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HomeMy Public PortalAboutVolume IV - Final Environmental Impact Report .1 •• ' r ' - TOWN OF - , ‘ , ,., �cr,"er7, ;y. . U� Ewa+rt•*s; GENERAL PLAN - -, . , 199, - 2014 1 VOLUME IV: - , • ' Final Environmental Impact Report .. • ,,• - _ , . V . Adopted February 15, 1996 V , • , by Town Council Resolution No. 96-08 Town of Truckee V. 7 , Community Development Department, - - Planning Division - , . . ' ` - 11570 Donner Pass Road , - --' , Truckee, CA 96161 ' (916) 582-7876 , - - ' , l , TRUCKEE GENERAL PLAN TABLE OF CONTENTS page # VOLUME IV: FINAL ENVIRONMENTAL IMPACT REPORT Introduction 1 Scope of General Plan Environmental Analysis 1 Project Description 1 Environmental Setting 2 Summary of Impacts and Mitigation Measures 2 Table I: General Impacts and Mitigation Matrix 6 Alternatives to the Draft General Plan 14 Final EIR Response to Comments 16 Comments Received on Draft Environmental Impact Report 28 Letter A - Placer County Office of Education Letter B - California Regional Water Quality Control Board Lahonton Region Letter C - Department of Fish and Game Letter D - State of California Office of Governmental and Environmental Relations Letter E - State of California Department of Transportation Letter F - William Abbott & Associates October 4, 1995 Letter G - William Abbott & Associates October 10, 1995 Letter H - William Abbott & Associates October 12, 1995 Letter I - Bob Johnston Letter J - Maryellen Benier Table of Contents page i Adopted February 15, 1996 l R UCKEE GENERAL PLAN ENVIRONMENTAL ANALYSIS INTRODUCTION SCOPE OF THIS GENERAL PLAN ENVIRONMENTAL ANALYSIS The California Environmental Quality Act (CEQA) requires that the environmental The scope of analysis for the general plan and impacts of a general plan be addressed and alternatives is very broad in nature. The mitigated where feasible. CEQA Section analysis is intended to identify the need for 15166(a)allows a general plan to serve as the general plan policy direction in areas of Environmental Impact Report on the plan if potential environmental impact. Future the following requirements are met: projects such as the Zoning Ordinance, Specific Plans, and individual development (a) The requirements for preparing an EIR on applications will undergo a level of a local general plan, element, or environmental analysis appropriate to the amendment thereof will be satisfied by scope of the project. This general plan using the general plan, or element document, as the EIR and no separate environmental analysis is not intended EIR will be required, if: function as project specific analysis for development applications which are currently (1) The general plan addresses all proposed or which may be proposed in the the points required to be in an future. It is intended to provide policy EIR by Article 9 of these Guidelines, and direction to guide the preparation of future environmental documents. The information (2) The document contains a special on cumulative impacts contained in this section or a cover sheet analysis may be used in subsequent identifying where the general plan environmental documents. document addresses each of the points required. This document constitutes the "special PROJECT.DESCRIPTION section" required in subsection (2). Table I identifies where each of the requirements of For a brief description of the project CEQA have been addressed in the Truckee objectives, please see the Introduction to the General Plan. General Plan. The Plan elements themselves in this document constitute the project The Technical Appendix(Volume II)contains description. Table A.1 in Volume I presents the environmental analysis performed for the information on buildout of the General Plan. General Plan. The General Plan policies If all of the land designated in this Plan were identify mitigation measures as policies of the to be developed as identified on the Land Use General Plan. Diagram at the densities and intensities described in the Land Use Element, the _ amount of housing, population, and Environmental Analysis page 1 Adopted February 15, 1996 TRUCKEE UCKEE GENERAL PLAN employees in the future would be as shown on impact categories and the types of policies Table A.1 in Volume I. that were developed to address these impacts. The General Plan Impacts and Mitigation Table I provides additional detail. ENVIRONMENTAL SETTING A description of the existing environmental LAND USE IMPACTS setting is found in the Technical Appendix (Volume II). Land use incompatibility occurs when activities related to one land use negatively SUMMARY OFIMPACTSANDMITIGATION affect a different nearby land use. Such MEASURES incompatibility may result from noise, odors, public access, traffic patterns, and lighting. Environmental Analysis was performed as a With the buildout of the General plan an part of the development of this General Plan. increase in industrial, commercial, and As potential environmental impacts were residential land uses will occur.Land uses that identified, policies were formulated for create potential compatibility problems inclusion in the General Plan to mitigate the include commercial,industrial,family support potential impact. Table I identifies the uses, schools, public facilities, timber impacts and which of the policies of the harvesting, mining, and recreational uses in General Plan mitigate for those types of proximity to residential uses and sensitive impacts. wildlife habitat areas. Impacts related to land use compatibility are mitigated by Land Use Two significant unavoidable impacts were Policies aimed at buffers, screening, and identified in the areas of traffic and air quality. locations of compatible uses. Population It was determined that these impacts could not growth accommodated by the Draft General be mitigated to a less than significant level Plan will result in impacts to all with implementation of general plan policies, environmental categories described below, primarily because of existing traffic and air AFFORDABLE$OosING quality conditions. Impacts in other categories will be reduced to The projected population at General Plan less than significant levels with buildout is 22,500. Currently the Town of implementation of general plan policies. Truckee has a shortage of affordable housing. Project specific impacts will be evaluated and The Housing Element addresses the existing mitigated as a requirement of development and future needs for affordable housing. application processing. Mitigation for impacts on affordable housing are found in the policies of the Housing The following summary identifies the main Element and in the Land Use Element. , Environmental Analysis page 2 Adopted February 15, 1996 TRUCKEE GENERAL PLAN TRAFFIC IMPACTS traffic concerns, these areas have significant mineral resources and should be protected as Traffic impact analysis for the General Plan such. Impacts on mineral resources are is discussed in detail in the traffic reports in addressed by policies of the Conservation the Technical Appendix(Volume II). Policies Element and the Open Space Element. to address traffic impacts are contained in the Measures that address these impacts include Circulation and Land Use Elements. Traffic identification of resources on a diagram, impacts are not mitigated to a less than policies requiring uses in resource areas be significant level due to the severity of the compatible with mineral resource extraction, existing problems in specific areas. and designation of resource areas as Resource Conservation/Open Space on the Land Use Diagram. Other policies lead to regulations to IMPACTS ON BIOLOGICAL RESOURCES protect adjacent residential areas from dust, noise, and truck traffic while allowing for The Town and adjacent areas contain a mineral resource extraction to continue. number of sensitive biological resources. The introduction of urban land uses and con- version of undeveloped lands may contribute ENERGY to the devastation of sensitive wildlife and plant habitats. Impacts on biological re- Additional development accommodated by the sources are addressed by policies of the general plan will result in increased energy Conservation Element and the Open Space consumption ( natural gas and electricity). Element. Measures that address these impacts The impacts on energy are addressed by include policies requiring or encouraging policies of the Conservation Element. These preservation of habitat areas and wildlife policies require and encourage activities that movement corridors in open space, policies conserve fuel energy through making it requiring clustering of development, and possible to use alternative energy, through designation of sensitive areas as Resource recycling, and through reduction in the need Conservation/Open Space on the Land Use for automobile trips. Diagram. IMPACTS ON MINERAL RESOURCES General Plan buildout may result in impacts to existing mining operations with the siting of incompatible land uses in the vicinity of mining operations. While eliminating mining in these areas would eliminate noise and Environmental Analysis page 3 Adopted February 15, 1996 TR UCKEE GENERAL PLAN CULTURAL RESOURCES the development of design standards for specific types of uses and specific areas. The Town of Truckee is one of the richest Other policies address light and glare. locations in California in terms of the density and variety of recorded cultural resources. Virtually all of the Town is considered AIR QUALITY IMPACTS moderately to extremely sensitive in terms of cultural resources. Recorded/designated Truckee is within the Mountain Counties Air resources within the Town include Basin. The Northern Sierra Air Quality approximately 115 archeological sites, 160 Management District is the local agency for historical sites, two National Register air quality planning with authority over air Properties, 6 properties eligible for National pollutant sources. Register listing. Truckee also has one California Historical Landmark and one Particulate matter(PM10) emission levels in California Point of Historical Interest. Truckee, as measured at the Truckee air Impacts on cultural resources are addressed by• quality monitoring station, exceeded the state policies of the Conservation and Open Space standard several times during winter months. Elements. Policies that provide mitigation This is generally attributed to residential include the requirement for a Cultural wood-burning and vehicles raising dust along Resources Ordinance, and policies expressing sand covered highways.Pollutants such as CO the Town's intent to work with private and and Nox are generated by vehicular traffic. other public agencies to preserve cultural Existing levels of these pollutants are not in resources and increase public access to them excess of Federal or State standards. Policies where appropriate. Other policies address the to reduce air quality impacts are contained in need for evaluation and mitigation of impacts the Circulation Element and the Conservation to cultural resources through project Element. Impacts are not mitigated to a less application review. than significant level for PM10 due to the severity of the existing problem. However, Conservation and Open Space Policy 11.2 VISUAL AND AESTHETIC IMPACTS requires 100%mitigation of particulate matter with discretionary project approval. Ozone is Visual resources are of great importance in a photochemical oxidant formed in the urban Truckee; significant resources include atmosphere. The creation of ozone is a result prominent ridge lines, open vistas, streams, of complex chemical reactions between rivers,and lakes. Visual and aesthetic impacts hydrocarbons and oxides of nitrogen in the are addressed by policies in the Land Use and presence of sunshine. For the most part, Open Space / Conservation Elements. ozone affecting Nevada County, including Mitigating policies include requirement for Truckee, is transported to the area by screening and landscaping, setbacks from prevailing winds from Sacramento and the prominent ridge lines, and policies requiring Bay Area. There is no ozone monitoring in Environmental Analysis page 4 Adopted February 15, 1996 R UCKEE GENERAL P lP,AN Truckee. Ozone levels in Nevada City have control groundwater and surface water exceeded State and Federal standards in contamination from runoff previous years. Policies in these elements that mitigate for potential impacts related to both air pollution generated by traffic and that PUBLIC SERVICES AND RECREATION generated by dust or by woodburning stoves and fireplaces include traffic reduction Demand for public services will be measures, measures directly aimed at significantly increased with the population woodburning stoves and fireplaces, and and land development projects of the General measures expressing the Town's intent to Plan. Impacts related to public services are work together with the AQMD to address air addressed in the Safety Element and in the quality issues. Land Use Element. Policies in the Safety Element relate to provision of safety services. Policies in the Land Use Element require HAZARDS public services concurrent with development. Policies in the Open Space/Conservation Additional development could place people Element address recreation services and and structures in areas subject to natural opportunities. hazards that have the potential to create risks to life and property,and could expose humans to hazardous materials and hazardous waste NOISE IMPACTS problems. Mitigation for potential impacts --- related to hazards are the policies of the Safety Additional development will result in an Element and the Land Use Element,including increase in vehicular and stationary source requirements for clustering new residential noise levels. Other future sources of noise development away from hazards. Other include overhead aircraft from the Truckee- - policies address provision of safety services Tahoe Airport,freight and passenger trains on and evacuation and access. the Southern Pacific rail line . Noise impacts are addressed by the goals and policies of the Noise Element. Types of noise addressed WATER QUALITY include construction noise, traffic noise, and noise from railroads and industry. Additional development will potentially affect recharge of groundwater supplies due to an increase in impervious surfaces. An increase in urban storm water runoff may carry pollutants and degrade water quality. Impacts on water quality are addressed by the policies of the conservation element that require minimization of paving and programs to Environmental Analysis page 5 Adopted February 15, 1996 „ . ---., • - . ! ^ ” , ,a a • ... „ , , . • • . • ••: „.....,.•••"•••• • " •.""' . • .... , „ .„ „ . • • GENERAL PLAN IMPACTS AND MITIGATION MATRIX .:• :,: i• •• Areas of Environmental Issues and Impact The Level orlilipactlibt Volume II contains an evaluation of each of the following impact categories This Table iImplementation summary of information contained Miliat document I. POPULATION GROWTH and LAND USE IMPACTS 1.1 Development accommodated by the General Plan will result in an increase in the 1.1 The following sections of this table 1.1 An ongoing monitoring population of the Town.This General Plan was formulated to accommodate projected address the environmental impacts of and reporting program growth in all land use categories to the year 2015.Projected growth for the year 2015 growth accommodated by the General will address potential was based on detailed demographic and economic studies for Truckee,and reflects a best Plan. Monitoring of growth will be impacts from over or estimate as to future growth trends. Refer to Table 1.5 in Volume I for a comparison necessary to evaluate the effectiveness of under estimating future of existing development and future development accommodated by the General Plan, the plan over the long term. The growth potential. There is a possibility that actual future growth could fall below projections,and that the following policy establishes a reporting General Plan provides a supply of land far in excess of what demand may be. This requirement for the General Plan: overstatement of growth could result in adverse impacts in the areas of public services. Please refer to the Service providers could oversize facilities to accommodate projected population, and Land Use Policy 1.1,All policies under following sections of service/utility plans could overestimate costs for future growth. Conversely, future Land Use Goals 2,3,7 and 8. this Table for a population could exceed that accommodated by the General Plan,resulting in problems discussion of individual with provision of services and infrastructure to accommodate the increase,In addition to environmental impacts potential impacts on public services and facilities,additional population growth will result associated with growth. in impacts in the areas of noise,air quality,biological/water resources,historic/cultural resources,land use compatibility,and growth inducement.These impacts are discussed under specific sections in this table. Since the draft General Plan was formulated with The impact from the goal of accommodating projected growth, it does not create a significant growth growth inducement is inducing impact. The Land Use map and associated policies direct growth to areas closer• less than significant to the existing developed core of Town. Growth is minimized in the outlying areas of after mitigation. Town in areas adjacent to undeveloped land outside of the Town boundaries, In addition, the draft General Plan reduces growth potential from the Nevada County zoning which is currently in place. • • Environmental Analysis page 6 Adopted February 15, 1996 rENERAL PLAN,�MPA�`S �CITIGA�IAN�A't'Ri� Areas of Environmental Issues and impact ate Truckee General Flan Tee Analy s Mkt g Goals ,evel of pact a ter volume'Il contains an evaluation of>each of the following impact categortes This Tattle is a and Policies Polity implementation summary of informatton contained in that document. 1.2 The Draft General Plan could result in land use compatibility conflicts. Land use 1.2 Potential conflicts for most of these uses 1.2 Impacts from land use incompatibility occurs when the activities related to one Iand use negatively impact a will be addressed in the future incompatibility are different nearby land use.Such incompatibility may result from noise,odors,public access, development code through the reduced to a less than traffic patterns, and lighting. Land Uses that create potential incompatibilities are establishment of site specific development significant level commercial, industrial, schools, public.facilities, recreational uses, timber harvesting, standards. In addition, certain uses are through implemen- mining, etc., in close proximity to sensitive uses such as residential areas and wildlife regulated through the Special Use Permit lotion of General Plan habitat. process which is intended to address policies. compatibility issues with adjacent development.Timber harvest activities are not regulated by the Town, however policies regarding development buffers adjacent to these lands are included in the General Plan. The following policies address land use compatibility issues: Land Use Policy 4.6; All policies under Land Use Goal 8; Conservation/Open Space Policies 2.1, 2.2., 3.3; Noise Policies 1.1, 1.3, 1.4,2.1,2.2,3.1,3.2, 3.3,3.6, 1.3 Development accommodated by the General Plan will result in changes to existing 1.3 The actual intensification and alteration of 1.3 Please refer to development patterns.The most substantial changes will occur where there is a fundamental land use patterns is a fundamental impact referenced Sections, change in the existing development intensity or land use pattern, such as from very low of growth and can only be altered by density residential and open space to Planned Community and higher density residential. changes to the land use map. The Changes to existing land use patterns can result in alteration of community character,and secondary impacts from intensification and a number of environmental impacts in areas such as biological and visual resources, alteration of land uses are addressed through a number of policies requiring clustering of development, open space preservation,and protection of visual and biological resources.Please refer to the F onmental Analysis -age 7 Adopted February 15, 1 r " . , , ; I ,„„ „ „ „ „„ .„ . ... • . • . . „ • • .„ . r „ .„. r r • . „ „ „.. • ,„,„ ..„, „, • „ : , • „ . . • • • .. . ,T .u .""... r' . ' . • ' ' .• GE?ERAL PLAN IMPACISAND MITIGATION MATRIX Areas of Environmental 1SsiteS and IMpactl.,The Truckee General Plan Technical Analysis in Mitigating Goals Level of Impact after Volume II contains an evaluation of each. of the following impact categories This Table is a and Policies Policy implementation , • summary of information contained:in that document, • 1.4 Additional commercial and industrial development could exacerbate the shortage of 1.4 The following policies address provision of 1.4 This impact will be affordable housing in the area. affordable housing: Housing Policies 1.2, less than significant 3.1,5.1. after policy imple- mentation. 1.5 Development accommodated by the General Plan could result in non-contiguous 1.5 The General Plan land use map reduces the 1.5 The potential for development patterns and urban/suburban sprawl. Non-contiguous development patterns • potential for sprawling-land use patterns by • --sprawling land use occur where lands separated from urbanized areas are developed with higher intensity uses, focussing new development close to the pattems,is reduced to a creating islands of urbanized land outside of existing developed areas. Non-contiguous existing core of Town, and reducing less than significant development patterns have the effect of encouraging urban/suburban sprawl.Sprawl is also development potential in the outlying level by implemen- created by allowing continuous strip commercial development along major transportation areas.The following General Plan policies tation of the General routes,or by allowing a large amount of suburban or estate-type subdivision to occur distant address this impact: Plan policies and land from the existing community core. Auto-oriented sprawling land use patterns result in Land Use Policies 2.1,2.2,2.3,3.2,3.4, use map. .. traffic, air quality, and visual impacts and are not conducive to the development of 4.4,7.2. compact,sustainable communities.There is the potential for strip commercial development patterns along Highway 267 south to and beyond the southerly.Town boundary into the Placer County portion of Martis Valley.There is the potential for lands outside the Town limits to the east to be further subdivided into estate type parcels,resulting in the potential for residential sprawl. 1.6 There is internal inconsistency between the Policies and the Land Use Map.Policies in the 1.6 To avoid potential internal inconsistency of 1.6 The potential in- plan discourage future subdivision of estate type parcels outside of existing subdivided the General Plan,the land use designation consistency has been areas,and require clustering of all new development outside of existing significant vistas, in has changed to RCIOS in the final corrected through the The land use map designates a portion of land in the Martis Valley(north of 1-80 and the General Plan , which is a designation recommended modi- existing CHP station)as RC-10. This land is not within an existing subdivided area. In which would implement the policies set ication to the land use addition, it may not be possible to locate future new development at the General Plan forth in the General Plan to minimize map. density outside of the significant Martis Valley Viewshed, residential sprawl, provide for growth, closer to existing developed areas, and minimize development in significant viewsheds. Environmental Analysis page 8 Adopted February 15, 1996 ' • • • . , • • •••• „ GENERAL PLAN IMPACTS AND 11GA11ON MATRIX , •Areas of Environmental issues and Input•The Truckee General Plan Teehnical:Analys)kw.:::,,,..Mi ilng Pad after ..‘ Volume II contains an evaluation of each of the following impact categories This Tb1e is a and Policies Policy Implementation summary of information contained in that document 2,TRAFFIC AND CIRCULATION IMPACTS 2.1 Growth accommodated by the General Plan will create additional traffic,resulting in and 2.1 New grgrowthwillbe required to mitigate 2.1 Because of the existing increase in Level of Service Deficiencies.A detailed analysis of the Traffic Impacts of the traffic impacts. followingTheGeneral LOS deficiencies General Plan is contained in Volume II. Plan policies address this impact: during peak hours at Land Use Policies 3.5,Circulation Policies the main intersections 1.2, 1.6, 1.8, 1.9, 1.13, 1.19, 1.20,8.2, in Town, this impact cannot be mitigated to a less than significant level. -,.onmental Analysis -2ge 9 Adopted February 15, 1 ty TABLE 2 GENERAL PLA1�41I'ACTS��1�ITIGATIOI�MATRI% ; Areas of Environmental Issues and impact The Truckee• General Plan Technical 1 ysts ut 1V ltigat g s Level of Eapact apex Volume II contains an evaluation of each`of the'following impact categories;Tuts Talc zs a and Pablo es Policy mplementation summary of information contained in that document, 3.NATURAL,SCENIC,AND CULTURAL RESOURCES 3.1 Sensitive Biological Resources could be disturbed or eliminated as a result of new 3.1 The following General Plan policies 3.1 Impacts to sensitive development accommodated by the General Plan.In summary,impacts to wildlife and plant address impacts to Natural Resources: biological resources species could occur in the following areas: loss of habitat and forage lands, habitat All policies under Conservation and Open will be mitigated to a degradation due to encroaching urbanization,direct mortality and/or injury of sensitive Space Goal 1,Conservation and Open less than significant species,habitat fragmentation and obstruction of movement corridors,and harassment of Space Policy 2.3,Land Use Policies 7.1, level by imple- wildlife by humans,pets,and livestock. 7.2 mentation of the General Plan policies. 3.2 Scenic Resources could be degraded by new development accommodated by the General 3.2 The following General Plan policies 3.2 Impacts to scenic Plan.The General Plan identifies significant scenic vistas and prominent slope exposures address impacts to Scenic Resources: resources will be and ridge lines on plate 5. In addition to these mapped scenic resources,the existing scenic All policies under conservation and open mitigated to a less than, character of Truckee is defined by visual access to large expanses of undeveloped open space goals 4 and 5;Land Use policies significant level through'v space, both within and outside of the Town limits. As development occurs on these 6.1,7.1,7.2. implementation of undeveloped areas, the scenic character of Truckee could be dramatically changed. General Plan policies. Additional lighting can result in increases in light and glare pollution. 3.3 Cultural and Historic Resources could be destroyed or degraded by new development 3.3 The following General Plan policies 3.3 Impacts to cultural accommodated by the General Plan. address impacts to cultural resources. resources will be All policies under Conservation and Open mitigated to a less than Space Goal 9. significant level through implementation of General Plan policies. 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Areas of ElivirOp.,91.Issues an evaluation nteneh of.the'.. 0110Viiiit.0p..."?..,!',,...;,,•!! 7::•;: :',•J'A.,.. 0.:4,4Y:4,:1::-..t.',,,:i.ii:•:,::,„•1: ,-:•.:Mi::',,',..•.....iE,,,F:.::R,-.'.•g:i'';',•:.,,•:';':•'...,''');','...•''''•''',',.''''' '•' •' Volume II contains summary of lofor.oia tfon contained in that document. .. •;-....,•...,..,,,,,,,,,,..,,,..,,,,.,,. i,,,.,,,,,,,,::::,,, 4.IMPACTS FROM EXPOSURE TO HAZARDS 4.1 The following exposure to natural natural hazards: and man-made hazards 4.1 New Development accommodatedGeneral Plan policies address 4.1/4.2 Impacts from by the General Plan could expose people to natural will be mitigated to a All policies under Safety goal 1,and Safety hazards such as avalanches,wildfire,flooding,and erosion. • less than significant plelvanel policies. hazards imple- mentation of General policies 2.1,2.1, 2.3, 2.4, 2.5, 2.6, 2.7, 2.8, man-made hazards: development accornmodated by . General Plan policies address s 4.2 The following 4.2 New . the General Plan could expose people to man-made hazards such as airport hazards and toxic spills. Safety Policies 2.1 and 2.2 Adapted February 15, 1 006 nage 11 11 ''onrnental Analysis . . , . _ .., ._. --, . - .--. jjj • • GENERALPLAN IMPACTS CITTGATIOIq MA'fll� areas of Environmental Issues and Im t The Truckee General Plan ec cal A to t + Goals Level' I� The, � � �. Volume 1I contains an evaluation of each of the followmg impact categories This Table ss a and oliciex Pairs nplementation summary of information contained in that document, 5.IMPACTS TO AIR AND WATER RESOURCES 5.1 New development will result in an increase in air pollutants, including the following: 5,1 The following General Plan policies 5.1• Impacts to air quality generation of air pollution from vehicular traffic;generation of particulate matter from wood address impacts to air quality: from PM10 remain burning stoves,fires,road sanding,and travel on unpaved roads,and construction activities; All policies under Conservation and Open significant after generation of odors from industrial uses. Space Goal'11,All policies under mitigation due-to the -Circulation Goals 3 and 4. existing exceedance of Federal and State PM10 standards. 5.2 New development will result in an increase in surface and ground water pollution,including 5.2 The following General Plan policies 5.2 Impacts to water the following: increase in pollutant laden urban storm water runoff, increase in new lots address impacts to water quality: quality are mitigated to served by septic systems, increase in the potential for erosion and sedimentation of - All policies under Conservation and Open a less than significant waterways,increase in the potential for toxic spills. Space Goal 6 and 7;Safety policies 2,1 level with im- and 2.10;Land Use Policy 3.4, plementation of GeneralPlan policies. 5.3 Soil and Mineral Resources could be adversely affected by additional growth.Additional 5.3 The following General Plan policies development could result in an increase in soil erosion, and could remove mineral lands address impacts to soil and mineral from production, resources:All policies under conservation and Open Space Goals 3 and 7. 6.IMPACTS TO PUBLIC SERVICES AND ENERGY SUPPLIES 6.1 Growth accommodated by the General Plan will result in increased demand for public 6.1 The following General Plan policies 6.1 Impacts to public services in the areas of schools,sewer service,water service,fire and police protection, address impacts to public services. services are mitigated parks,and energy supplies,and solid waste production. Land Use policy 1.1,and all policies to a less than under Land Use Goal 3;Safety Policy significant level with 2.6,all policies under Conservation/Open implementation of Space Goal 10. General Plan policies. Environmental Analysis page 12 Adopted February 15, 1996 e; TIDE GENERAL PLAN II ACTS MLTiGATION M�ARI Areas of Environmental issues and pact The Truckee General Plan Tec An ysi ;Mitigating Gods Level of impact after ea fallowing,unpact categories This Table is a and Policies >; Policy implementation Volume II contains:an evaluation of eh of the summ of information contained in ary that document, 7.IMPACTS FROM INCREASE IN NOISE LEVELS 7.1 Additional development accomodated by the General Plan will result in an increase in traffic 7.1 The following General Plan policies 7.1 Impacts from exposure noise,and an increase instationary-source noise generators and ambient noise. address impacts from an increase in noise to excessive noise levels: levels are mitigated to All policies under Noise goals 1 and 2. a less than significant level with implementation of General Plan policies. E' 7nmental Analysisge 13 Adopted February 15, 1!' TR UCKEE GENERAL PLAN FINAL EIR RESPONSE TO COMMENTS 3. Timber harvest activities necessary for environmental studies and control of The Draft General Plan and Environmental fire fuels are not typically within a Impact Report(EIR)were circulated for a 45- Town's land use regulatory authority. day State Clearinghouse review period, This type of review is the starting on September 9, 1995 and ending on responsibility of the California October 20, 1995. During this time, the Department of Forestry. following comments were received from agencies, organizations and individuals. The 4. The following language will be added responses are numbered to correspond to the to Safety Policy 2.8 on page 48 of the numbering on the applicable comment letters. Draft General Plan (page 79 of final The policies and page numbers in parenthesis draft): Defensible space may include refer to the location of the referenced material revegetation with less flammable in the Final Draft General Plan, species, such as fire resistant native and adapted species, and the use of Letter A: Placer County Office of mulch to prevent erosion on bare soil. Education 5. Comment noted. This Comment 1. Comments noted. This letter addresses General Plan policies and addresses General Plan policies and does not raise any issues with the does not raise any issues with the Environmental Impact Report. Environmental Impact Report. 6. CEQA provides a Categorical exemption (Section 15303 CEQA Letter B: California Regional Water Guidelines)for apartments, duplexes, Quality Control Board-Lahontan Region and similar structures with no more than four dwelling units. Housing 1. Comment noted. This Comment Program 3.1.2 has been modified to be provides general information and consistent with the CEQA guidelines does not raise any issues with the regarding exemptions for multi-family Environmental Impact Report. units. 2. Circulation Policy 2.3 on page 33 of 7. The Draft General Plan includes the Draft General Plan (page 64 of policies to address the impacts of new final draft) requires that roadway construction on water quality on page construction prevent significant 42 (page 73 of final draft) under impacts to biological, scenic, and Conservation and Open Space Goal 6. historic resources. This policy will be Conservation/Open Space Policy 6.2 amended to include prevention of specifically addresses the Town's significant impacts to water quality, intent to implement BMP's Environmental Analysis page 16 Adopted February 15, 1996 TR UCKEE GENERAL PLAN established by Lahontan, as is which requires evaluation and requested in this comment. mitigation of project specific impacts to sensitive wildlife habitat. Letter C: Department of Fish and Game 4. Please refer to response to comment #1. 1. Conservation and Open Space Policy 1.4 on page 40(page 71 of final draft) 5. Comment Noted. The text in the final requires that proposed development General Plan will be modified projects evaluate and mitigate their accordingly. impacts on wildlife habitat and movement corridors. Conservation 6. Conservation and Open Space Policy and Open Space policy 1.1 will be 1.4 will be modified to include offsite modified to include the following habitat restoration as a mitigation language: Cooperate with the option to the extent that no net loss of Department of Fish and Game in the habitat values results. preparation of a comprehensive plan for the management and protection of _ • sensitive wildlife areas, including Letter D: Department of Conservation - important wildlife movement Office of Governmental and Environmental corridors, within the Town. Relations 2. The Development Reserve (DR) 1. Geologic Hazards in Truckee are __ designation has been removed from discussed on page 2 of the May 19, the General Plan. The subject area 1994 Technical Memorandum on now has one land use designation: Major Constraints contained in Open Space Recreation (OSR). The Volume II of the Public Review Draft definition of the OSR Designation on General Plan. Figure A has been page 9 (page 39 of final draft) has added to the final version of Volume been amended to include protection of II which includes a fault map, and wildlife movement corridors as a epicenter map,and a table of potential listed purpose of this designation. earthquake severity. 3. Any development proposal which Safety Policy 2.1 on page 47 (page 79 included modifications to the Prosser of final draft) requires the Town to Village interchange would have a coordinate with other emergency potentially significant impact on the response agencies to develop an wildlife movement corridor, and Emergency Response Plan including would be subject to measures to respond to earthquakes. Conservation/Open Space policy 1.4, Environmental Analysis page 17 Adopted February 15, 1996 l R UCKEE GENERAL PLAN ALTERNATIVES TO THE DRAFT GENERAL the Technical Analysis of the Draft General PLAN Plan Land Use Plan, which is included in Volume II. CEQA requires that alternatives to the proposed project be evaluated in an EIR. For the purpose of this general plan analysis, the COMPARATIVE IMPACTS ASSOCIATED WITH Draft Land Use Map and Guiding Policies THE No PROJECT ALTERNATIVE were considered the proposed project. The environmental analysis was focused primarily The magnitude of the environmental impacts on the proposed project. Two alternatives in all categories would be reduced under this were evaluated in addition to the proposed alternative due to the reduction in growth project: A No Project Alternative, and a Low potential. Impacts from traffic circulation and Growth Alternative. air quality would remain significant and unmitigated under this alternative due to the The No Project alternative consists of buildout existing LOS at major intersections in Town of existing residential parcels. No additional and due to the existing exceedances of PM 10 subdivisions or other "discretionary" concentrations. development approvals would occur under the No Project Alternative. What this alternative provides is a baseline for analysis. In other COMPARATIVE IMPACTS ASSOCIATED WITH words, it lets us know what environmental THE REDUCED GROWTH ALTERNATIVE impacts will occur if we only allowed residences on existing residential lots, and do The reduced growth alternative will result in not approve any additional development a slightly lower buildout population than the applications. Draft General Plan. Commercial growth will be less under this alternative due to the The Low Growth alternative is a "scaled reduction in commercial growth in the down" version of the Draft General Plan. Planned Communities. Assuming that the Under this alternative the development same set of policies were applied to the potential of the Planned Communities (PC-1 reduced growth alternative that are in the and PC-2) would be reduced by Y2, and Draft General Plan, environmental impacts residential densities would be reduced on under this alternative will be similar to or less some lands in the eastern portion of Town by than the Draft General Plan in all categories. designating more areas in RC/OS. A comparison of the buildout potential of the Overall development pressures on wildlife different alternatives is contained in Volume resources and scenic resources would be less I, Appendix Tables A.1, A.2 and A.3. The under this alternative than under the draft following is a discussion of the comparative general plan due to the lower densities impacts associated with each alternative. The accommodated in outlying areas of Town. full analysis of the alternatives is contained in Since traffic volumes would not be Environmental Analysis page 14 Adopted February 15, 1996 TRUCKEE GENERAL PLAN substantially reduced under this alternative,air quality and noise impacts will not be appreciably different from those of the draft general plan. The significant impacts identified for the draft general plan will occur under this alternative in the areas of traffic and air quality. One identified impact in the General Plan, impact 1.6 regarding potential internal inconsistency,would not occur under this alternative due to the RC/OS designation replacing the RC/10 designation on the subject property. Environmental Analysis page 15 Adopted February 15, 1996 TRUCKEE UCKEE GENERAL PLAN The Sphere of Influence Map shown 7. Inter jurisdictional coordination in Figure 1 on page 24 of the Draft between Placer County, Nevada General Plan, Volume I (page 55 of County, Town of Truckee and final draft), is not a geologic map. It Caltrans is necessary regarding depicts the proposed LAFCO Sphere regional land use and transportation of Influence for the Town. planning. Circulation policy 1.21 on page 33 (Policy 1.20 on page 64 of 2. Comment noted. The Notice of final draft) addresses this issue. Preparation for the General Plan EIR was sent to the Division of Mines and 8. Comment noted. Circulation Policy Geology on September 19, 1994. No 1.6 on page 31 (page 62 of final draft) response to the NOP was received has been replaced with the following: from the Division of Mines and Geology . Strive to establish and maintain a level of service D or better at weekday P.M peak hour on arterial and Letter E: Caltrans collector road segments, and on primary through movements at 1. Comment Noted. The Development intersections, in portions of the Town Code prepared pursuant to adoption of outside the downtown study area. the General Plan will further define Strive to establish and maintain a "freeway oriented commercial uses". level of service E or better at weekday Detailed definitions of specific types P.M peak hour on local, collector, of land uses are more appropriate in and arterial road segments and on the Development Code rather that in primary through movements at the General Plan. intersections within the downtown r-, study area. 2. Comment noted. 9. The traffic volumes used in the 3. Yes, it is the Joerger property. development and calibration of the Town of Truckee Transportation 4. Comment noted. The Final General Forecasting Model were from 1992 Plan designates the Joerger property as Traffic Volumes on California State a "Planned Community" which Highways, Caltrans 1993. This was requires a specific plan. the"best"available data at the time of }LL� the model calibration. Figure 2 and 5. Comment noted. Table 1 have been revised to reflect the 1994 traffic data. 6. Comment noted. See response to comment 4. 10. Comment noted. The figure has been Environmental Analysis page 18 Adopted February 15, 1996 TR UCKEE GENERAL PLAN revised. can be attributed to the lower number of work related trips in vacation 11. The traffic study and data were homes than in standard subdivisions. forwarded to Caltrans District 3. The transportation model files can be 14. The rates between a High School and forwarded to Caltrans if Caltrans has Hotel/Motel are similar during the the capability to run TMode12. p.m. peak. Thus, they were grouped together. 12. The weighted average method of • calculating unsignalized intersection 15. Comment Noted. Table has been capacity was presented to show the corrected. comparison between that method and 1' the method used in the 1985 Highway 16. Comment noted. Capacity Manual, Special Report 209. The standard 1985 Highway Capacity 17. This is correct. State Route 89, north Manual, Special Report 209, method of Interstate 80, would need to of analysis was used for the remainder improved to a four or five-lane facility of the calculations in the report. It from Interstate 80 to Prosser Dam should be noted that the revised Road. Highway Capacity Manual uses a weighted average method of analysis 18. Comment note. One exception would for unsignalized intersections. be the Truckee Bypass (State Route 267). 13. The trip generation rates are not consistent with standard Institute of 19. The road widenings shown in Table Transportation Engineers (ITE) rates. 22 are presented to provide a During the development of the Town comparison of the number of lanes of Truckee Transportation Forecast needed to meet the projected traffic Model ITE trip generation rates were demands at general plan buildout at used in the initial stages of the model the level of service D. They are not calibration. However, as the model intended to be mitigations or show if was developed the rates were changed the improvements are feasible. until the model could forecast traffic volumes for the existing conditions 20. The table is intended to provide a within acceptable tolerances when comparison of the impacts or benefits compared to actual summertime of each of the land use and circulation weekday p.m. peak hour traffic alternatives studied.To provide a even volumes.The discrepancy between the comparison the intersection level of single family home p.m. peak hour service analysis was completed using trip rate in the model and the ITE rate the existing lane configurations and Environmental Analysis page 19 Adopted February 15, 1996 l�-+ RUCKEE GENERAL PLAN traffic control. characteristics of the project description are described in Volume II in the Technical Memorandum on Letter F: William Abbott and Associates Major constraints,the Technical Noise (October 4, 1995) Study, the Draft General Plan technical analysis, and the Town of 1. Comment noted. These comments Truckee Transportation Model. address General Plan policies and do Volume III, the Economic and __ not raise any issues with the Demographic Analysis, provides a Environmental Impact Report. description of the existing economic and demographic setting. 2. This comment states general positions on the DEIR which do not allow for a c) A statement describing the specific response to the alleged intended uses of the EIR is not deficiencies. provided. Response: The intended uses of the 3. This comment raises three issues: EIR are contained on page 126 of a) A regional map showing the Volume I under the heading"Scope of location of the project is not provided this General Plan Environmental Response: Analysis" (page 1 in Volume IV of A regional map has been included as final draft). figure 1 in the Final Volume I Document. 4. The DEIR contains a description of the Town's existing air quality b) A general description of the environment on page 10 of Volume II Project's technical and economic and in the Technical Memorandum on environmental characteristics is not Major constraints (May 19, 1994) provided. (page 11 in Volume II of final draft), Response: The project description is and on page 22 of the General Plan summarized in Table 8.2(Table A.1 in Technical Analysis(August 29, 1995) final draft) and on Plates 1-6 of the (page 21 in Volume II of final draft), Volume I Draft General Plan. The which also includes an analysis of the Land Use element provides effect of General Plan buildout on definitions of land use designations Carbon Monoxide (CO), Reactive which are the primary component of Organic Gasses (ROG), Nitrogen the General Plan project description. Dioxide(Nox),and Particulate Matter Other components of the project (PM10). Significant air quality description are contained in the goals impacts are discussed under Item 5.1 and policy statements of the General in Table 8.1 in Volume I (Table I in Plan Volume I. The environmental Volume IV of final draft). Environmental Analysis page 20 Adopted February 15, 1996 TR UCKEE GENERAL PLAN 5. This comment is correct in stating that "Prior to the adoption of the Truckee applicable mitigations were not Air Quality Management Plan, the included for air quality impacts in the Town shall require that discretionary Impacts and Mitigation matrix Table development projects shall mitigate 8.1. Table 8.1 (Table I in Volume IV 100%of their impacts on PM10 levels. of final draft) will be amended to add Such mitigation may include: the following under Mitigating Goals prohibitions on wood burning stoves and Policies for item 5.1: All policies and fireplaces, purchase and/or under Circulation Goals 3 and 4. replacement of non-EPA certified woodstoves within the Air Basin, 6. The Summary of Impacts and prohibition on vegetation burning, Mitigation measures on page 127 of dust control during construction, or Volume I (page 3 in Volume IV of other measures as appropriate. " final draft) identifies air quality impacts as significant and 9. The potential physical deterioration of unmitigable. the Downtown Area which could result from the build-out of 7. The Air Quality Discussion on page commercial uses in the General Plan is 129 of Volume I (page 5 in Volume too speculative to analyze. No IV of final draft)has been amended to information has been provided to include information regarding the substantiate the claim that the Mountain Counties Air Basin and downtown area could deteriorate, Ozone pollution. resulting in potentially significant environmental impacts. Information 8. This comment summarizes comments contained in Volume III: The 4, 5, 6,and 7. Please see the responses Economic/Demographic Conditions to these comments. Mitigation and the Fiscal Impact Analysis of the measures for air quality impacts are Draft General Plan demonstrates that contained in Volume I, Table 8.1 the population and economy of the (Table I in Volume IV of final draft), Town will continue to grow and item 5.1, and in Circulation Element support substantial additional policies under Goals 3 and 4. To commercial development. address PM10 impacts which may occur in the interim prior to the Air 10. CEQA does not require that the Lead Quality Management Plan, the Agency conduct economic analyses on following policy has been added to the general plan policies which serve as General Plan (Conservation/Open mitigation measures. Space Policy 11.2 on page 76 in Volume I of final draft): 11. Table 23 in the Traffic Analysis in Volume II of the General Plan shows - - Environmental Analysis page 21 Adopted February 15, 1996 TRUCKEE UCKEE GENERAL PLAN projected LOS at General Plan 14. The General Plan states on page 126 buildout for 20 major of Volume I (page 1 in Volume IV of intersections in the Town.This fmal draft): "Future projects such as table shows LOS for the the zoning ordinance, Specific Plans, following Conditions:Existing and individual development Condition, No Project applications will undergo a level of Alternative, Low Growth environmental analysis appropriate to Alternative, General Plan the scope of the project. This general (project description) , and four plan environmental analysis is not sub-alternatives of the General intended to function as project specific Plan scenario. These analysis for development applications alternatives and sub- which are currently proposed or which alternatives are described in may be proposed in the future." detail on pages 67 and 68 of the Traffic Study in Volume The final General Plan includes an II. Significant effects on implementation program in Volume I traffic created by buildout of which provides additional specificity the Draft General plan are on the time frame and responsible detailed in tables 22 and 23, agencies for each of the general plan and summarized on page 72 of policies. the Traffic Study in Volume II. The circulation network .15. One of the primary implementation alternatives are described on tools for the General Plan is the page 69 of the Traffic Study. Development Code(also referred to as Commentor is referred to these the zoning ordinance). Land Use sections for information Policy 4.4 on page 20(page 51 of final relevant to the comment. draft) states that standards to preclude new strip commercial development 12. At the General Plan stage, practicality will be established by the prohibits devising precise project Development Code. It is commonly specific mitigation measures early in accepted planning practice to establish the planning process. Future specific development standards and development projects will be subject definitions in the Development Code to project specific environmental rather than the General Plan. In the analysis in order to formulate project interim period prior to adoption of the specific mitigation measures. Development Code projects will be evaluated against Land Use policy 4.4 13. Comment noted. The Town will make on case-by-case basis. the required CEQA findings when the final General Plan is adopted. 16. Comment noted. This comment Environmental Analysis page 22 Adopted February 15, 1996 TR UCKEE GENERAL PLAN provides general information August 25, 1995 Technical Analysis and does not raise any specific contained in Volume II discusses the points regarding the EIR. relative impacts of the alternatives in each of the environmental categories 17. By its very nature, the environmental analyzed. analysis for the General Plan addresses cumulative impacts. The 21. The General Plan could foster analyses were based on buildout economic and population growth conditions of the General Plan. The within the Town by planning to traffic, noise, and air quality analyses accommodate growth projected to were based on traffic generated at occur as result of economic and buildout of the general plan in market forces. Growth inducing addition to a proportion of regional impacts are discussed on Pages 4 and traffic generated from outside the 5 of the August 25, 1995 Technical Town of Truckee. Analysis contained in Volume II, and in Table 8.1 under item 1.1 in Volume 18. Comment noted. This comment I(Table I in Volume IV of final draft). provides general information and does not raise any specific points regarding 22. The impacts of accommodating the EIR. growth on existing community services and facilities are described on 19. The alternatives evaluated in the pages 29 through 31 of the August 25, General Plan EIR are clearly described 1995 Technical Analysis contained in on page 130 of Volume I (page 13 in Volume II (page 28 through 30 of Volume IV of final draft) under final draft), and under items 1.1 and "ALTERNATIVES TO THE DRAFT 6.1 of Table 8.1 in Volume I (Table I GENERAL PLAN". In addition, the in Volume IV of final draft). alternatives are described in more Estimated population increases are detail in Tables 8.3 and 8.4 of Volume contained in item 1.1 of Table 8.1 I (Table A.2 and A.3 in Volume I of (Table I in Volume IV of final draft), final draft). Please see the response to and in Table 8.2 (Table A.1 in comment 11 regarding the additional Volume I of final draft). Growth alternatives evaluated in the Traffic inducement was not identified in the Study. Draft EIR as a significant unmitigatable impact. The Final EIR 20. Impacts which occur under the Low will clarify this issue by adding the Growth Alternative and the No Project following to Item 1.1 in Table 8.1 of alternative are summarized on Page Volume I (Table I in Volume IV of 131 of Volume I (page 13 in Volume final draft): IV of final draft). In addition, the _ Environmental Analysis page 23 Adopted February 15, 1996 TRUCKEE UCKEE GENERAL PLAN Add under areas of Environmental Environmental Impact Report. Impact: 2. Comment noted. This Comment Since the Draft General Plan was addresses General Plan policies and formulated with the goal of does not raise any issues with the accommodating projected growth, it Environmental Impact Report. does not create a significant growth inducing impact. The Land Use map 3. Comment noted. This Comment and associated policies direct growth addresses General Plan policies and to areas closer to the existing does not raise any issues with the developed care of Town. Growth is Environmental Impact Report. minimized in the outlying areas of Town in areas adjacent to 4. Comment noted. undeveloped land outside of the Town boundaries. In addition, the draft 5. Comment noted. General Plan reduces growth potential from the Nevada County zoning which is currently in place. Letter H -William Abbott and Associates (October 12, 1994) Add under Mitigating Goals and Policies: 1. There is no significant new information which has been added to All policies under Land Use Goals 2, the EIR which would necessitate 3, 7, and 8. recirculation of the document. Following is an explanation of the Add under Level of Impact after Policy changes made to the Draft General Implementation: Plan: The impact from Growth inducement Non-residential square footage at is less than significant after mitigation. buildout has decreased by 12,000 square feet. This is due to a decrease 23. Comment Noted. in the amount of commercial and industrial acreage, offset to some extent by additional development Letter G: William Abbott and Associates potential in the Downtown Study area (October 10, 1995) and PC-2. 1. Comment noted. This Comment Residential units at buildout have addresses General Plan policies and increased by 230 units. This is does not raise any issues with the primarily due to an increase in the Environmental Analysis page 24 Adopted February 15, 1996 TRUCKEE GENERAL PLAN potential number of dwelling hour to 2,980 vehicles per hour). units downtown, and in the amount of land changed from the open space to residential categories. Letter I-Bob Johnston The traffic model was redone based on 1. The mitigation measures for traffic the Town Council's modifications to impacts are identified in Table 8.1 in the draft General Plan. The results of Volume I (Table I in Volume IV of this analysis are contained in the final draft) under item 2.1. Mitigation General Plan Traffic Analysis in measures for air quality impacts are Volume II of the final draft. To identified under item 5.1 in Table 8.1 summarize, the rerun of the Traffic (Table I in Volume IV of final draft). model showed: The documentation for conclusions regarding the significance of impacts a) changes in land use are contained in the Technical designations from commercial to Analysis of the Draft Land Use Plan residential along Deerfield Drive (August 29, 1995), contained in resulted in a decrease in projected Volume II of the Draft General Plan, traffic volumes on Deerfield Drive and in Chapter 8 of Volume I(Volume (1,300 vehicles per hour to 970 IV of final draft). vehicles per hour) and Highway 89 South (1,770 vehicles per hour to 2. Comment noted. This Comment 1,460 vehicles per hour). addresses General Plan policies and does not raise any issues with the b) modification of development Environmental Impact Report. assumed on PC-2 in the lodging category results in a decrease in 3. Comment noted. This Comment projected traffic volumes on Highway addresses General Plan policies and 89 North (2,330 vehicles per hour to does not raise any issues with the 2,070 vehicles per hour). Environmental Impact Report. c) intensification of commercial 4. The RC/OS Designation is not and residential development in the "permanent" because it is a land use Downtown Study Area results in an designation which is subject to change increase in traffic volumes on through future General Plan updates.It Commercial Row(1,290 vehicles per is not possible to establish permanent hour to 1,370 vehicles per hour), and open space through a General Plan. A on State Route 267 South of general plan only establishes policies Commercial Row(2,940 vehicles per that lead to the eventual creation of Environmental Analysis page 25 Adopted February 15, 1996 TR UCKEE GENERAL PLAN permanent open space through available data shows that the trend is measures such as acquisition, towards an increased proportion of conservation easements, etc., second homes in the area. The traffic as is recognized by model is based on full buildout of the Conservation and Open Space Draft General plan. As such, it Policy 4.6 on page 42(page 73 represents a "worst case" scenario of of final draft). the traffic impacts which could occur, since it is highly unlikely that full 5. Conservation and Open Space Policy buildout could ever be reached. 1.4 on page 40 (page 71 of final draft) requires that impacts to sensitive 8. Comment Noted. habitat be identified through the Development review process in all 9. Conservation and Open Space Policy land use categories. 11.1 on page 45 (page 76 of final draft)requires that the Town develop 6. Noise impacts on the old mill site are and Air Quality Management Plan for generated primarily from the rail the control of PM10. The purpose of corridor, as is explained in the noise the Air Quality Management Plan is to analysis contained in Volume II. The identify the sources of the PM10 airport flight paths are regulated by the 'problem in Truckee, identify Federal Aviation Administration and appropriate methods for reducing are not subject to control by the PM10 levels, and establish a Truckee-Tahoe Airport. In addition, regulatory program to implement airport flight paths are established controls on PM10 generators. Due to based on a number of constraining the detailed and technical nature of factors such as prevailing winds and the PM10 problem, specific measures topography. Modifying these flight are more appropriately identified paths may not be feasible based on the through the development of an Air highly constrained nature of the Quality Plan rather than through the airport. General Plan. Also see response to comment F 8. 7. A proportion of regional traffic which is not generated from within the Town Conservation and Open Space Policy of Truckee is assumed in the traffic 12.3 on page 46 (page 77 of final model. This share of regional traffic draft) requires that significant was assumed to increase above developments assess and mitigate existing levels in the traffic for the short term and long term impacts to air buildout scenario. Assuming that the quality. Project specific mitigation ratio of second homes would decrease measures will be applied as required over time is too speculative, since during review of individual Environmental Analysis page 26 Adopted February 15, 1996 TRUCKEE GENERAL PLAN applications. 3. Mitigation measures for traffic impacts are identified in Table 8.1 10. Land Use Policy 3.3 on page 19 (page under item 2.1 in the Volume I 49 of final draft) requires that services General Plan(Table I in Volume IV of be available concurrently with project final draft). approval. This policy applies to both residential and non-residential 4. Mitigation measures for air quality development. impacts are identified in Table 8.1 under item 5.1 in the Volume I The comment regarding mitigation General Plan(Table I in Volume IV of measure 2.1 is too general to respond final draft). Additional mitigation for to. It is not clear what components of air quality impacts will occur with the the listed policies need elaboration and addition of Conservation/Open Space quantification. Policy 11.2. Circulation Policy 1.6 on page 31 5. The impacts associated with the (page 62 of final draft), which construction of the Highway 267 establishes the LOS D standard, Bypass were addressed in previous applies to roadways and intersections. environmental documentation In order to prevent adverse impacts prepared by Caltrans and referenced in resulting from strict application of this the Bibliography on page 79 of standard (for example, widening an Volume II of the Draft General Plan intersection to 32 lanes), the policy is (page 4 of final draft). As stated on modified as stated in the response to page 3 of the Volume I Draft General comment E-8. Plan, a basic assumption of the Plan was that the Highway 267 Bypass would be built within the time frame Letter J-Maryellen Benier of the Plan. 1. Comment noted. This comment addresses General Plan policies and does not raise any issues with the Environmental Impact Report. 2. Comment noted. This comment addresses General Plan policies and does not raise any issues with the Environmental Impact Report. Environmental Analysis page 27 Adopted February 15, 1996 l R UCKEE GENERAL PLAN COMMENTS RECEIVED ON THE DRAFT ENVIRONMENTAL IMPACT REPORT Environmental Analysis page 28 Adopted February 15, 1996 PLACER COUNTY OFFICE OF EDUCATION 360 Nevada Street, Auburn, CA 95603-3779 ••- (916) 889-8020 JOHN REINKING, Placer County Superintendent of Schools October 10, 1995 RECEIVED O r T 12 1995 Mr. Tony Lashbrook Community Development Director TOWN ®F TRUCKEE Town of Truckee 11570 Donner Pass Road COMMUNITY DEVELOPMENT DEPT, Truckee, CA 96161 Dear Mr.. 7 wash. . v{-,ro-l- On behalf of the Tahoe Truckee Unified School District, I offer the following comments on the Town of Truckee' s General Plan and Draft Environmental Impact Report. 1 . Page 19 - Land Use Goal 3 . 1 A definition of special districts should be included into the plan which specifies the Tahoe Truckee Unified School District as a special district . 2 . Page 19 - Land Use Policy 3 . 3 "Approved permits" should he expanded to include General Plan Amendments, rezones on subdivision maps . 3 . Page 19 - Land Use Policy 3 . 6 Do "all facilities" in this policy include schools and other non-town public facilities: 4 . Page 21 - Table 1 . 6 - Ser-:_ce Standards and Timing • Standards should show under schools . "Sufficient school sites and facilities including permanent and temporary classrooms" Timina - The timing should be shown as zoning, ' subdivision map and specific development use permit stage instead of just zoning. PLACER COUNTY BOARD OF EDUCATION �:• *` SCHOOLS MR. RICH COLWELL MRS. CAROLE ANNE ONORATO MR. NORMAN F. FRATIS, JR. DR. KENNETH SAHL MR. SCOTT GNILE MR. FRED TUTTLE . ... MRS. PAMELA ULMER Page 2 Many times a large residential development already has zoning on their property without a school funding mechanism in place. A condition of approval on a subdivision map would then be necessary. The condition would require entering into a development fee agreement with the project . 5 . Page 108 - Fees The fees section should have a discussion of the district' s financing program which was adopted in 1990 . The details of this program are as follows : • Collection of the State 2eveloper Fee on all developed lots (currently $1 . 72 Per sq. ft. ) • Collection of an increased Developer Fee on all new lots created after August 1990 . The fee was calculated at 50% of the actual cost of providing new facilities . This Developer Fee is implemented through a condition of approval by the City, Town or County in which the project was located. A Mutual Benefit Agreement would be signed by project developer prior to the District issuing a Will-Serve letter to the public agency approving the project. 2he current fee in this agreement is $2 . 83 per square foot. Prior to the town' s incorporation, the District had Nevada County condition several projects to comply with this program. 6 . Page 112 - Table 7 . 31 Please show the District' s adopted $2 . 83 per square foot fee for future development . This fee is currently being collected on projects within the Town of Truckee and on projects adjacent to the town in Placer County. All existing lots in projects not conditioned to be in the District' s financing program would pay $1 . 72 per square foot . Attached is a fee comparison of school districts in Placer County which have school financing programs beyond the state $1 .72 level as shown. Please note that the Auburn School District shown is only a K-8 district and collects a portion of the $1 . 72 per square foot on all existing parcels . Tbe Mello Roos program listed is for future development since 1989 . In addition, the Placer High School District collects Page 3 the remaining portion of :he $1 .72 . The Placer High School District' s portion plus the Auburn Mello Roos totals $8, 093 per single family home . Thank you for allowing the Truckee Unified School District to offer comments on the Town' s Draft General Plan Policies . s . ncerely, James F. Bush Facility Planner JFB:nt Enc. FEE PROGRAMS IN PLACER COUNTY NON UNIFIED DISTRICTS K-8 Fee 9-12 Fee Total Eureka 4,874 Roseville High 3,392 8,266 Roseville City 4,354 Roseville High 3,145 7,499 Loomis 4,869 Placer HSD 1,340 6,209 Foresthill 6,405 " 1,340 7,745 Placer Hills 6,553 " 1,340 8,479 Auburn Union 6,365* " 1,340 8,093 *Auburn Union Mello-Roos Buy Out UNIFIED DISTRICTS Rocklin Unified $4,000 + 59¢ per sq. ft. = $5,062 plus $477 per year for 20 years +$477 per year tax Western Placer Unified Mello-Roos Buy Out $8,602 $3.95 per sq. ft. (2,200 sq. ft. maximum fee) Tahoe-Truckee Unified School District $2.83 per sq. ft. Example 2,200 sq. ft. home = $6,226 COMPARING THE COST OF A NEW SCHOOL TO THE RECEIPT OF THE DEVELOPER FEES. BASED ON THE COST OF $18,000 PER STUDENT FOR AN ELEMENTARY SCHOOL (GLENSHIRE ELEM) 1500 SF $1 .72 $2580 15% $2.83 $4245 24% 2000 SF $1 .72 $3440 19% $2.83 $5660 31 % 2500 SF $1 .72 $4300 24% $2.83 $7075 3 9% EXAMPLE #2 (TRUCKEE PINES APARTMENTS) 104 UNITS, APPROX 100,000 SF, PAID $1.72 SF ...$175,000 TO DIST. ESTIMATED STUDENT YIELD .70 PER UNIT = 72.8 CHILDREN WILL GENERATE A NEED FOR 5,205 SF. OF BUILDING SPACE AT $155 COST PER S.F. TO BUILD = $806,806 TO CONSTRUCT FEES COLLECTED $175,000 COST TO CONSTRUCT (806,806) SHORT FALL TO SCHOOL DIST $ 631,806 TO HOUSE CHILDREN IF ONLY PORTABLE CLASSROOM USED 4 @ $95,000 =$ 380,000 SHORTFALL W/RELOCATABLES ONLY = $205,000 HAD THEY PAID $2.83 SF = S283,000 STILL SHORT $97,000 FOR PORTABLE CLASSROOMS & $523,806 FOR NEW CLASSROOMS Le+t'tr STATE OF CALIFORNIA-CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY PETE WILSON, Governor 1LIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - ,• ►HONTAN REGION 2092 LAKE TAHOE BOULEVARD 3< °t'� r SOUTH LAKE TAHOE,CALIFORNIA 96150 J�o° (916)542-5400 FAX(916)544-2271 RECEIVED Y° � October 17, 1995 • OCT 191995 Town of Truckee Community Development Department, TOWN OF TRUCKEE Planning Division COMMUNITY DEVELOPMENT i DEPT. 11570 Donner Pass Road Truckee, CA 96161 Gentlemen: REVIEW OF TOWN OF TRUCKEE DRAFT GENERAL PLAN AND " ENVIRONMENTAL IMPACT REPORT, 1995-2014 Staff of the Lahontan Regional Water Quality Control Board (Regional Board) have reviewed the Draft General Plan and Environmental Impact Report (DGP/EIR, Vols. I and II). The DGP consists of goals and policies to deal with projected growth through 2014. The DEIR concludes that water quality impacts of the General Plan can be mitigated to less than significant levels. The Regional Board will not issue any permits as a direct result of Truckee's adoption of a General Plan. We have the following comments as a "trustee agency" under the California Environmental Quality Act (CEQA) for the surface and ground waters of the Truckee area. General Comments: 1 � _ The Town of Truckee is to be commended for considering a number of very constructive proposed policies in the Conservation and Open Space and Safety Elements of the General Plan which will protect and enhance water quality and beneficial uses of water. These policies include establishment of setbacks from the Truckee River and its tributaries, protection of groundwater recharge areas and steep slopes, transfer-of-development-rights systems to protect biologically sensitive areas such as wetlands, and commitment to work with state and local agencies to identify and eliminate existing and potential sources of water 1 pollution. Regional Board staff are in support of these policies. The State Water Resources Control Board and the Regional Boards are in the process of shifting their water quality planning activities to a watershed planning focus. The Regional Board has recently revised its Water Quality Control Plan for the Lahontan Region (Basin Plan) which clarifies Regional Board goals and policies for the Truckee River and its watershed. The Truckee River watershed is one of the highest priority watersheds in the Lahontan Region for watershed planning. The proposed General Plan policies will be an important factor in our watershed planning and implementation effort. Regional Board staff look forward to working with the Town of Truckee and other stakeholders toward the protection and enhancement of water quality in the Truckee River watershed. Town of Truckee -2- The new Basin Plan encourages watershed restoration and includes a detailed program for the protection and enhancement of wetlands and 100-year floodplain areas of the Truckee River and its tributaries. Regional Board staff are committed to work with local governments to coordinate and streamline permitting processes. Along with CEQA and other permitting processes, policies in the Basin Plan include requirements to develop adequate measures when mitigation for losses of wetland/floodplain values and functions is required. These values and functions include water purification, flood control, nutrient removal and transformation, sediment stabilization and retention, water supply, ground water recharge, erosion control, recreation, and wildlife and aquatic habitat values. The Regional Board generally implements its wetland protection policies within a hierarchy of preferred alternatives, with avoidance and minimization of wetland disturbance preferred over disturbance followed by mitigation consisting of wetland restoration or creation. In general, onsite and in-kind mitigation is preferred over offsite mitigation. In some cases, avoidance and onsite mitigation may be infeasible or undesirable due to other competing objectives. For these cases, the Regional Board encourages local governmental entities to develop and implement wetland and floodplain policies, including the development of local "mitigation banks" whose primary focus is the restoration of damaged historic wetland sites. Under this concept, wetland encroachment mitigation fees are paid by the developer to the custodian of the wetland bank to improve the functions and values of the historic wetlands. Mitigation banking is especially applicable to mitigating disturbance of small, fragmented wetlands of low value, by focusing efforts into the enhancement of a formerly high-value wetland. It is also suited to assisting local residents (i.e., the single- family home owner or business owner) to provide adequate mitigation where the expertise, financial resources, water or land to provide suitable replacement wetlands is limited. There are areas within the Town of Truckee which may be suitable as potential sites for development of a wetland mitigation bank, including, but not limited to, the Teichert Aggregates quarry site on Donner Creek, near the west end of Deerfield Drive, and the old Fiberboard mill near the confluence of Trout Creek with the Truckee River. Grants and/or low interest loans may be available for start-up, with the goal that the bank will ultimately be self-supporting. The Regional Board is,currently awaiting the results of a study of the Truckee River watershed, conducted pursuant to Section 205(j) of the federal Clean Water Act, which will provide information on appropriate planning efforts to improve watershed conditions in the Truckee region. The study has three primary components: water quality planning, land use planning, and water budgeting within the watershed. In addition, the 205(j) study will provide an improved planning basis for grant funding available to local governmental agencies under Section 319 of the Clean Water Act, particularly with regard to control of non-point source water pollutants. A Technical Advisory Committee has been formed around the development of the 205(j) report, and Regional Board staff look forward to continued cooperation with Town of Truckee staff in assessing the conclusions and recommendations of the final report, when published. Town of Truckee -3- Specific Comments on the DGPIEIR 1. (Vol. I, page 29) Table 2.1, "Roadway Improvements Associated with General Plan Implementation", includes the widening of West River Road east of Highway 89 to four lanes. Because of the proximity of the road to the Truckee River, this direction could be in conflict with some of the water quality protection policies elsewhere in the 2 General Plan. The final EIR should recognize and identify possible mitigation for the potentially significant water quality impacts of this circulation goal and for those of other potential roads or road-widening projects near surface waters. (An example is the dedicated easement across Trout Creek for the Euer Valley Road alignment between Northwoods Boulevard and Bridge Street.) Road widening projects which affect wetlands and/or 100-year flood plains will be subject to the Regional Board's Basin Plan mitigation/offset requirements. 2. (Vol. I, page 43) Conservation and Open Space Policy 7.4 would require a Conditional Use Permit for substantial grading or timber harvesting not associated with a development project on parcels in a number of zoning categories. However, "actions necessary for environmental studies, and for control of fire fuels" would be 3 exempt from this requirement. Because of the currently large number of dead and dying trees, we are concerned about the potential water quality impacts of these exemptions. The final EIR should recognize and provide mitigation for such impacts, particularly in cases where small-scale fuel control timber harvests may not be reviewed under California Department of Forestry procedures. 3. (Vol. I, page 48) Safety Policy 2.8 involves implementation of requirements to maintain "defensible space" for fuel reduction around development. In order to protect water quality from the potential for accelerated and severe erosion from land development, the concept of "defensible space" should include revegetation with less 4 flammable species, and fire-resistant native and adapted species, and the use of mulch rather than the creation of large areas of bare soil continually disturbed by raking, and subject to erosion by water and wind. —4. (Vol. I, pages 107 and 114) The Housing Element provides for second dwelling units on single-family residential parcels "in appropriate areas" and under certain conditions. The availability of wastewater collection and treatment facilities and the 5 Regional Board's septic system waste discharge prohibition and density criteria should be factors in the determination of "appropriate areas" for second units, and for "clustered development" in unsewered areas. Storm water control needs associated with increased impervious surface for such units should also be considered. 5. (Vol. I, page 118) In order to increase the supply of affordable housing, Housing Program 3.1.2 proposes to change the Development Code to make the approval of multifamily dwelling complexes of 24 units or less "ministerial". As we commented in our response to the Notice of Preparation for the General Plan EIR, Regional Board staff are concerned that this recommendation will make it necessary for the Regional Board to assume lead agency responsibility for "ministerial" multi-family housing projects, and to prepare its own environmental documents before approving waste discharge permits; this would cause delay and negate the purpose of the policy. On Town of Truckee -4- page 126 of Volume I, it is stated that the General Plan environmental analysis is not intended to function as project specific analysis for development applications which are currently proposed or which may be proposed in the future. The draft General Plan EIR does not adequately address the potential water quality impacts of ministerial multi-family housing projects. There are two potential alternatives for resolving this problem: (1) the final General Plan could designate specific areas where such "ministerial" housing could be built and provide adequate programmatic analysis of water quality impacts and mitigation measures for housing in such areas in the final EIR; or (2) in adopting the General Plan, the Town of Truckee could make a commitment to do a future programmatic EIR for such housing before it is declared "ministerial". 6. (Vol 2, pg 37) This section states that all new development and construction will potentially affect water quality and ground water recharge, and indicates that General Plan policies should address these issues. In addition, proposed policies such as undergrounding all utilities to prevent viewshed impacts may have unintended consequences to water quality, for instance, as a result of repeated disturbance to unstabilized roadside drainageways. In view of Regional Board prohibitions on waste discharges within the Truckee River watershed, improvements to water quality within the watershed will most likely occur through the control of non-point source pollution and restoration of the natural, water-cleansing functions of wetlands and floodplain areas. To this end, the Regional Board has required that new commercial, as well as new and existing industrial facilities, incorporate onsite drainage controls to treat or infiltrate storm water runoff from all impervious surfaces generated by a 20-year, 1- hour storm (0.70 inch of rainfall). Although the Regional Board typically does not regulate single-family residential development following subdivision development, it is consistent with the goals set forth in the DGP/EIR that local Town planners require that new residential development (i.e., individual homeowners, multi-family housing developers) consider and incorporate appropriate Best Management Planning to prevent increases in suburban runoff and impacts to water quality from the construction of impervious and compacted surfaces associated with new and expanded residential development. Accepted Best Management Practices could be used to limit water quality impacts to pre-development levels, or use of design criteria (such as the 20-year, 1-hour storm) could be specified as an alternative to showing that a project will not result in substantial adverse impacts when considered cumulatively with other development. Individual drainage improvements will serve other goals such as I si • Town of Truckee reducing the need for auxiliary Town drainage improvements, prevent exacerbation of flooding effects and associated hazards, improve the quality of storm waters tributary to surface waters, reduce erosion, enhance the aquatic environment, etc. Such requirements appear to be consistent with other design elements of the General Plan. Please contact Judith Unsicker at (916) 542-5417 if you wish to discuss these comments. Sincerely, () Jc.ev- Ranjit S Gill, Ph< Chief, Planning and Toxics Section cc: Regional Board members State Clearinghouse JEU/sh17-truckee.dgp [Town of Truckee/General] I = Le4e•r c STATE OF CALIFORNIA—THE RESOURCES AGENCY PETE WILSON, Governor DEPARTMENT OF FISH AND GAME Air* NON 2 c •._; 2 NIMBUS ROAD, SUITE A �:1= KANCHO CORDOVA, CA 95670 - (916)(916) 358-2888 RECEIVED October 16, 1995 OCT 2 3 1995 TOWN OF TRUCKEE COMMUNITY DEVELOPMENT DEPT. Ms. Elizabeth Eddins Town Planner Town of Truckee Community Development Department 11570 Donner Pass Road Truckee, California 96161 Dear Ms. Eddins: The Department of Fish and Game (DFG) has reviewed the Town of Truckee Draft General Plan and Environmental Impact Report. This document is intended to guide growth within the incorporated area and sphere of influence of the Town of Truckee (19, 520 acres) , Nevada County. We remain concerned about the integrity of portions of the General Plan area with respect to use by wildlife as movement and habitat areas. The area designated in the Land Use Plan as OSR, RC/OS, and PUB running north of the Truckee Tahoe Airport to Interstate 80 has not been appropriately designated to ensure that this area will remain functional for wildlife use. We believe that this area provides the only opportunity within the General Plan area to assure animal movement along traditional wildlife corridors. The above designations allow land uses such as intense recreational and other public facilities and structures that will significantly impact use by wildlife. We have the following specific comments related to this and additional issues: 1 . Page 10, DR designation: Open Space is not adequately defined for this parcel to assure where or what can be 2 developed in the future. Clarification should assure that Open Space uses be confined to those consistent with maintenance of natural habitat conditions and that they are located in areas that assure continued animal movement and use. 2. Allowable use of the Prosser Village interchange has not been discussed, thus potentially affecting the ability of 3 the interchange area to continue to be used by wildlife as = an undercrossing along Interstate 80. This issue should be addressed and discussed. Ms. Elizabeth Eddins October 16, 1995 Page Two 3. Page 39, Conservation and Open Space Policy 1 .3: The Land Use Plan and this policy are clearly inconsistent based upon our evaluation of the potential uses as allowed under the current land use designations and plan omissions as they affect the ability of the site to function as wildlife habitat and a wildlife movement corridor. 4. Page 40, Conservation and Open Space Policy 1 . 3 : "Habitat for resident populations" is not by itself considered to be sensitive and should be deleted from this list. However, habitat for State-listed and Federally-listed plant and animal species should be added as sensitive. 5. Page 40, Conservation and Open Space Policy 1 .4: Protection of habitat may not be feasible or practical 'as the only means to mitigate impacts to sensitive resources and 4 severely limits options that may provide overall benefits to wildlife. At times, mitigation through manipulation of degraded or non-sensitive habitats would be preferred to that of protection. This type of option should be included within this policy to the extent that no net loss of sensitive habitat values results from such action. • Pursuant to Public Resources Code Sections 21092 and 21092.2, the DFG requests written notification of proposed actions and pending decisions regarding this project. Written notifications should be directed to this office. Thank you for the opportunity to review this project. If the DFG can be of further assistance, please contact Mr. Jeff Finn, Associate Wildlife Biologist, at (916) 477-0308 or Mr. David Zezulak, Acting Environmental Services Supervisor, at (916) 358-2919 . Sincerely, " ` L. Ryan Broddrick Regional Manager cc: Warden Perrault Department of Fish and Game Rancho Cordova, California g:t+e Th State of California-— THE RESOURCES AGENCY MEMORANDUM To • Project Coordinator Date: October 20, 1995 Resources Agency - ' Mr. Tony Lashbrook Town of Truckee ? Department of Community Development 11570 Donner Pass Road - Truckee, California 96161 From : Department of Conservation Office of Governmental and Environmental Relations Subject: Draft Environmental Impact Report (DEIR) for the Town of Truckee General Plan - SCH# 94092041 Dear Mr. Lashbrook: The Department of Conservation's Division of Mines and Geology (DMG) has reviewed Chapter 5, the Safety Element (pages 47 and 48) of the new General Plan for the newly incorporated Town of Truckee. We are concerned that the Safety Element does not foci's on the 1966 Truckee earthquake and the seismically active Dog Valley Fault Zone. We recommend the Safety Element include a fault map, an earthquake epicenter map, a table of earthquake ground motion expected from nearby faults, and a discussion of earthquake preparedness for residents of Truckee. Useful publications are available from the California State Seismic Safety Commission. We also recommend the bibliography be grouped according to specific elements. The Land Use element included a geologic map for the Town of Truckee sphere of influence. Section 65302(g) of the California Government Code requires city and county planning departments to directly contact the State Geologist for initial consultation regarding geologic hazards applicable to the Safety Element. This copy was forwarded to us through the State Clearinghouse, so we received it too late to make a detailed technical comment as required by statute. Please send your initial correspondence to Senior Engineering Geologist Robert H. Sydnor, California Division of Mines and Geology, 801 K Street, MS 12-31, Sacramento, California 95814; telephone (916) 323-4399. Mr. Sydnor will be able to provide you assistance in writing the geohazards section of the Safety Element. The Department appreciates the opportunity to comment o; he DEIR. If I can be of assistance, please contact me at (916) 445-8733. . 444Jas. R. Mars all 14 A g Assistant Director "e 0 flee of Governmental and Environmental Relations cc: R.H. Sydnor, Division of Mines and Geology • STATE OF CALIFORNIA-BUSINESS,TRANSPORTATION AND MOUSING AGENCY PETE WILSON,Governor ' DEPARTMENT OF TRANSPORTATION DISTRICT RECEIVEDIr • SRYSLLE.CA 96901 Telephone(916)741-4509 FAX(916)7415946 Te eohohe(916)741.4599 `, N O V 6 1995 November 2, 1995 TOWN OF TRUCKEE COMMUNITY DEVELOPMENT DEFT, GNEV098 03-NEV-80 PM 14/18 Town of Truckee General Plan DEIR SCH#94092041 Ms. Elizabeth Edins, Town Planner Town of Truckee Planning Division Community Development Department 11570 Donner Pass Road Truckee, CA 96161 Dear Ms. Edins: Thank you for the opportunity to review and comment on the above referenced document. COMMENTS: 1 4- Page 18 A more detailed list of freeway oriented commercial uses should be listed under 4- Land Use Policy 2.1, including factory stores and motels. Table 2.1 A note should be added to the first three segments listed for State Route (SR) 2 267 to indicate these segments are part of the existing SR 267 highway. These segments will become local arterials once the planned Truckee Bypass is constructed. The segment labeled as (N/O Tahoe Truckee Airport) would be more specific if it was labeled as (N/O SR 267 Bypass). Plates 1 and 4 3 In the area surrounding the south end of the SR 267 Truckee Bypass, a significant amount of commerciar land use is shown. Is this the Joerger Property which is referred to in the alternatives analyses? Although commercial development in this area could reduce trips from one side of town to the other, preparation of a specific plan for this area is recommended. It may be necessary to reduce the amount of commercial land use or to shift the majority of it to the west side of the planned route of the Truckee Bypass. This would reduce the amount of traffic which would need to cross the Bypass. The SR 267 highway in this area will only be accessible at the proposed signalized intersection. A fourth leg to this intersection is planned, and it should be designed as a collector or an arterial road which extends to the Airport Road to improve local circulation. With only the one proposed SR 267/local road intersection in this area,turning 6 volumes and through volumes on Friday afternoons and Saturdays could cause significant amounts of congestion. Providing local roads parallel to the highway would provide some alternative reliever routes. Ms. Elizabeth Edins, Town Planner November 2, 1995 Page 2 In addition,Caltrans recommends a road extension into Placer County to connect to the Gooseneck Ranch area. This road should be planned to provide local 1 circulation south of SR 267 which would allow a local connection to the development. Coordination with the Placer County Planning Department in the development of a specific plan will ensure better circulation and land use planning , in this area. Page 31 Circulation Policy 1.6 should be revised to specify what PM peak hour it is 8referring to. Traffic volumes in the Truckee area vary dramatically by day of the week and by season. Traffic impact studies conducted in off-peak seasons could significantly underestimate the impacts of proposed developments. — Technical Memorandum. Figure 2 It appears that the traffic volumes shown for the State Highways are based on Caltrans' 1991 Traffic Volumes publication. It should be labeled accordingly. The 1994 traffic volumes are significantly different from 1 1991, and we recommend that these volumes be updated. The volume of 12,500 shown for SR 267 should be relocated to a point just south of Commercial Row. > The reference to this volume in the first paragraph of Page 47 should also be revised accordingly. �/ L' I to T.M.. Figure 4 This figure should be labeled to indicate what year, season, and day of the week it is based on, and the source of these volumes. Page 54 The Traffic Analysis does not include sufficient information to determine its adequacy. Caltrans needs to review both the existing and future intersection analyses for all State Highway facilities. The Level of Service (LOS) threshold 1 I criteria used to determine the LOS for highway segments should also be listed, . with references cited. Figures similar to Figures 4 and 5 are also needed to show future volumes. The traffic model files should also be sent for Caltrans review. Page 58 The use of the weighted average method for unsignalized intersections is acceptable only if the LOS for the worst individual movements is also listed. It is 2. turning feasible to improve the.LOS for individual movements by adding I turning lanes, wide shoulders, or improving the intersection sight distance. These types of improvements should be considered before an individual movement LOS — of E or F is considered acceptable. ; , I Table 20 The trip generation rates shown do not appear to be consistent with the I i'E Trip Generation publication. As an example, the PM peak hour trip generation rate for 13 single-family detached housing, as shown on Page 261 of the LIE Manual, is 1.01 trips per unit. Table 20 lists it as 0.60 trips per unit. This discrepancy should be explained. Tables 20 and 21 Both of these tables combine "High School" trip rates with hotel or /1 motel trip rates, which is not logical. -._ Ms. Elizabeth Edins,Town Planner November 2, 1995 Page 3 Table 22 Label the first three segments listed for SR 267 as we commented on Table 2.1. S The segment listed as SR 89 (S/O Donner Pass Road) is not a State Highway. It should be listed as the Extension of SR 89. The SR 267 Bypass is planned to be constructed as an expressway, not a freeway, and its capacity should be evaluated accordingly. This table only considers the need for 2 or 4 through-lanes for the road segments. Providing a two-way left- turn lane, or left turn lanes with a raised median,can also significantly increase the capacity of a roadway. It is recommended that these road segments be reanalyzed to determine whether 3-lane or 5-lane sections would be more appropriate. { This table indicates that SR 89 north of I-80 would need to be widened to provide 4 through lanes unless the Low Growth Alternative is adopted, or the Planned Community in the area is eliminated. 1$ Local funding of all related highway improvements should be assumed. This table also indicates the need to widen the existing SR 267 to provide 4 through lanes through the downtown area. The feasibility of this future widening 19 project should be seriously considered before the land uses in this area are finalized. Table}23 This table appears to provide LOS results for intersections without assuming 3a any improvements. Future improvement needs should be estimated and their feasibility discussed. The future LOS with all feasible improvements in place should then be listed. If you have any questions or need assistance please contact Terri Pencovic, Inter Governmental Review/CEQA Coordinator,at(916)741-4199. Sincerely, E. A. "LIB" HARAUGHTY, Chief Office of Transportation Planning -Rural SENT B=.':* * * CFA * * * ; 10- 5-9 9:06AM ; CFA, 1 1 G562'i d52;w 2 r WILLIAM ABBOTT & ASSOCIATES ATTORNEYS AT LAW William W.Abbou 1-� {{-e r F Diane G. Xinderrnann October 4, 1995 VIA FACSIMILE Brita Tryggvi, Chairperson I Planning Commission Town of Truckee 11570 Donner Pass Road Truckee, CA 96161 Re: Public Review Draft General Plan and Environmental Impact Report, Volumes I and II - Town of Truckee Dear Planning Commission: r INT4ODUCTION These comments are being submitted on behalf of the Mountain Area Preservation Foundation ("MAPF"). These comments are based on all of the documents comprising the Public Review Draft General Plan ("General Plan") Volume I, and Environmental Impact Report and Technical Appendix Volume II ("DEIR" I1 collectively called "Project") prepared for the Town of Truckee (hereinafter "Town" or "Truckee"). This comment letter also repeats and incorporates by reference all other comments presented in conjunction with the California Environmental Quality Act ("CEQA") Public Resources Code section 21000 et seq., review relating to the Project. The comments herein address General Plan and CEQA issues. The General Plan discussion will address general requirements followed by specific requirements for ' each mandatory element. This will be followed by a discussion of CEQA compliance. While it is possible that the answers to some inquiries or omissions may be found in the Project documents, we believe this to be the exception. The MAF F remains poised to assist the Town in the resolution of each issue raised. I I I 455 Capital Mag Suite 702 • Sacramento, California 95814 • (916) 446.9595 • Fax No. (916J 446-2291 SENT 5Y:* * * CFA * * * ; 10- 6-95 ; 3:074 ; CFA-0 191653273894 3 Planning Commission October 4, 1995 Page 2 I. GENERAL PLAN ISSUE& A. STATEMDEVELOPMENT P LICIES: INCLUDING GOALS, OBJECTIVES, POLICIES AND IMPLEMENTATION MEASURES Government Code section 65302 states that "the General Plan shall consist of a statement of development policies and shall include a diagram or diagrams and text setting forth objectives, principles, standards and plan proposals." The General Plan Guidelines (1990, Governor's Office of Planning and Research) ("General Plan Guidelines"), provides examples of development policies and demonstrates the relationships among goals, objectives, policies and implementation measures. Essentially, a "development policy" is a General Plan statement that guides action. A "goal" is a direction setter, It is an ideal future end, condition or state related to the public health, safety or general welfare toward which planning and planning implementation measures are directed. An "objective" is a specific end, condition or state that is an intermediate step toward obtaining a goal. It should be achievable and when possible, measurable and time specific. A "policy" is a specific statement that guides decision-making. It indicates a clear commitment of the local legislative body. �. It is based on the General Plan's goals and objectives as well as the analysis of the data. An "implementation measure" is an action, procedure, program or technique that carries out General Plan policies. Each policy must have at least one corresponding implementation measure. The General Plan contains few identifiable implementation measures. All statements are designated "policies" and few constitute an action, procedure, program or technique that carries out General Plan policy. Land Use Policy 7.2 is one example of an implementation measure. In addition to violating the planning and zoning law mandates on general plan content, the paucity of implementation measures renders the DEIR legally inadequate insofar as mitigation measures are'required. Without any substance, the "policies" cannot mitigate the relevant impacts and the Town cannot make findings as to the significance of impacts after mitigation. Although specific statutory references to implementation programs are found under the open space, housing, and noise elements, each element should contain policies setting forth the commitment of the local legislative body to implement the Plan, and "each policy must have at least one corresponding implementation measure." (General Plan Guidelines, page 16.) Without implementation measures, there are no actions, procedures or programs driving the development policies. Examples of implementation measures are: (1) "The Town shall use tax increment financing to pay the cost of replacing old sidewalks in the redevelopment area." (2) "The Town shall adopt a specific plan for the industrial park." (3) "Areas designated by the land use • SENT BY:* * * CFA. * * * : 1 G- 5-95 CFA- 15165827869;# 4 Planning Commission I October 4, 1995 Page 3 Ielement for agriculture, shall be placed in the agricultural zone," The Guidelines should be referred to for the construction of appropriate language to create I implementation measures. Some examples of recommended implementation measures that fulfill the goals, objectives and policies of the General Plan, plus provide mitigation, are as follows: Land Use: (1) Policy 2.2: Change "is discouraged" to "is not allowed" to prevent subdivisions of estate type parcels. If the Town does not want sprawl-inducing,. inefficient parcel sizes, an unequivocal directive will demonstrate that intent. (2) In furtherance of retaining the Town character, open space designations shall be permanent. An implementation measure should provide: "The Town Council I shall not approve any development in areas designated for open space." Also, the Town shall designate as OSR or OSRC all parcels circumscribing Truckee. The RC- 10 10 and RC-5 designations on the Town's border are inconsistent with the Vision rStatement of retaining the small town character. (3) The Town Council shall establish a commercial limit line starting at the Old Mill site on the east, circling Donner Pass Road, PC-1 and a portion of Highway 89 South. Commercial development outside of this important infill area shall be limited to neighborhood serving commercial and will be restricted to 5 acres. (4) The Town Council shall only approve commercial development in Truckee which is phased with an emphasis placed on the Old Mill site and vacant parcels in the Downtown study area. Without phasing, none of the objectives for Downtown will be realized. These objectives include the development of Downtown before the development of outlying areas. (5) Residential development in Truckee will be phased so that no new subdivisions will be built on the edge of Town until 80 percent of Tahoe Donner and other infill areas are completed. (6) Policy 4.4 is an excellent example of a policy to preclude "strip" commercial development. However, to indicate a clear commitment of the legislative body, the clause "outside of freeway-oriented commercial areas" should be deleted. (7) Policy 7.2 is one example of an implementation measure. Also, requiring the creation of a Truckee Open Space District to manage open space lands and/or facilitate the transfer of open space lands to the Parks and Recreation District would provide a solid mechanism to carry out the policy and mitigate potential significant I SENT BY:* * * CFA * * * : 10- 6-55 : CFA-' 19165627669:# 5 • Planning Commission October 4, 1995 Page 4 impacts. Given the Park and Recreation District's workload and the reluctance of land trusts to actively manage open space areas, a new District could take care of these lands and the Town's creation of such a district would demonstrate its seriousness about protecting and maintaining open space now and in the future. (8) Regarding PC-2, implementation measures could provide that the Town Council will only approve phased commercial development on PC-2, with phasing not to take place before 70 percent of the Old Mill site is developed. Plus, commercial • uses in PC-2 shall be neighborhood serving only, and shall be limited to 5 acres, The land use element should define "destination recreational community." These modifications create measures that implement the goals to preserve existing natural features and values, protect the small town character and ensure design on a pedestrian scale. Circulatj; Policy 6.3 is a goal to encourage continued freight service on the Southern 1. Pacific rail lines. One implementation measure should direct the Town and Southern Pacific to adopt a plan to fund a second crossing on Spring Street to accommodate the traffic impacts from the continued freight service. Consgrvatian and Open Spy: Policy 3.2 requires an implementation measure such as: "The Town Council shall adopt a Town Reclamation Policy (enumerate performance standards) to ensure the full clean-up and restoration of mineral extraction sites and the transfer of those sites to open space/recreational uses once the resources have been extracted and reclamation is concluded." Policy 4.6 also requires implementation measures. For example: "Areas designated as open space shall be dedicated as permanently protected open space." B. CoNSIsTENa The "internal consistency" requirement stems from the language in the basic General Plan law mandating "that the General Plan and elements and parts thereof comprise an integrated, internally consistent and compatible statement of policies for the adopting agency." (Gov. Code § 65300.5.)' This standard has been interpreted and applied by the courts in a number of cases, and judicial decisions on the issue fall into two categories: (1) Cases where irreconcilable conflicts between General Plan 'Unless otherwise specified, all subsequent statutory references are to the Government Code. .SENT Br* * * CFA * * * MG- 6-35 9:09.AM CFA- 19i65527689;4 6 Planning Commission October 4, 1995 Page 5 rpolicies are present on the face of the Plan; and (2) cases where a minor amount of tension within or between elements exists, but is found acceptable within the context of the Plan. Examples of internal consistency deficiencies include, but are not limited to the following: (1) Land Use Policy 3.4 requires that sewers be provided for all new f residential subdivisions creating more than four lots. This seems to encourage rather than discourage the establishment of "estate type parcels" by providing an incentive to keep parcel sizes large enough for septic systems and is therefore inconsistent with ' Land Use Policy 2.2 which discourages subdivision of estate sized parcels. If estate type parcels are not discouraged, the sewer requirements will tip the balance toward larger (less than four) parcel sizes, (2) Circulation Policy 1.14 requires the construction of a secondary access road out of Tahoe Donner which connects to Highway 89 north and the Downtown area. To ensure consistency with the Guiding Principles requiring that new development be located around existing development, more emphasis should be placed • on Downtown and not 89 North, thereby ensuring that new commercial development is -' contiguous with existing development. (3) To be consistent with the General Plan's Vision Statement for pedestrian- "! oriented uses, and improve the look of Donner Pass Road, implementation measures should establish tree planting policies and techniques to conceal parking lots (i.e., Safeway) and encourage foot and bike traffic. Require tree planting and sidewalk 1 maintenance along Dormer Pass Road and in all new commercial/office development. (4) Conservation and Open Space Policy 5.2 ordains that all structures at the existing Interstate 80/Highway 267 north interchange be substantially screened from sight from the Highway. This is inconsistent with the Guiding Principles which provide that any new freeway-oriented commercial development shall be located at two (2) specific interchanges. (General Plan, page 7.) The Interstate 80/Highway 67 north interchange was not identified as one of the two interchanges slated for commercial development, C. LAND USE Government Code section 65302(a) outlines the required components of an adequate land use element. In essence, the land use element shall designate the general distribution and intensity of uses of the land for housing, business, industry, open space, education, public buildings and grounds, waste disposal facilities, and other categories of public and private uses. The General Plan's land use element does not comply with the statutory requirements. Examples of this deficiency include, but axe not limited to, the following: SENT by:* * * CFA * * * ; 1S— 6-55 ; 9:1QAM CFA-, 15165827835;# 7 Planning Commission October 4, 1995 Page 6 (1) The General Plan does not contain appropriate standards for population density. Camp v. County of Mendocino (1981) 123 Cal.App.3d 334. See also Twain Harte Homeowners Association. v, Tuolumne County (1982) 138 Cal.App.3d 664, in which the court defined "population density" as the actual number of people in any given area. (2) The General Plan Land Use Map does not designate all public facilities within the urban area owned and operated by the federal, state and local government agencies. All public facilities must also be addressed in the text of the General Plan, including their density and intensity, and the development, maintenance and siting of existing and projected public facilities, including buildings and infrastructure. (§ 65302(a) and General Plan Guidelines published by the Office of Planning and Research at pages 80-81.) (3) The General Plan does not contain appropriate quantifiable standards for building intensity, as required under Camp, supra. The General Plan must contain such building intensity standards for each land use designation defining the most intensive use that will be allowed under each designation. The case of Twain Harte Homeowners Association v, County of Tuolumne (1982) 138 Cal.App.3d 664, has provided the most complete interpretation of building intensity available to date. Intensities should be defined for each of the various land use categories in the General Plan, General land use captions such as "neighborhood commercial" and "service industrial" are insufficient measures of intensity by themselves. Intensity will be dependent upon the local Plan's context and may be based upon a combination of variables such as maximum dwelling units per acre, height and size limitations, and use restrictions. While the land use designation identifies the type of allowable uses, the building intensity standards will define the concentration of use. These standards of building intensity should define the most intensive use that will be allowed under each designation. Each intensity standard should include (1) permitted land uses and building types; and (2) concentration of use. Permitted land uses and building types is a qualitative measure of the uses that will be allowable in each land use designation. The concentration of use can be defined by one or more quantitative measures that relate directly to the amount of physical development to be allowed. Maximum dwelling units per acre is a good residential standard. Floor area ratio (the ratio of building floor area to the total site area) is a useful measure of commercial and industrial intensity. The dual standard of maximum lot coverage and maximum building height is suitable for agricultural, open space and recreational designations where development is being limited. The General Plan building intensity analysis and data fall short in terms of permitted land uses and building types, but does present fairly solid criteria for concentration of use. __J SENT 3Y *. * CFA * * Mo- 8-$5 : -, CFA-, 15185827885;; 8 Planning Commission October 4, 1995 Page 7 I (4) The General Plan should state whether the Town has adopted Nevada County's Hazardous Waste Management Plan. Legislation adopted in 1986 encourages county-city cooperation in the preparation of Hazardous Waste Management Plans pursuant to Health and Safety Code sections 23135 el sec. Hazardous Waste Management Plans are still required even though the CoIWMP may present overlapping information also required in the County Hazardous Waste Management Plan. For example, the CoIWMP must contain a Household Hazardous Waste Element (Pub. Resources Code §§ 41500-41510). Health and Safety Code section 25135,1(d)(4) provides that a Hazardous Waste Management Plan shall include directions for management of hazardous waste produced by businesses and households. Consequently, some repetition of information will occur. Final adoption of the Hazardous Waste Management Plan requires approval by the county supervisors, as well as the majority of the councils of the cities containing a majority of the county's population. Inter-governmental coordination should take place between the Town and Nevada County to prepare and submit this Plan for approval to the Department of I1 Health Services. (5) Under Policy 5,2 a 35,000 square foot limitation would be consistent with the Vision Statement for retaining the "small town flavor." (6) PC-1 Policy 4: Change "commercial serving local needs" to ,I "neighborhood serving commercial" and reduce the commercial acreage to 5 acres. It ■■ is unclear from the chart in the General Plan how much of the 20-acre "mixed use development" is actually commercial. Local serving commercial should be located on vacant land Downtown on Donner Pass Road, not in PC-1. This is the only way to ensure that the Teichert Planned Community-1 does not create an unacceptable traffic impact on Donner Pass Road, but instead fulfills the Vision Statement concerning pedestrian-oriented uses and a retention of small town character. (7) The language on page 15 of the land use element states, "Full build-out of the land uses for PC-1 would result in the need for four lanes on Donner Pass Road. To mitigate this, the Plan calls for a mix of land uses. However, the only way to ensure that people do not drive on Donner Pass Road to PC-1 to shop, is to limit the 1 commercial uses to neighborhood serving commercial only. This land use designation is consistent with the traffic studies and appropriately places the burden on the applicant to request a zone change. (6) PC-1 Policy 10: This is not an acceptable mitigation measure for the traffic on Donner Pass Road, As stated above, limiting the amount of commercial uses on PC-1 can ameliorate the decrease in level of service. 1 I .SENT BY:* * * CFA * * * ; 1Q— 5-95 ; 9: 12AM ; CFA— 191e5527559;# 9 • Planning Commission October 4, 1995 Page 8 D. CIRCULATION ELEMENT Section 65302(b) states that a circulation element shall consist of the general location and extent of existing and proposed (1) major thoroughfares, (2) transportation routes, (3) terminals, (4) all other local public utilities, and (5) all other local facilities, (6) all correlated with the land use element of the Plan. Issues such as "transportation routes" and "other local public utilities and facilities" cover a wide variety of topics including streets and highways, public transit routes, stops, and terminals for busses, railroads, etc., private bus routes and terminals, bicycle and pedestrian routes and facilities, truck routes, railroads, airports, parking facilities, etc. It also includes assessment of the adequacy and availability of existing community water, sewer, and drainage facilities, and the need for expansion and improvement, trends, and peak and average daily flows, assessment of current power plant development and potential future development, inventory and location of existing and proposed power plants, oil, and natural gas pipelines and major electric transmission lines and corridors. The circulation element of the General Plan is deficient in several areas including, but not limited to, the following: (1) The circulation element of the General Plan does not include goals, I objectives, policies, and implementation measures for each policy. Section 65302 mandates that the General Plan shall consist of a statement of development policies, and shall include diagrams or text setting forth objectives, principles, standards, plan proposals, and implementation measures. Without goals, objectives, policies, and implementation measures in place to govern circulation in the Project area, the circulation element is legally inadequate,' (2) The General Plan does not address the adequacy and availability of existing community water, sewer and drainage facilities and the need for expansion and improvements. It does not include existing and projected capacity of treatment plants and trunk lines, and trends in peak and average daily flows. Moreover, it does not include an inventory or location of existing and proposed power plants, oil and natural gas pipelines and major electric transmission lines and corridors. Finally, there is no powerplant development and potential future development. assessment of currentp There is no consideration of such factors as the demand for transmission facilities, the transport and storage of hazardous materials and local transportation impacts of current and, future power plant development. This comment regarding the lack of distinguishable goals, objectives, policies and implementation measures, is applicable to ail, of the mandatory General Plan elements in this proposed Plan. ___ 1 • SENT BY:* * * CFA * * * : 10- 6-55 ; 5: 13A.11 �''' CFA- 1$165527889;#10 OPlanning Commission October 4, 1995 Page 9 E. CORRILATLON The General Plan circulation element is not correlated with the uses projected by the land use element, nor does it plan for a level of service commensurate with projected development. Concerned Citizens of Calaveras County v. County of Calaveras (1985) 166 Cal.App.3d 90, 212 Cal.Rptr, 273. The importance of correlation between circulation and land uses cannot be overemphasized. It is a common allegation in lawsuits, in part because of its complexity and in part because many general plans do not include the explicit evidence of correlation recommended in the statute. Three California appellate cases have addressed the subject of correlation between the circulation and land use elements. These three cases are: Concerned Citizens of Calaveras County; Twain Harte Homeowners Association; and Camp. The Concerned Citizens court held that the Calaveras County General Plan land use and circulation elements failed the correlation test of Government Code section 63502(b). The court's decision relied upon the analysis of the correlation requirements set forth in Twain Harte. In that case, the County General Plan described the existing roadways and public transportation system, AIL but did not'project future circulation needs generated by the increase in county population. ,The court held that the correlation requirement dictates that the circulation element describe. "...the changes or increases in demands on the various roadways or transportation facilities of the county as a result of changes in uses of land which will or may result from implementation of the decision system and General Plan." Twain Harte, supra, at 701. Since the General Plan was silent on this issue, the court held that the correlation requirement of section 65302(b) had not been met. Except for some oblique objectives and implementation measures, the General Plan does not address the need for expansion of the circulation system, nor does it elucidate how new traffic generated by growth would be accommodated. In both cases discussed above, the courts' underlying concerns stressed the need for the local government to address, by way of specific proposals or objectives, a method for meeting the increased infrastructure demands anticipated from the projected population growth. In the Twain Harte and Calaveras County cases, the appellate courts required a three step analysis to demonstrate compliance with the correlation requirement. First, the General Plan must project the population growth anticipated over the time period of the General Plan. Second, the circulation element should analyze whether the existing road network is adequate for the new growth, and if not adequate, describe what is needed in light of additional growth. Third, the General Plan must explain how the local agency will either address the problems identified as a result of this evaluation of the circulation system (see Twain Harte, supra, 13$ Cal,App.3d at 701), or provide an objective or standard by which the population growth will be restricted 40 in the event that the circulation system is inadequate to handle future traffic. (Calaveras County, supra, 166 Cal,App.3d at 100-101.) SENT BY:* * * CFA * * * i1U- 6-95 + 9 i3AM I CFA- 19165B27689:#11 Planning Commission4111 October 4, 1995 Page 10 That the correlation requirement is a salient general plan feature not to be overlooked is evidenced by virtue of its extension to ill mandatory circulation element topics, and not only to traffic. Government Code section 65302(b) states that the General Plan shall include: "...a circulation element consisting of the general location and extent of existing and proposed major thoroughfares, transportation routes, terminals and other local public utilities and facilities, all correlated with the land use element of the plan." (Emphasis added.) Therefore, correlation extends not only to major thoroughfares and transportation routes, but also to the remaining portions of a legally valid circulation element, all of which must be closely, systematically and reciprocally related to the land use element. As discussed herein, none of the mandatory components were sufficiently addressed in the General Plan circulation element and correlated with the land use element. Consequently, the correlation requirement has not been satisfied. F. OPEN SPACE AND RECREATION Government Code section 65302(e) requires the General Plan to contain an open 1 space element drafted pursuant to section 65560. According to Government Code section 65560(b) "Open Space Land" is any parcel or areas of land designated in an open-space plan as any of the following: (1) Open space for the preservation of natural resources; (2) Open space use for the managed production of resources; (3) Open space for outdoor recreation; and (4) Open space for public health and safety. Unlike some of the other elements, the open space element must contain an action program consisting of specific programs, which the legislative body intends to pursue in implementing its open space plan. (Gov. Code § 65564.) By virtue of the Legislature's stated intent that open space resources be conserved wherever possible, the treatment of open space issues generally requires greater detail and analysis than other elements. (Gov. Code § 65562(a).) In this General Plan, the open space element was combined with a conservation element. Although the conservation and open space element identifies some areas for the preservation of natural resources, managed production of resources and outdoor recreation, it does not identify open space areas for public health and safety such as open space areas designed for fuel break and fuel reduction zones, helistops and fire access. Moreover, the inventory and analysis under each of the categories is lacking. • SENT BY:* * * CFA * * * :10- 6-95 : 9: 14A ' � CFA-, 19165827869:#12 Planning Commission October 4, 1995 Page 11 Guiding Principles in this element provide that "clustering" will be mandatory in new residential development on large parcels to create open space. The General Plan should define "clustering" and should define "larger parcels." Also, to reiterate earlier comments, there are no implementation measures to ensure that clustering will occur in the new residential development. As to the conservation component of this element, pursuant to section 65302(d), the General Plan shall include a conservation element "for the conservation, development and utilization of natural resources, including water and its hydraulic forces, forests, soils, rivers and other waters, harbors, fisheries, wildlife, minerals and other natural resources. That portion of the conservation element including waters, shall be developed in coordination with any county-wide water agency and with all districts and city agencies which have developed, served, controlled or conserved water for any purpose for the county or city for which the Plan is prepared." Although the conservation element overlaps provisions found in the open space, ( land use, safety and circulation elements, it differs from these elements in that it is almost exclusively oriented toward natural resources. Consequently, the conservation element should emphasize the conservation, development and utilization of specified resources, The General Plan analysis provides minimal identification and analysis for the conservation of specified resources, but fails to examine the development and utilization of the resources, For example, Goal 2 addresses protection and conservation of forest and range land resources, but provides no specific measures for development and utilization thereof. G. NOISE ELEMENT Pursuant to Government Code section 65302, the noise element shall identify and appraise noise problems in the community. It should analyze and quantify to the extent practicable, current and projected noise levels for all of the following sources: 1) highways and freeways; 2) primary arterials and major local streets; 3) passenger and freight online railroad operations and ground rapid transit systems; 4) commercial general aviation, heliport, helistop and other airport operations; 5) local industrial plants; and 6) other ground stationary noise sources identified by the local agencies as contributing to the community noise environment. The noise contours shall be used as a guide for establishing a pattern of land uses in the land use element that minimizes the exposure of community residents to excessive noises, The General Plan noise element does not appear to analyze, quantify or provide noise contours for all of the sources that are required by statute. The discussion in the General Plan briefly summarizes existing and future noise environments. However, the SENT BY:* * * CFA * * * ; 10- 5-95 ; 9:15AM : CFA- 19155827589;#15 Planning Commission October 4, 1995 Page 12 technical noise study appears to analyze and quantify only the existing noise environment and not the future noise environment for all of the statutorily-required sources. Of equal importance, the noise contours were not utilized as a guide for establishing a pattern of land use in the land use element that minimizes the exposure of community residents to excessive noise. H. SAFETY ELF,MENT The General Plan shall include a safety element for the protection of the community from any unreasonable risks associated with the effects of such hazards as seismically-induced surface rupture, landslides and other geologic hazards, flooding, and wildland and open fires. The safety element shall include mapping of various hazards and shall address various evacuation routes, peak load water supply requirements and minimum road widths and clearance around structures as those items relate to identified fire and geologic hazards. The safety element fails in that it does not address evacuation routes, peak load water supply requirements and minimum road widths and clearance around structures as those items relate to fire and geologic hazards. In particular, fire hazards would seem to be a predominant concern in Truckee. For example, on the risk of wildland fires there should be the identification and classification of the areas of varying fire hazard severity based on the degree of development, fuel loading (vegetation), weather and slope, accessibility to fire protection assistance (i.e., response time, availability of helistops, proximity of air tanker attack bases, etc.) historic data and other pertinent data. The safety element can also address hazardous material, spills, power failures and storm drainage. Of particular concern in the Downtown area is the Old Mill site which is the subject of controversy concerning soil contaminated with toxic substances. This is a crucial property with regard to Truckee's immediate growth. The safety element should include goals, objectives, policies and implementation measures to ascertain the remediation and development potentials on this site. I. HOUSING ELEMENT The statutory requirements for a legally supportable housing element are delineated in section 65583, which provides that the housing element shall consist of an identification and analysis of existing and projected housing needs and a statement of goals, policies, quantified objectives and scheduled programs for the preservation, improvement and development of housing. A clarification of existing and projected housing needs to build-out of the General Plan is also required. One apparent problem with the General Plan is that it lacks an estimate of the anticipated population growth to the end of the 20-year planning horizon. Although the General Plan is based on 20- SENT BY:* * * CFA * * * ; 10- 5-05 CFA-0 19155527669;414 Planning Commission October 4, 1995 Page 13 year growth projections, no further population estimates are provided. The housing • element states that the population of Truckee grew by 60.9 percent between 1980 and 1990. However, there does not appear to be any estimate of the percentage of population growth anticipated over the 20-year period to build-out of this General Plan. As with all other elements, there is a lack of distinguishable goals, objectives, policies and implementation measures. Also, clarification is requested on Housing Program 5.1.4, This Program appears capable of precluding some forms of new development. Clarification is required as to the intent of the Program and as to why 100 or more jobs is the standard for triggering a development agreement. It is understood that Truckee has a severe affordable housing deficit, and perhaps this Program should not apply only to commercial projects. Finally, the housing element should be submitted to the State of California Housing and Community Development Department for its review and comment prior to any approval of this element by the Town of Truckee. II. CEQA ISSUES INTRODUCTISIN The following comments on the DEIR underscore critical deficiencies in the- environmental documentation, and for the sake of brevity, provide only a few examples in those categories. The preparers of the EIR should review the CEQA statutory directives and California Code of Regulations, title 14 (hereinafter "Guidelines"), section 15126(a)the CEQA Guidelines, as well as any of a number of treatises available, to ensure that they have addressed all of the substantive requirements of an EIR. 2 MAPF's position is that the DEIR is deficient in all areas, to wit: 1) the Project description; 2) summary of impacts and mitigation measures; 3) description of the Project's environmental setting; 4) identification of significant impacts; 5) identification of mitigation measures to minimize significant impacts; 6) identification of unavoidable significant environmental effects; 7) alternatives; 8) significant irreversible changes; 9) growth-inducing impacts; and 10) cumulative impacts analysis. The correction of deficiencies noted in the General Plan will, to some extent improve the DEIR, but will not be sufficient to remedy all deficiencies. A. PROJEcT DESCRIPTIQN 3 An EIR's project description must include: 1) a detailed map and a regional map showing the location of the Project; 2) a statement of the objective sought by the proposed project; 3) a general description of the Project's technical and economic and SENT BY.* * * CFA * * * MO- 6-95 ; 9:23AM ; CFA- 19 :65627669;# 1 Planning Commission October 4, 1995 Page 14 environmental characteristics; and 4) a statement describing the intended uses of the EIR, including a list of the agencies expected to use the EIR in a list of approvals for which it will be used. CEQA Guidelines § 15124. The Project description in the DEIR is inadequate for the following reasons: 1) regional map showing the location of the Project is not provided; 2) a general 3 description of the Project's technical and economic and environmental characteristics is missing; and 3) a statement describing the intended uses of the EIR, including a list of the agencies expected to use the EIR in a list of approvals for which it will be used is also not provided. The Project description in the DEIR provides: "The Plan elements themselves in this document constitute the Project description." To the extent that the Plan elements do not contain the requirements set forth in CEQA Guidelines section 15124, the Project description is deficient. B. SIGNIFICANT ENVIRONMENTAL EFFECTS OF THE PROPOSED PROJECT The DEIR fails to fully identify and focus on the possible significant environmental impacts of the proposed Project as required pursuant to Public Resources Code section 21000(a). The analysis should identify both direct and indirect impacts as they occur, both in the short and long term, and should also discuss the environmental specifics of the affected area, the resources involved, and other aspects of the resource base such as water, soil, scenic quality and public services. (Guidelines §§ 15126(a) and 15143.) Examples of this deficiency include, but are not limited to, the following: (1) The DEIR does not adequately identify and focus on the possible significant environmental effects of the proposed Project on air quality. The study relied on selectively focuses only on intersection carbon monoxide concentrations (Table 6). The DEIR does not include a current description of the local and regional air quality environment in the vicinity of the Project as it exists before the commencement of the Project. By failing to discuss air quality of the affected area, the DEIR does not adequately identify the significant environmental impacts resulting from the Project. The DEIR, does note that policies to reduce air quality impacts are contained in the circulation anal conservation and open space elements. However; it dismisses these impacts by stating that the impacts are not mitigated to a less than significant level for s PM10 due to the existing severity of the problem. In the Mitigation Matrix, the EIR states that policies addressing impacts to air quality are found at Goal 11 in the conservation and open space element. This is inconsistent with the finding earlier in the document which provides that mitigation measures are only contained in the circulation element. i-- SENT BY;* * * CFA * * * ; 10- 6-95 ; 9;23AM" CFAs 191658276694 2 Planning Commission October 4, 1995 Page 15 Elsewhere, the DEIR also concludes that air quality could not be mitigated to a (, less than significant level because of existing air quality conditions. (General Plan, page 127.) - There is no data as to whether the California Clean Air Act of 1988 (the "Act") has identified Nevada County as being inspecific air basin such as the Mountain any p Counties Air Basin. Nor does it address whether Nevada County suffers from exceedence of maximum ozone levels as do many other upwind areas in the Mountain Counties Air Basin which have been required to adopt sufficient control measures to — attain specified ozone standards within the impacted areas. Appendix G of the CEQA Guidelines defines significant effects and concludes that a project will normally have a significant effect on the environment if it will violate any ambient air quality standards, contribute substantially to an existing or projected air quality violation, or expose sensitive receptors to substantial pollutant concentrations. (Guidelines, Appendix G(x).) g The DEIR's failure to identify the environmental specifics of the region's air quality, failure to identify and adequately mitigate the Project's significant environmental effects, and failure to investigate and note the mitigation requirements set forth by the State of California Air Resources Board, is violative of CEQA.. (See Kings County Farm Bureau, et al, v. City of Hanford (1990) 221 Cal,App.3d 692, 270 Cal.Rptr. 650, where the court rejected the lead agency's conclusion that because regional ozone levels were "already bad," the additions from the Project would be treated as minor.) Likewise, the Town of Truckee cannot trivialize the Project's impacts on air quality. The DEIR needs supplemental data on the levels of criteria pollutants and concrete mitigation to reduce the significant impacts to some degree. (2) Where appropriate, a DEIR should contain discussions of the economic and social impacts of the proposed project. CEQA Guidelines § 15131(a); see also Pub. Resources Code §§ 21100(c), 21151, 21080(e). A proposed project's incidental effects on public services and facilities, necessitates CEQA review where such effects are related to or caused by physical change. An EIR may trace a chain of' cause and 61 effect from a proposed decision on a project through anticipated economic or social changes resulting from the Project to physical changes caused in turn by the economic and social changes. The intermediate, economic and social changes need not be analyzed in any detail greater than necessary to trace the chain of cause and effect. The focus of the analysis shall be on the physical changes. CEQA Guidelines § 15131(a). Citizens for Sensible Development in Bishop Area v. County of Inyo (1985) 172 Cal.App.3d 151; 217 Ca1.Rptr. 893. In that case the court held that the lead agency should consider physical deterioration of the Downtown area to the extent that potential is demonstrated to be an indirect effect of the proposed shopping center. Note that this requirement to consider such secondary and indirect environmental ENT BY:* * * CFA * * * MO- 6-95 ; 9:24AM ; CFA-' i9165827009;4 3 Planning Commission October 4, 1995 Page 16 effects is mandatory. Here, the Town of Truckee should consider potential physical 1 deterioration of the Downtown area resulting from the proposed build-out of commercial uses of the General Plan, identify the significance of the impacts and provide mitigation. In addition, if a project's physical impact may cause economic and social consequences, the magnitude of the latter may be relevant in determining whether the physical impact is significant. Ultimately, the lead agency must consider economic, social and particularly housing factors together with technical and environmental factors in determining the feasibility of proposed mitigation measures to reduce or avoid significant effects identified in the EIR. For example, Land Use Policy 3.4 is ro evidently a mitigation measure to reduce impacts to services and infrastructure. However, there is no economic analysis as to how the sewer would be provided for all new residential subdivision creating more than four lots in all commercial uses. This comment also relates back to the lack of implementation measures in the General Plan. If this were a true implementation measure, it would identify the sources of funding or criteria for determining the sources of funding, and as a result, would demonstrate that the Town has considered economic factors in determining the feasibility of this proposed measure to reduce or avoid significant impacts. _ (3) General Plan Circulation Policy 1.6 provides that the Town's roadway - ;- system should maintain a minimum Level of Service D (LOS D) at the PM peak hour on all roadways and intersections. LOS D is considered by MAPF to be a significant effect which has not been properly identified or mitigated. The DEIR thoroughly identifies existing LOS at 15 intersections, but does not provide similar comparisons L I under the Project conditions. Instead of clearly estimating future LOS at the intersections, the document enumerates a host of "circulation network alternatives" and "land use alternatives" most of which do not comport with the alternatives to the Project identified elsewhere in the DEIR. In addition to the confusion engendered, these alternatives fail to identify the significant impacts to traffic created by build-out of the General Plan. C. MITIGATION P4orOSED TO MINIMIZE SIGNIFICANT EFFECT Public Resources Code section 21002 requires agencies to adopt feasible mitigation measures in order to substantially lessen or otherwise avoid significant adverse environmental impacts. CEQA Guidelines section 15370 defines mitigation as I'A a measure which: (a) avoids the impact altogether by not taking a certain action; (b) minimizes the impact by limiting the degree or magnitude; (c) rectifies the impact by repairing, rehabilitating or restoring; (d) reduces or eliminates the impact over time by preservation and maintenance operations; and (e) compensates for the impact by replacing or providing substitute resources or environments. There must be substantial evidence to support the approving agency's conclusion that mitigation measures will be _.I SENT BY:* * * CFA * * * :10- 6-95 ; 9:25AM CFA- 19165627889;# 4 4111 Planning Commission October 4, 1995 Page 17 effective. Laurel Heights Improvement Association of San Francisco v. Regents of the University of California (1988) 47 Ca1.3d 376, 407, 253 Cal.Rptr. 426. The CEQA Guidelines seem to be more oriented toward site specific analysis, so it is difficult to determine exactly what level of specificity is necessary in a general _. plan EIR. But, when approving projects that are general in nature, such as this General Plan, agencies are still obligated to develop and approve whatever general mitigation measures are feasible to lessen or avoid the Project's significant impacts. li. The Town cannot defer the obligation to formulate and adopt general mitigation measures or performance criteria until a specific development project is proposed. Citizens for Quality Growth v. City of Mt. Shasta (1988) 198 Cal.App.3d 433, 243 Cal.Rptr. 727, 731; Christward Ministry v. Superior Court (1986) 184 Cal.App.3d 180, 193-195, 228 Cal.Rptr. 868, 874-877, The deferral of environmental assessment until after project approval violates CEQA's policy that impacts must be identified before project momentum reduces or eliminates the agency's flexibility to subsequently change its course of action. ..1 Ultimately, the absence of a sound analysis of impacts and mitigation measures ' prevents the Town from being able to make findings required under CEQA Guidelines section 15091. Section 15091 states: ii f'` (a) no public agency shall approve or carry out a project for which an EIR has. been completed which identifies one or more significant environmental effects of the Project unless the public agency makes one or more written findings for each of those significant effects accompanied by a brief explanation of the rationale for each finding. The possible findings are: 13 (1) Changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effect as identified in the DEIR. (2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. (3) Specific economic, social or other considerations make infeasible mitigation measures or project alternatives identified in the DEIR. (b) The findings required by subsection (a) shall be supported by substantial evidence in the record. SENT by;* * * CFA * * * ; 10- 0-95 ; 5:26AM ; CFA, 19185827889;# 5 Planning Commission October 4, 1995 Page 18 (c) The finding in subsection (a)(2) shall not be made if the agency making 13 the finding has concurrent jurisdiction with another agency to deal with identified feasible mitigation measures or alternatives. At the general plan stage, practicality prohibits devising precise mitigation measures early in the planning process. However, the Town can still commit itself to eventually devising measures that will satisfy specific performance criteria articulated at the time of the Project approval. Where future action to carry a project forward is contingent on devising a means to satisfy such criteria, the Town should be able to rely on its prior commitment as evidence that significant impacts will in fact be mitigated. Thus, at some point, the DEIR should state that when projects come along in the future where the General Plan DEIR mitigation measures are not enough, the Town will then require project specific EIRs and mitigation measures. Examples of deficiencies in this area include, but are not limited to, the following; The impacts and mitigation matrix provides that all policies under Conservation and Open Space Goal 11 will mitigate air quality impacts. However, these are true policies in that they provide no measures for implementation, and do not establish any performance criteria. For example, Policy 11.5 is actually more of an objective than a policy, implementation measure or mitigation measure. A real mitigation/implementation measure would be: "The Town shall install left-turn lanes at arterial intersections with peak hour levels of service worse than C. All new development causing traffic impacts shall be required to fund the improvements at a pro rata share." Instead, the eight "policies" which allegedly are intended to mitigate air quality impacts are nothing more than goals or objectives instead of mitigation or implementation measures. D. DEFER. QE,.Nj _r1, ATION With narrow exception, determinations that impacts have been reduced to less than significant cannot be based on the presumed success of mitigation measures that have not been formulated at the time of project approval. Kings County, supra, and Sundstrom v. County of Mendocino (1988) 202 Cal.App.3d 296, 248 Cal.Rptr. 352. In those cases, the courts disapproved of mitigation measures requiring post-approval i4 formulation of specific plans. "The CEQA process demands that mitigation measures be timely set forth, that environmental information be complete and relevant, and that environmental decisions be made in an accountable arena." (Sundstrom, supra.) Deficiencies set forth in the current document include, but are not limited to, the following: The mitigation matrix provides that Land Use Policy 4.4 is capable of reducing to less than significant the potential non-contiguous development patterns and urban/suburban sprawl that could be accommodated by the General Plan. However, ti 5ENT BY:* * * CFA * * * : 10- 6-95 ; 9:27AM CFA-' 191658276894 6 Planning Commission October 4, 1995 Page 19 that Policy lacks any criteria for the standards that would preclude "strip" commercial development outside of freeway-oriented commercial areas. A mandate that the Town shall adopt a zoning ordinance restricting strip development in specific locations (by 15 defining "freeway-oriented") would provide the criteria that is not provided in the current directive to "establish standards which preclude..." With the nebulous existing language, the Town cannot conclude that the impact would be mitigated to less than significant because it is deferring mitigation to the future. E. CIJMULAT,T'YE IMPACTS Cumulative impacts are defined as "two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts." (Guidelines § 15355; see also Pub. Resources Code § 21083(b).) The individual effects may be changes resulting from a single project or a number of separate projects. (Guidelines § 15355(a).) A DEIR must discuss cumulative impacts whether they are deemed significant or not. (Guidelines § 15130(a).) Where deemed not significant, the document must explain the basis for that conclusion of non-significance. Citizens to Preserve the Ojai v. County of Ventura (1985) 176 Cal.App.3d 421, 432, 222 Cal.Rptr. 247, 253. In essence, a legally adequate cumulative impact analysis is an analysis of a particular project viewed over time and in conjunction with other related past, present, and reasonably foreseeable, +� probable future projects whose impacts might compound or interrelate with those of the Project at hand. Section 15130 outlines the minimum requirements for an adequate discussion of cumulative impacts. They are as follows: "1. Either: (A) A list of past, present and reasonably anticipated future projects including related or cumulative impacts, including those projects outside the control of'the agency, (the "list method:] or (B) A summary of projections contained in an adopted General Plan or related planning document which is designed to evaluate regional or area wide conditions. ["Summary of Projections Method"]... 2. A summary of the expected environmental effects to be produced by those projects with specific reference to additional information stating where that information is available, and SENT BY:* * * CFA * * * ;10- 6-95 ; 9:27AM ; CFA-, 19165827889;# 7 Planning Commission October 4, 1995 Page 20 3. A reasonable analysis of the cumulative impacts of the relevant projects. I An EIR shall examine reasonable options from mitigation or avoiding any significant cumulative impacts for proposed project." Unless cumulative impacts are analyzed, agencies will commit resources to a course of action before understanding the resulting long-term impacts. There is virtually no discussion of cumulative impacts in the DEIR. At page 3, there is a brief discussion of development which may occur south of the Town and east of the Town. The discussion concludes that "the General Plan should include policies which address the need to coordinate which these jurisdictions to address such uses." At page 7 there } are exactly two sentences regarding the loss of mineral resources that could contribute to cumulative impacts on mineral resources and development in areas of visual resources which could contribute to cumulative effects on visual resources. Finally, there are exactly two sentences discussing cumulative impacts under "Noise" at page 10 of the DEIR. This glossing over a statutorily mandated component of a DEIR renders the document legally deficient. Moreover, contrary to what the document says, the General Plan does not appear to include any policies which address cumulative impacts —` or mitigation measures to reduce cumulative impacts. F. ALTERNATIY S The CEQA requirement to set forth project alternatives was not satisfied in the -` Project's DEIR, The DEIR must describe a reasonable range of alternatives and must evaluate the comparative merits of each alternative, (Guidelines § 15126(d), Pub. Resources Code § 21100(d).) 19 Section 15126(d) of the Guidelines provides as follows: "(d) Alternatives to the Proposed Action. Describe a range of reasonable alternatives to the Project, or to the location of the Project, which could feasibly attain the basic objectives of the Project, and evaluate the comparative merits of the alternatives. (1) If there is a specific proposed project or a preferred alternative, explain why the other alternatives were rejected in favor of the proposal if they were considered in developing the proposal. (2) The specific alternative of "no project" shall also be evaluated along with the impact. If the environmentally superior alternative is the "no project" alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives. 1_ SENT BY:* * * CFA * * * ;10- 6-95 ; 9:28AM : CFA-, 19165827889;# 8 Planning Commission October 4, 1995 Page 21 (3) The discussion of alternatives shall focus on alternatives capable of eliminating any significant adverse environmental effects or reducing them to a level of insignificance, even if these impede would to some degree the attainment of the $ Project objectives, or would be more costly. (4) If an alternative would cause one or more significant effects in addition to those that would be caused by the Project as proposed, the significant effects of the alternative shall be discussed but in less detail than the significant effects of the Project as proposed." The DEIR lists the standard range of alternatives frequently used in General Plan EIRs. Nevertheless, the traffic and circulation discussions interpose a 161 combination of additional land use and circulation network alternatives thereby creating confusion as to which alternatives are actually being considered. It is therefore impossible t© ascertain which alternatives are actually being considered by the lead agency. As to the alternatives listed, their comparative merits are not evaluated. For example, the discussion should have characterized the nature of the impacts under all relevant categories: i.e., biotic resources, traffic, public services, air quality, etc., and evaluated the comparative increases or decreases in impacts when compared to the Project in the other alternatives. Such an analysis is lacking. Although the discussion of alternatives need not be exhaustive, the key issue is whether the selection and the 20 discussion of alternatives fosters informed decision-making and informed public participation. As it stands, the public cannot determine which project alternatives are being considered, Moreover, the absence of any discussion of their environmental impacts and the comparative merits of each, make it impossible to prepare findings to provide the requisite rejection of the alternatives as infeasible, with supporting evidence, Further, once the other sections of the DEIR have been amended to identify significant impacts as discussed herein, the discussion of alternatives will also have to be amended. G. 3ROw'TH INDUCING IMPAC.LS The DEIR must discuss the ways in which the proposed Project could foster 2 economic or population growth, or the construction of additional housing either directly or indirectly in the surrounding environment. The analysis must discuss project characteristics that may encourage and facilitate activities that either individually or cumulatively will affect the environment. (Guidelines § 15126(g), and Pub. Resources Code § 21200(g).) The Project DEIR is deficient in its analysis of growth inducing impacts. SENT, BY:* * * CFA * * * ; 10- 6-95 ; 9:29AM : CFA-0 191666276694 9 Planning Commission October 4, 1995 Page 22 Pages 4 and 5 of the DEIR discusses growth inducing impacts but does not clarify how the General Plan could foster economic or population growth as is required 21 by CEQA. Also the analysis does not substantively cover those project characteristics that will encourage and facilitate activities that either individually or cumulatively will adversely effect the environment. There is also no coverage of how population increases may impose new burdens on existing community services and facilities. As stated earlier, the General Plan fails to estimate population increases. Finally, there is no identification of growth inducing 22 impacts as either significant or less than significant, nor have any mitigation measures for the impacts been identified. r H. C LUSION Based on the foregoing analysis and for the additional reasons submitted in other comments prepared and included within the administrative record, we request 23 that the DEIR and General Plan be modified consistent with the comments provided herein. Further, the MAPF remains committed to working with the Town to assist in the completion of these or other recommended modifications, — Very truly yours, 0 4114.06 , , Diane G. Kindermann DGK:yb 9510.6.2 1 ' WILLIAM ABBOTT & ASSOCIATES ATTORNEYS AT LAW William W.Abbott r Diane G.Kindennann October 10, 1995 VIA FACSIMILE Brita Tryggvi, Chairperson Planning Commission Town of Truckee 11570 Donner Pass Road Truckee, CA 96161 Re: Public Review Draft General Plan and Environmental Impact Report, Volumes I and II - Town of Truckee Dear Planning Commission: On behalf of the Mountain Area Preservation Foundation ("MAPF"), I am submitting the following comments on the Draft General Plan ("General Plan") and Environmental Impact Report ("EIR") for the Town of Truckee, to supplement and be read in conjunction with the October 4, 1995 letter from the MAPF. Land Use Policy 5.2: The first comment references Land Use Policy 5.2 insofar as it creates an "exception" to a given size requirement for single retail commercial use buildings. The MAPF is opposed to any exception to the maximum size limit for a single retail commercial use of 35,000 square feet. Larger sized retail uses would be inconsistent with such Vision Statements as enhancing Truckee's small town flavor, ensuring development that is pedestrian-oriented, and safeguarding the natural environment. If such exception will not be deleted, in the alternative, the policy should be rewritten to enunciate performance criteria and include corresponding implementation measures. Although a specific plan can be an appropriate tool to direct all facets of future development, the Draft General Plan provides no performance criteria for the specific plan. For example, in addition to the statutory requirements, the specific plan should address economic impacts, (including a market analysis), community design, architectural and landscaping standards. 455 Capitol Mali Suite 702 • Sacramento, California 95814 • (916)446-9595 • Fax No. (916)446-2291 Planning Commission October 10, 1995 Page 2 The Governor's Office of Planning and Research encourages local jurisdictions to adopt local specific plan guidelines. Assuming that the Town of Truckee does not have any 1 such guidelines in place, the need for criteria is magnified. Lastly, there is no foundation for evolution of a specific plan since a specific plan is intended to implement the goals, objectives and policies of a general plan, and the General Plan is deficient in these areas. Land Use Policy 3.5: Second, Land Use Policy 3.5 forbids discretionary development resulting in a net increase in traffic south of the Truckee River until such time as the Highway 267 Bypass is constructed. The MAPF believes that discretionary development north of the Truckee River should be prohibited as well. As discussed in the comment letter dated October 4, 1995, implementation measures are needed to ensure that these objectives are fulfilled. Circulation Element: .3 The MAPF also notes that there are no goals, objectives, policies or implementation measures in the Circulation Element addressing the proposed Highway 267 Bypass. Corrections: The final comments are corrections to the October 4, 1995 letter. Specifically, at page 1 5, Comment (4) pertaining to Conservation and Open Space Policy 5.2, both roadway references should be: "Interstate 80/Highway 89 north." Another correction is at page 22, paragraph 1: the word "effect" in the last sentence should be "affect." Conclusion: 5 Based on the foregoing, we request that the DEIR and General Plan be modified consistent with the comments herein. The MAPF remains committed to working with the Town to assist in the finalizing of the EIR and General Plan. Very truly yours, ati-44.) Diane G. Kindermann DGK:yb cc: Joshua Susman Mountain Area Preservation Foundation 9510.28.2 OCT 12 '95 15:% WILLIAM ABBOTT & ASSOCIATES , P.2/3 WILLIAM ABBOTT & ASSOCIATES ATTORNEYS AT LAW William W.Abbott Diane G. Kineermann October 12, 1995 VIA FACSIMILE Brita Tryggvi, Chairperson Planning Commission Town of Truckee 11570 Dormer Pass Road Truckee, CA 96161 Re: Public Review Draft General Plan and Environmental Impact Report, Volumes I and Ii - Town of Truckee Dear Planning Commissioners: These comments are being submitted on behalf of the Mountain Area Preservation Foundation ("MAPF"). These comments are based on all of the documents comprising the Public Review Draft General Plan ("General Plan") Volume I, and Environmental Impact Report and Technical Appendix Volume II ("DEIR" collectively called "Project") prepared for the Town of Truckee (hereinafter "Town" or "Truckee"). This comment letter also repeats and incorporates by reference all other comments presented in conjunction with the California Environmental Quality Act ("CEQA"), Public Resources Code section 21000 et seq., review relating to the Project. It is MAPF's understanding that new information not formerly available to the Town and the general public was presented by the Hopkins Family Trust ("Proponent") to the Planning Commission at the October 11, 1995, continued hearing on the Draft General Plan and DEIR. Proposed changes to the General Plan were submitted by the Proponent of PC-2, a mixed use project on 750 acres at the intersection of Highway 89, north of Interstate 80. 455 Capitol,Mal4 Suite 702 • Sacramento, California 95814 • (916)446-9595 • Fax No. (916)446-2291 OCT 12 '95 15:36 WILLIAM ABBOTT & ASSOCIATES P.3/3 Planning Commissioners October 12, 1995 Page 2 It is our understanding that the Proponent desires increases in square footage for the Regional/Local Commercial and Office component and the Commercial Recreational designation for the PC-2 project. The MAPF objects to these requested increases. The proposed square footage deviates by nearly 50% from the build-out assumptions on which the General Plan and supporting the EIR were based. Amendments to both documents would be required if the Town approves the 1 proposed increases. Moreover, recirculation of the EIR would be necessary pursuant to Public Resources Code section 21092.1, which requires recirculation where, subsequent to public review and interagency consultation, but prior to final certification, the lead !_ agency adds "significant new information" to the EIR. Absent the Town's acceptance of the increases recommended for the PC-2 project, recirculation may still be necessary in light of the changes requested by the MAPF and other members of the public. The MAPF will be submitting detailed objections to both the Planning Commission and the Town Council when it receives complete information on the Proponent's specific proposals. Thank you for your consideration of this general comment letter. Very truly yours, Diane G. Kindermann DGK:yb cc: Josh Susman (via,facsimile) T. To: Truckee Town Planning Commission /(/. Fr: Bob Johnston ph 582-0700 Re: Comments on the DEIR within the Staff Draft General Plan (Aug. 29, 1995) October 9, 1995 Please excuse my late response. I just moved my office and it was difficult to reassemble all the papers and files. I have read the Plan and DEIR, Appendix, and Fiscal Analy- sis. I attended most of the staff briefing meeting in September. I cannot make any of the Commission meetings in early October. I may make additional comments, as I find out more about the Plan. In general the DEIR is very minimal and will not survive legal challenge. Background information is clearly not adequate for the reader to independently evaluate impacts. The mitigation I measures are often missing (air quality, traffic) and are often not quantified or are defered to the future without quantified standards. The assertion that impacts have been reduced to less than significant is not documented. 1. Wildlife impacts. There seems to be no growth phasing, that is all owners can come in and apply after adoption. Residential is overallocated about 30%, to permit choice of lots, etc. This is too much, as only about 10 years' worth of land is needed, at any one time, to prevent land price rises. Putting it another way, we have 80% overdesignation for the first 10-year period. I suggest no lot splits or subdivisions on the edge for about 10 years as a mitigation measure. Reason 1: when the citizens freak out over traffic iri a few years., we will have some growth to pullback with and not sprawl. Otherwise, a slow-growth initiative will have to phase building permits in the sprawled subdivisions, an undesirable choice. Reason 2: We cannot meaningfully argue with the County to not permit projects beyond our limits, if we are not phasing growth. Make the phasing a mitigation measure for wildlife and fiscal impacts, to lock it in. 2. Buildings of historic significance. There seems to be no phasing of commercial development. This is a serious omission in that Hopkins will go first and the Mill Site will be dead for at least 10 years, due to proximity. I suggest holding Hopkins until some percentage of the downtown commercial growth occurs. This mitigation measure will help maintain the historic buildings on Commercial Row in profitable uses. ,j 3 . Wildlife impacts. Make it clear that RC/OS is permanent, not a "�` holding zone. 4 . Wildlife and other impacts. In RC/OS, RC-5, RC-10, and OSR, 5 require field studies of physical and biological environmental constraints before subdivision design begins. 1 5. The Plan shows aircraft noise over the Mill Site in the fu- ture. Can the airport reroute flight paths as a mitigation meas- ure? 6 . The traffic modeling may understate local street loadings due to traffic from Tahoe and Martis . Assuming constant diversion rates to local (Truckee) destinations may not be realistic, } because as Truckee grows a higher portion of through travelers may stop in Town for something. Also, the assumption of a con- stant residential vacancy rate may also understate local trip generation, as many second-home communities evolve toward a higher percentage of first homes. I would investigate these assumptions and perhaps add a risk factor to these local street loadings. 7. In Circulation Policy 4.1, traffic flow improvements and flextime are not transportation control measures . Both of these policies add to total travel and emissions. It is doubtful that ... they even improve LOS, in the long term. Delete them. 8. There does not appear to be an air quality mitigation program for residential stoves and for local auto traffic. I would re- quire fees for new residential units and use the funds for volun- tary stove upgrades and buyouts in existing units. In addition, the Town should tighten its new construction standard for stoves to roughly the Washoe Co. one of 1.0 gm/hr. HC, which allows a few types of pellet stoves and many gas log heaters. Third, the resale retrofit ordinance should be committed to. All three of these measures must be included in the Plan and EIR. For traffic, I would levy a new construction fee in propor- tion to vehicle-miles per day projected for each type and loca- tion of residential and commercial/industrial unit. These funds could be used for street sweeping and transit programs. This fee could be replaced by a local fuel tax of equal or greater amount _ per year, if we can get such a bill written and approved. The Bay Area has such a bill in this year. All of these policies seem feasible as mitigation measures and are, therefore, required to - be adopted. 9. There appears to be a full concurrency services requirement for all new developments. I would make this policy more explicit and apply it to nonresidential , as well as residential, develop- ments. Mitigation measure 2 .1 needs to be elaborated and made quantifiable (LOS D) . The level of service standard should apply O to intersections, as well as roadways. I would also limit inter- section lane totals, not just roadway travel lane totals. Other- wise, we will get lots of cheating with extended turn lanes and pockets that become center turn lanes and new curb lanes. Small town character can be ruined by turn lanes at intersections and by traffic lights. The plan seems to allow 32-lane intersections (with left turn pockets and right turn lanes) . 2 0CA- Irl , IetaS RECEIVED • Icy —r(t) cI� te (.1vs; � ( avnci OCT 1 9' 1995 TOWN OF TRUCKEE 5 a �r'v cl4 ze ►'e 5 c CLP.KIT T h a COMMUNITY DE1-eAA; T DEPT. orn t -r1-5 Drift' E 12 e "eelerc- pa -- = e o n c u e- rn o 5 t � p e zt I e r 5 c'-t- © C} ►0 ?Jan ninc Carnal crn meE.' 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