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required are contradictory to the CDFW recommendations (pg. 4.4 -41). This whole area of the <br />project needs to be re- evaluated in the DEIR and changes made to eliminate these impacts. <br />3. The RDEIR states, "The project could indirectly impact these wetlands through <br />modification of the hydrology that supports these areas ", (pg. 4.4 -42, threshold c). <br />Modification of the hydrology could impact the Truckee River Watershed that conservation <br />groups are working so hard to protect. Water from the site flows to the Glenshire Pond & <br />Truckee River ( "tributary to the Truckee River", pg. 4.4 -35). There is already concern that the <br />adjacent Elkhorn Ridge housing development, with inadequate mitigation, has resulted in <br />erosion and deteriorating water quality in the Glenshire Pond. <br />The Canyon Springs impacts on and eutrophication of the Glenshire Pond need to be studied <br />and addressed in the DEIR. How project effects would be assessed, before and after <br />development, needs to be established. Once development occurs, without adequate pre - project <br />and ongoing regulation and monitoring, it is impossible to prove blame for future impacts. This <br />is serious as deterioration of the pond can cause damages to the Glenshire- Devonshire HOA, <br />which would need to be indemnified from this liability. <br />Anything leading to the deterioration of the Glenshire Pond, affecting its role as a major scenic, <br />recreational, and aesthetic resource in the neighborhood is also a serious matter. In addition to <br />the obvious, it also conflicts directly with the TOTGP Goal COS -2 ( RDEIR Table 4.4 -1, pg. <br />4.4 -5, TOTGP Goal CC -2). <br />The RDEIR needs to be revised to include analysis as to how the hydrology will be modified, <br />what the impacts are and how to mitigate them. Just saying that modifications to surface <br />hydrology are "insignificant" and no mitigation is required is invalid without more study and <br />documentation in light of the initial statement (above in bold). <br />4. Along the same lines, the TOTGP policy pertaining to Biological Resources, Goal LU -4, <br />P4.5 requires "new infrastructure and development to be designed and built to manage storm <br />water runoff and to minimize or eliminate harmful impacts to property prone to flooding, water <br />quality, and riparian, wetland and meadow habitats ". The DEIR needs to include a <br />comprehensive drainage plan for the whole project (not just limited to impervious surfaces) to <br />mitigate impacts associated with runoff from yards and trails and flooding on water quality and <br />on riparian, wetland, and meadow habitats, based on appropriate analysis. Additionally pg. 2 -3 <br />of the RDEIR states that the HOA will be responsible for maintenance of drainage. How can it <br />be assured that they will actually be able to do that through the various phases of the 20 -plus <br />year construction period and after build -out, when there may only be small numbers of actual <br />home - owners in the association at times, or if the HOA becomes nonviable? <br />Biological Resources: Effects on the Loyalton- Truckee Deer Herd <br />Items in the report regarding negative impact on the deer herd are conflicting. <br />2 <br />Pamela Eisele <br />