HomeMy Public PortalAboutPublic Comment #065 (Zink)November 19, 2014
Ms. Denyelle Nishimori, Senior Planner
10183 Truckee Airport Rd.
Truckee, CA 96161
dnishimori@townoftruckee.com
Re: Comments for Canyon Springs RDEIR
Dear Denyelle,
The following are comments and concerns regarding the adequacy of the RDEIR for the proposed
Canyon Springs housing development:
Please find attached my comments to the Draft EIR, as not all of the comments have been addressed in
the RDEIR. There is no specific addressing of the hydrologic concerns. The REIR admits the hydrologic
effects could be significant as there is no way to assess or mitigate the effects that the piles for bridges
may have on the hydrologic operation of the area.
IMPACTS & MITIGATION
Although the presence of some of these species is in the potential to be present range according to the
Biological Resources section, potential impacts should be seriously considered.
BIO-1 – If Sierra Red Fox is ever present, there should be no circumstance in which a take of any Sierra
Red Fox is acceptable.
BIO-2 – Removing trees where birds have nested, even though there is no active nest at the time, should
not be acceptable mitigation. Birds often return to the same spot every year to build their nests, as do
mammals that use dens. Removing this habitat while they are not there is a loss of habitat to that
animal. They have to find a new place to nest or den and this is frequently not possible in today’s
environment. Loss of habitat just because the wildlife is not present at the time, should not be
considered mitigation. Loss of habitat most often adds up to a reduction in the number of that species
that is reproducing.
BIO-3 – Credits and in lieu fees will never replace the special environment of springs and meadow
systems that exists on this property and should not be acceptable mitigation for this significant impact.
One of the mitigations is that the developer will get the required permits from USACE. Really? They
have to do that anyway and as long as there is mitigation of some kind, USACE never refuses a permit
due to significant impacts.
All mitigation (manmade) lands will be protected in perpetuity. The existing, natural meadows and
wetlands should be protected in perpetuity; they are far more valuable than something created to make
up for this significant impact to these wetlands.
BIO-4 – Roosting bats have a fairly high probability of being present. Again, they will wait until the bats
are not roosting to remove the snags and this will again constitute a loss of habitat. Bats are becoming
more endangered with the spread of white nose syndrome. Bats are particular about roosting sites and
the loss of a site could mean the reduction of reproduction in the bats that used that site.
BIOLOGICAL RESOURCES/GENERAL PLAN COMPLIANCE
Table 4.4-1
Goal LU-P7.2 of the General Plan states: Residential development shall be clustered to avoid areas of
natural resources including wildlife habitat and migration corridors and visual resources
Goal COS-5.1. – Preserve open space in Truckee and increase the amounts of desired open space under
permanent protection.
COS P1.5 – Preserve open space that occurs in large blocks and is contiguous and connected. Provide
maximum benefits in terms of habitat preservation.
This development does the opposite of these goals with one of the most desirable areas of open space
and contiguous wetlands in Truckee.
Even with all the mitigation measures, the RDEIR had to admit (page 47) that “long term disturbances in
the form of increased human activity, vehicular and bicycle traffic, equestrian use, and presence of
domestic animals, such as pet dogs”… given CDFW’s high interest and concerns for the Verdi sub-unit of
the Loyalton Truckee deer herd, impacts from the long term disturbances associated with permanent
residences on the project site are considered significant. In addition, they try to say construction
impacts can even be mitigated to less than significant, but construction will be ongoing for years, near
an important deer migration corridor. The impact of construction noise and traffic cannot be mitigated;
it will change the patterns of deer affected by this noise and traffic, not to mention the increased
mortality due to the increased construction traffic. Development moves deer to new areas with
unknown hazards and impacts, there is no doubt.
There are many more items that could be addressed that make this an unviable project for Glenshire
and for Truckee. However, based on the preceding paragraph (human disturbance and construction)
alone and the extreme inconsistency with the Truckee General Plan, particularly in relation to infill as
opposed to sprawl, I ask that the Planning Commission and Truckee Town Council vote for Alternative A:
No Project. The current owners of this property took ownership when the current General Plan was in
place. Infill is encouraged, sprawl discouraged. They should have no expectations of their project being
approved considering its inconsistencies with the General Plan. This is an out of area developer, all they
are interested in is profit, there is no consideration of the quality of life of the surrounding community
or its wildlife. Canyon Springs is undoubtedly sprawl, and the consequences of this sprawl are too high
to be allowed in Truckee. Open space and habitat are at too high of a premium these days to do this to
it. Once it’s gone, it’s gone forever.
Sincerely,
Jacqui Zink
10273 East River
Truckee 96161
March 4, 2013
Ms. Denyelle Nishimori, Senior Planner
10183 Truckee Airport Rd.
Truckee, CA 96161
dnishimori@townoftruckee.com
Re: Comments for Canyon Springs DEIR
Dear Denyelle,
The following are comments and concerns regarding the adequacy of the DEIR for the proposed Canyon
Springs housing development:
LAND USE AND GENERAL PLAN COMPLIANCE:
Goal COS-9 Link open space areas in Truckee through a well-connected network of open space and trails.
(p 7-40).
Trails in this project do not connect with the entire development, or the Town of Truckee’s trail
network.
Section LU-P9.7 Oppose development within the Planning Area that significantly impacts the Town’s
natural ecosystems and viewsheds. Goal CC-1 Preserve open space in Truckee that contributes to the
town’s scenic mountain community character. ¤ Ensuring that new development enhances the desired
character of each of these areas. And section COS-P1.1 s Acquire and preserve open space lands in
Truckee, and purchase development rights for the purpose of open space preservation, with priority
given to the following open space types: ¤ Pristine open space and large blocks of undeveloped open
space.
Canyon Springs will significantly impact the 8 acres of meadows and wetlands that occur on this
property. The construction of bridges will cause impacts to the wetlands they are supposedly
enhancing. The development will cause discontinuity in the meadow systems and springs with unknown
and possibly devastating consequences to these special meadows. These meadows are a significant
part of Truckee’s scenic mountain community character and there is no justification to have any impact
on these valuable ecosystems. At least 8 lots in phases 7 and 8 and within 200 feet of wetlands,
Goal LU-5 – Encourage a mix of land uses in the Town to promote a vibrant community and to reduce
traffic…
Canyon Springs is in direct conflict with this goal. It significantly increases traffic w/o doing anything to
promote a vibrant community or mixed land use.
Goal COS-15 - Encourage conservation of energy and fuel resources, strive to reduce generation of solid
waste, and promote environmental sustainability.
Canyon Springs is on the far outskirts of Truckee, which does not encourage sustainability and will use
more energy and fuel resources for construction as well as for the distance residents will have to travel
to services, since it provides no services to the development.
Goal LU-9 Support development patterns in the Planning Area that do not negatively impact the Town
of Truckee, and that enhance the quality of life for residents of Truckee and the wider region.
There is nothing about Canyon Springs that enhances the quality of life for the residents surrounding the
development. It will increase traffic on Glenshire drive to significantly more than mitigateable levels.
Glenshire Drive and Donner Pass Road as well as Glenshire Drive and Dorchester are already over LOS
and cannot support the 2,578 additional trips a day that will be generated by Canyon Springs.
Construction traffic will impact Glenshire and Olympic Heights for years. It will turn neighborhood roads
into an unsafe situation for children walking to and from school and bus stops and for playing. Heavy
construction traffic will have a negative impact on the condition of Glenshire Drive, is the developer
going to provide for the extra road maintenance costs?
REQUEST: Traffic studies need to be done during winter storm periods to truly show the impact of
thousands more trips per day on Glenshire Drive and on traffic safety. Is it worth people dying to allow
yet another development that is not economically feasible? Glenshire Drive is a very unsafe road during
winter storms. This development is unfeasible due to its more than significant impacts on traffic and
human safety in the adjacent neighborhoods and on all of Glenshire Drive and should not be approved
as proposed.
Canyon Springs is in conflict with Goal LU-9 of the General Plan and should not be approved.
Goal LU-3 states Create efficient land use patterns which reduce environmental impacts and
minimize the potential for residential and commercial sprawl.
Canyon Springs is sprawl and is in conflict with the General Plan. People who do not live in Glenshire
complain about how far it is from town, Canyon Springs is even farther. Developments that use more
gas and produce more greenhouse gases to get to and from city centers do not enhance Truckee and are
an environmental impact that must be considered.
Goal CC1, P1.3 Cluster new development so as to preserve the maximum amount of desired types of
open space, as identified in the Conservation and Open Space Element (p3-30) This development
represents sprawling development and not clustered. Project development should illustrate ‘Rural
Clusters’ as noted in General Plan (Table LU-7, 2-62)
DEIR alternatives: Request an Alternative be considered with no wetland crossing that clusters
development on the north side of the property only and reduces density. The current reduced density
alternative covers the same footprint and the current no wetland crossing alternative keeps the same
density with smaller lots. There should be an alternative combining lower density with no crossing to
see if it reduces impacts to an acceptable level.
WILDLIFE
Goal COS-4,P 4.2 Protect sensitive wildlife habitat from destruction and intrusion by incompatible land
uses where appropriate. All efforts to protect sensitive habitats should consider (1)Sensitive habitat and
movement corridors in the areas adjacent to development sites, as well as on the development site itself,
(2) Prevention of habitat fragmentation and loss of connectivity (p 7-31)
This project will impact a known deer migration corridor, making no attempt to protect it. New deer
study data needs to be incorporated into DEIR, as current analysis is not sufficient and updated.
Cumulative impact of development throughout the Verdi-Loyalton mule deer migration corridors should
be considered in the DEIR. The DEIR consultants seem to have used the project owner’s deer report
without any kind of independent peer review or to have consulted any other experts for other
information or possible dissenting opinions. The deer analysis appears biased due to conflict of interest
and needs more factual and recent data.
Canyon Springs will have significant impact on deer migration in the area and mitigation measures
cannot help. Changes in migration corridors affect deer significantly, as has been shown in Martis
Valley. The DEIR provides zero support for statements that the deer will continue to be able to do
seasonal migration trips through the site via the open space that remains. The numbers of this
beleaguered herd have reduced significantly in the last decade. There needs to be updated data and
independent expert references, not just unsupported opinions of the owner’s biologist and previous
data used.
HYDROLOGY
The DEIR hydrology section is inadequate. It does not include Glenshire Pond, which is a large omission
as Glenshire Pond receives the water from all of the proposed project’s drainage. Sediments and
nutrients that are added from the project site will collect in Glenshire Pond causing severe impacts to
water quality and bacteria and algae blooms to form. Hydrology and mitigation measures need to be
re-analyzed.
DEIR assumes water will infiltrate into the ground, yet the soil surveys have indicated poor permeability.
This means the analysis of the amount of pollutants and run-off in the water that overflows the
sediment basins is inadequate. Elkhorn Ridge development was built on similar soils and it has
experience large impacts due to erosion and flooding. The DEIR needs to consider cumulative hydrology
impacts from other development projects as well.
This DEIR is inadequate due to its lack of overall consideration of cumulative impacts. Loss of
migration corridors, loss of habitat, loss of connective meadow systems, water quality, air quality,
biological resources. In addition, Canyon Springs does not comply with numerous goals and land use
objectives of the general plan and that in itself should be reason for denial.
The biggest testimonial to denial is the DEIR itself. The amount of significant impacts stated for this
project should require denial considering that Truckee’s economy probably cannot even support 185
more residential lots. It states significant impacts would result to air quality, numerous biological
resources (this in itself should be unacceptable), hazardous materials, soils, hydrology and water quality
and last but certainly not least on traffic. Is this what we really want for Truckee? I don’t believe this is
any citizen of Truckee’s vision for our town, except maybe the developer.
Thank you for allowing me to comment on this DEIR. And thanks to the Town of Truckee for the effort it
has put into helping get the public involved and public comment into this project.
Sincerely,
Jacqui Zink
15434 Donnington, Truckee,
587-6030
tahoejaz@gmail.com