area, will not
protect the area and must be eliminated as an alternative.
4. Alternative D: medium density cluster of 185 lots.
The RDEIR states this alternative would decrease lot size and development area and increase
open space. All other aspects are like the project. There would be the same number of
people and cars. The RDEIR states that the decreased number of trees and the "wall effect" of
the houses would decrease wildlife movement through the project, but this is "less than
significant." Why? How? All of the poorly mitigated or unmitigated impacts of the RDEIR
would remain. For this reason, alternative D is not a viable alternative.
5. Alternative E: reduced density to 88 lots.
This alternative would decrease the number of lots, but increase the size of each lot. There
would be one house per 1.2 acres, and still 107.59 acres would be designated for housing.
The RDEIR states there would be "less land disturbance" and biological impacts would be "less
than significant." However, the roads, infrastructure, trail would remain like the project and all
of the impacts from that construction remain.
The RDEIR states that there would be decreased traffic but, "because the mitigation measures
that are recommended for the proposed project are required to improve existing deficiencies to
which the addition of any new trips would result in significant impact, the mitigation would also
apply to alternative E." The RDEIR also states that, "overall impacts to transportation and
traffic under this alternative would generally be the (sic) less than those of the proposed project
since fewer trips would be generated." No acknowledgement of the obvious conflicts in the two
statements above is given. It is not enough to say that on one hand there would be a significant
and on the other, less impact. This is unacceptable and makes this alternative nonviable.
Additionally, since the traffic mitigation needed, as above, is necessary for the project, it would
apply to ALL alternatives except A.
6. Alternative F: Open space buffer, 185 lots
This alternative "would result in less development in the southeast cornier of the project site."
Open "public space" would increased by 4.6 acres, however, "grading, tree and vegetation
removal and new development with landscaping improvements would generally occur on the
site in the same manner that would occur under the proposed project." There is no description
of how this open space buffer would occur and it is impossible to ascertain a difference between
the proposed project map and the alternative F map to see where the open space would be
located.
In addition, Buck's Spring is in the southwest corner of the project and is an area the RDEIR
already admits is used by wildlife. There is no protection listed for the southwest and therefore,
alternative F is not a viable alternative.
Environmentally Superior Alternative (RDEIR 5-55):
The RDEIR states that, "section 15126.6 of the State CEQA Guidelines requires that an
'Environmentally Superior' Alternative be selected and the reasons for such a selection
disclosed." "In general, the environmentally superior alternative is the alternative that would be
expected to generate the least amount of significant impacts." "The project under consideration
cannot be identified as the Environmentally Superior Alternative."
The RDEIR identifies Alternate E which reduces the number of lots to 88 but increases the size
of each lot, as the Environmentally Superior Alternative. Then the RDEIR goes on to say,
"Alternative E would meet the projects objectives, decrease the overall development area and
increase open space from that of the proposed project, and, with 185 lots, would achieve the
minimum density of at least 50 percent of the maximum allowed density." Clearly, there is
confusion in the RDEIR, as alternative E proposes 88 lots, not 185 lots. Alternative E does not
increase open space, as the footprint for housing remains the same as the project.
The only Environmentally Superior Alternative remains Alternative A: NO PROJECT. The initial
DEIR and the RDEIR are flawed documents that do not mitigate the significant impacts Canyon
Springs would have on the environment. At the very least the EIR process must be restarted
from the beginning and only considered with the cumulative impacts of all surrounding projects
on the environment.