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1 <br /> <br />March 4, 2013 <br />Ms. Denyelle Nishimori, Senior Planner <br />Town of Truckee Community Development Department <br />10183 Truckee Airport Road <br />Truckee, CA 96161 <br /> <br />Comment on 2012 Draft Environmental Impact Report for Canyon Springs Subdivision, Chapter 4.7, <br />Greenhouse Gases <br />Dear Ms. Nishimori: <br />The Town of Truckee takes deserved pride in its snow-capped mountains. Skiing and other <br />snow sports are woven into the community’s environment, history and identity. The local economy <br />depends on snowy winters to attract commerce and generate income. The Sierra Sun succinctly <br />captured the point recently with a headline proclaiming there is “No Business Like Snow Business.” <br />Given Truckee’s dependence on snowfall, it is surprising to see a draft Environmental Impact <br />Report (EIR) for the Canyon Springs Subdivision that is so incoherent and defective in its analysis and <br />conclusions regarding the development’s projected emissions of greenhouse gases (GHG). These <br />emissions contribute to the accelerating rate of global warming. Climate change will cause Truckee to <br />experience reduced snowfall and snowpack, as well as an increased risk of catastrophic wildfires, and a <br />higher probability of extreme weather events. <br />Because global warming poses such a threat to Truckee’s environment, identity and economy, <br />the Town needs to take it seriously and act accordingly. The draft EIR for the Canyon Springs <br />development does neither. It also violates multiple regulations under the California Environmental <br />Quality Act (CEQA). <br /> One of the draft EIR’s deficiencies is its failure to describe the significant environmental hazards <br />of increased GHG emissions on the proposed development. The draft EIR merely refers to the “global <br />climate setting” with passing references to adverse effects on the State as a whole. It describes impacts <br />that will not affect Truckee and fails to address those that will. The only reference to the reduced Sierra <br />Nevada snowpack concerns the broad threat to California’s water-storage systems.1 The draft EIR <br />appears to be a one-size fits-all approach to environmental review. <br />The draft EIR needs to analyze the short and long term effects of increased GHG emissions on <br />snowpack volume and duration in the greater Truckee area, the increased risk of catastrophic wildfires, <br />and the types of extreme weather that will affect the prospective residents of the proposed <br />development and the other residents of the Truckee community.2 The one-size fits-all approach is <br />inadequate. <br />Under CEQA, the Town must also determine whether the development’s GHG emissions will <br />have a significant impact on the environment.3 If the emissions are significant, mitigation is required.4 <br />One factor the Town must consider is “[w]hether the project emissions exceed a threshold of <br />significance that the lead agency determines applies to the project.”5