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16173 Lancaster Place <br />Truckee, CA 96161 <br />March 4, 2013 <br /> <br />Ms. Denyelle Nishimori <br />Town of Truckee <br />10183 Truckee Airport Road <br />Truckee, CA 96161 <br /> <br />Subject: Canyon Springs Draft EIR December 2012 <br /> <br />Dear Ms. Nishimori, <br /> <br />I appreciate the opportunity to comment on the DEIR referenced above. <br />I have worked in the design and environmental review of development projects, and in performing <br />biological consulting services, since 1988. A summary of relevant expertise is included in Attachment 1 <br />to this letter. My experience with applicants, planners, and engineers over the years convinces me that <br />an environmentally sound project whose impacts could be mitigated to less-than-significant levels <br />might possibly have been designed for the Canyon Springs site. However, neither the present Canyon <br />Springs application nor any of the DEIR alternatives are that project. For a project of 185 parcels, the <br />planners have provided a layout that minimizes road lengths, maximizes the ratio of open space to <br />development area for that many units, and minimizes impact in some sensitive areas. However, <br />significant impacts would still result, not all of which are disclosed in the DEIR. <br />No  Public  Hearing   <br />To my recollection, in my experience with multiple EIRs in the 25 years from 1988 to the present), the <br />decision makers of the lead agency have always held a public hearing on the DEIR. This is such a <br />consistent and customary practice that I was surprised to find that it is not required by CEQA guidelines. <br />The Town of Truckee Planning Commission itself held just such a hearing for the last Canyon Springs <br />DEIR, in 2007, and held three public hearings on the Railyard Master Plan DEIR in 2009. Given how <br />unusual it is not to have a DEIR hearing, and that no explanation of this change from former Town <br />practice was provided at either Canyon Springs public meeting, it is appropriate for the public record to <br />include the answers to these questions: <br />Is this the Town’s standard policy for all future EIRs, or does it apply only to the Canyon Springs project? <br />If the latter, who/what was the individual or entity that initiated the request, suggestion, or <br />recommendation (or whatever other similar noun is applicable) not to have a hearing on the 2012 DEIR? <br />What was the process for making this decision? <br />Why was it judged unimportant for the Planning Commissioners to hear public comment at any time <br />prior to the one and final hearing at which the decision to certify the Final EIR will be made? <br />Given that written comments on the DEIR are the public’s only forum for participation, those comments <br />must provide more detail and explanation than would normally be necessary. Absent a public hearing, <br />written comments must also include any relevant visual aids. If I understand the notice rules correctly, <br />the Commissioners could potentially have as little as 10 days to review all of the comments, responses, <br />and changes that the FEIR makes to the DEIR. I believe that’s not enough time for an informed decision. <br />General  Comments  On  Draft  EIR     <br />The Canyon Spring DEIR provides some inadequate and/or inaccurate baseline information that is <br />sometimes, does not fully analyze and describe the environmental impacts that would result from <br />project construction and long-term occupation, and recommends many mitigation measures that are