HomeMy Public PortalAboutPublic Comment - MAP
August 15, 2022
Truckee Town Council
Town of Truckee
10183 Truckee Airport Road
Truckee, CA 96161
Re: Draft Truckee 2040 Public Comments for Economic Development, Conservation and
Open Space, and Community Character Elements
Dear Truckee Town Council and Planning Commissioners,
Please accept the following comments from Mountain Area Preservation (MAP) for the
draft Truckee 2040 elements public hearing focused on Economic Development,
Conservation & Open Space, and Community Character.
Economic Development Element:
● ED-1.D (New Office Space)—An incentive program for the development of office
spaces under 500 sf
● According to the 2020 BAE Market Study, local real estate brokers indicate
that office spaces under 1,000 sf are in the highest demand. Many
Truckee office spaces available for lease are more considerable in size,
between 1,600 and 6,000 sf. Subdividing or reconfiguring larger office
spaces is challenging because the utility systems are not designed to
accommodate separate meters, and improvements are cost prohibitive.
According to real estate brokers, the quality of these spaces is also
lacking. Why not create a program that supports and funds the
redevelopment of large offices into more desirable spaces? If small offices
are in high demand, they will be built without an incentive program based
on market needs. Redevelopment of existing infrastructure would be
better utilization of funds and programming.
● ED-1.E (Healthcare Opportunities)—Work with Tahoe Forest Hospital on the
development of a comprehensive healthcare campus plan.
● It is unclear which entity would be the lead on this, the Town or the
Hospital. Truckee 2040 should not give the Hospital free reign to develop a
plan that would impact the entire community.
1
● Tahoe Forest Hospital has already submitted a plan but has yet to receive
a response from the Town. How will this Master Plan fit with the goals,
policies, actions, and EIR review?
● ED-3.1 and ED-3.A (Sustainable Management of Tourism)
● What is a sustainable level of tourism? What is a sustainable tourism
program? Truckee 2040 needs to provide examples of sustainable tourism
and sustainable tourism programs that can be used to guide a future
program for the Town. Otherwise, it feels like an intangible goal at best
and greenwashing at worst.
● ED-3.B (Management of Tourist Attractions to Reduce GHG Emissions)
● The plan should include and identify sustainable transit options to and
from trails, recreational areas (e.g., Donner Lake), and popular open
spaces. Additionally, the plan should include sustainable transit options to
and from Reno and Sacramento.
● ED-4.9 (Housing Policies and Local Workforce Needs)
● Housing policies that meet the local workforce needs are critical. How will
this be implemented if we do not create a policy or program to
restrict/prioritize housing for the local workforce? There are no actions
proposed or associated with this policy.
● ED-6.2 (Relocation Opportunities for Industrial Uses)
● The Town and the community need to work with industrial business owners
to identify the appropriate incentives. Providing opportunities to relocate
industrial uses along the Truckee River in the Downtown and West River
District was identified as a priority in the 2025 General Plan, but this has
proven to be unsuccessful. The Planning Division needs to engage in
meaningful outreach with these business owners and discuss real
incentives/solutions to relocate industrial uses on the river.
Economic Development General Comments:
● Truckee 2040 is planning for new commercial/retail (890,000 sf), office (390,000
sf), and lodging (393 rooms), which equates to 1,526,000 sf of new non-residential
floor area. The BAE 2020 study states that Truckee has enough commercial floor
area to accommodate the next planning horizon. Why are we planning for more
than a million square feet that could negatively jeopardize our current
commercial community and create blight? This is not sound planning and
impacts our existing business community and business character.
● Utilizing the Reno economic leakage framework to justify the need for more
commercial floor area is inappropriate. It impacts the small business community,
which is the economic diversity that Truckee residents and visitors would like to
preserve. Reno will always provide goods and services for which a mountain
community is not built for, both from an infrastructure and economic standpoint.
It is hard to compete with Reno, and most of the community does not want big
box/corporate retailers.
2
Open Space and Conservation Element:
● COS-1.1 (Increase in Amount of Protected Open Space)
● The COS Element needs to 'create' not 'encourage' a Transfer of
Development Rights (TDR) program. It is unclear who the Town would be
encouraging as the Town would likely be the entity to develop,
implement, and enforce such a program. A TDR program is critical to
implement this and many other policies referenced throughout the plan.
The first step is identifying the areas to protect. Truckee 2040 needs to map
out sensitive resources (wetlands, riparian habitat, migration corridors,
habitat for sensitive species, etc.) and other open space areas with high
natural, recreational, and cultural resource values to conduct resource
planning. If we do not identify areas where there are opportunities for
density transfers to be received, then we should not make a policy for this
type of program; it feels like lip service.
● COS-1.C (Mapping of Open Space and Natural Resources)
● These maps should have been developed in the briefing book as part of
this planning process. Without the data for significant natural resources,
information is missing to make informed decisions about important areas
to be protected.
● COS-1.D (Transfer of Development Rights)
● Again, a TDR program is a crucial component for implementing numerous
goals and policies included throughout the draft GP, and the language in
this Action needs to reflect its importance. Rather than evaluating the
feasibility of a TDR program, create, implement and enforce a TDR
program.
● Upper McIver was zoned Resource Conservation in Truckee’s first land use
map of 1993, due to the steep slope, dense and tall tree stand, and
wetland features. The rezone to high-density housing has not been
supported by MAP or the community. This site would be a primary
candidate for a TDR program, moving the density to a site with capacity
and less environmental constraints.
● COS-2.A (Management Plans for Truckee River and Donner Lake)
● There are a variety of actions identified in this GP that essentially kick the
can down the road, and a ton of other plans end up sitting on the shelf. Is
another program needed? Why not incorporate policies here? If not, who
would lead this effort? Are they supportive?
● COS-2.B (Incentivization of Public Access and Restoration Activities)
● Amend the Development Code to add incentives to increase and
improve access to the Truckee River and Donner Lake. What are the
proposed incentives? The draft General Plan should have proposed
incentives, this is throughout the draft. Please provide examples.
3
● COS-3.1 (Biological Resource Open Space)
● What does it mean to consider the items identified in this policy? Provide
specific examples or more concrete details about how this policy would
be implemented and how the consideration would be incorporated into
the development review process..
● COS-3.A (Management and Protection Sensitive Biological Resources)
● It is vital not only to “prepare”, but also to implement a "comprehensive
plan for the management and protection of sensitive biological resources
such as wetlands, riparian corridors, and critical habitat areas". Such a
plan is critical given the pace at which Truckee is growing and the
recurring and potentially worsening impact of drought on our sensitive
biological resources. Local agencies need to understand the location of
these resources, their character and beneficial uses, and their
susceptibility to impact from water demand growth and land
development.
● Conservation and Open Space Element - General Comments:
● The COS Element is silent on the threat to surface waters and wetlands
posed by groundwater pumping.
● Update the COS Element to recognize groundwater-dependent
ecosystems as a critical aspect of Truckee's environmental resources.
Include language in the background section of the Element that
highlights groundwater-dependent ecosystems and provides a basis for
an additional policy. Here is an example of a paragraph that fulfills this
purpose:
● Water supplied to existing and new development in Truckee comes
almost entirely from the Martis Valley Groundwater Basin.
Groundwater pumping during periods of high demand and low
recharge (summer and autumn) can harm beneficial uses
provided by groundwater-dependent ecosystems and
groundwater-influenced surface waters. Protection of these
practical uses from groundwater pumping is an objective of the
State of California through its Sustainable Groundwater
Management Act, signed into law in 2014.
● Add a policy that protects the beneficial uses of surface waters and
groundwater-dependent ecosystems. This policy could be straightforward:
"Protect the beneficial uses provided by surface waters and groundwater-
dependent ecosystems." Defining how to implement it would need to
occur at some point, but the first step is to affirm that such protection is an
explicit policy of the Town. Doing so also strengthens the Climate Action
Plan's wetland and habitat protection goals by adding a policy basis.
Community Character Element:
4
● CC-1.2 (Surrounding Natural Context)
● This section is intended to ensure that the development of lowland areas
shall contribute to and enhance the quality of the Truckee townscape.
Still, there are no action items associated with this. How would this be
accomplished?
● CC-1.E (Donner Lake District)
● A Donner Lake overlay district should include specific height requirements
to maintain the scenic qualities of this unique area.
● CC-1.9 (Minimization of Vegetation Disturbance)
● Why not require the preservation of mature trees and native vegetation
rather than encouraging it?
● CC-1.B (Scenic Corridor Standards)
● The scenic corridor buffer was established along 1-80 to preserve the
scenic qualities and character of this mountain community. Amending or
eliminating buffer requirements to facilitate new mixed-use projects is
contradictory to the purpose of this element and should not be included
in Truckee 2040.
● CC-3.5 (Spaces to Encourage Social Interaction)
● How could the Town incentivize commercial uses that support community
interaction rather than encouraging it?
● CC-3.16 (Underground Utilities)
● Utility lines often degrade viewsheds rather than enhance them. This
should be incentivized, not encouraged.
● CC-6.2 (Inclusive Public Participation)
● This Element emphasizes the importance of public participation and
inclusion as part of the decision-making process, yet that isn't being
prioritized as part of the General Plan update. There are numerous barriers
to participation, including that the General Plan resources are not
available in Spanish. Additionally, the Planning Commission and Town
Council joint working sessions have been held in quick succession, thus
making it difficult for community members to access and process the
information provided prior to the meetings. The remaining Truckee 2040
planning timeline seems arbitrary and contrary to this policy.
● CC-8.6 (Protection of Views)
● Again, building heights for new development should be complementary
to other existing infrastructure to maintain the scenic qualities of Donner
Pass Road.
Community Character Element - General Comments:
● The actions in this plan are inconsistent with the community character
outlined in this Element—increased density without mitigating associated
impacts (traffic, parking, safety, emissions, etc.), lack of assurances for
local/workforce/affordable housing, unnecessary commercial
5
development, and inadequate open space and natural resource
protections.
● Height requirements should be implemented to ensure that building
heights are consistent with adjacent developments and do not degrade
viewsheds, especially in areas with unparalleled scenic qualities, like the
Gateway Area and Donner Lake.
● The overview discusses the importance of preserving open space to
maintain community character, but there are no policies/action items to
ensure this occurs.
● This Element references the importance of responding to the climate
challenges of the mountains and enhancing connectivity but doesn't
include policies/action items to address these needs.
Thank you, Council and Commission, for considering our comments. We appreciate
your service and dedication to this vital community planning effort. If you have any
questions regarding our comments please feel free to reach out.
Sincerely,
Alexis Ollar, MS & GISP
MAP Executive Director
Sophia Heidrich
MAP Advocacy Director