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March 5, 2013 <br /> <br /> <br />Denyelle Nishimori, Senior Planner <br />Truckee Community Development Department <br />10183 Truckee Airport Road <br />Truckee, CA 96161 <br /> <br />Re: Canyon Springs DEIR <br /> <br />Dear Denyelle, <br /> <br />It is my opinion that the submitted Canyon Springs DEIR fails in its analysis of Project <br />Alternatives as required by the California Environmental Quality Act, CEQA. This DEIR <br />does not allow an adequate comparison of Project Alternatives sufficient for comparative <br />review and consideration by the Public, TOT and all concerned. Specifically this DEIR does <br />not appropriately consider Project Alternatives which could greatly reduce Traffic, <br />Environmental and Community concerns. <br /> <br />PROJECT DENSITY: <br />The submitted DEIR considers project density but does not propose a Project Alternative <br />where Canyon Springs meets the “Rural Clusters” criteria as described in Table LU-7, <br />Clustered Development Types and Applicable Land Use Designations, 2-62 of the 2025 TOT <br />General Plan’s Land Use Element. Our General Plan specifically assigns this designation to <br />“Rural residential areas on Town edges”, words which are consistent with Canyon Springs. <br />Instead of an Alternative Project density consistent with “Rural Clusters”, this DEIR suggests <br />that the Canyon Springs project have a “Rural Suburban Cluster” designation. This <br />designation is inappropriate because it is intended for “Sites peripheral to Town core, <br />generally not on sites within the rural fringe”. Why doesn’t this DEIR compare a Canyon <br />Springs project which is consistent with a Rural Clusters designation, to the project as <br />submitted? Even more alarming is the suggestion that this submittal have an allowed density <br />under the “Suburban Clusters” designation when the Canyon Springs site is clearly on the <br />“Town edges” and not the “Town core”. <br /> <br />PROJECT TRAFFIC: <br />The submitted Canyon Springs DEIR does not propose a Project Alternative where Canyon <br />Springs has no bearing / impact on our existing roadways and intersections. Instead, the <br />submitted DEIR suggests that this project would mitigate its impacts to our existing roads <br />and traffic infrastructure and is reliant in some degree to improvements to the Glenshire <br />Drive / Donner Pass Road intersection which are to be completed as part of the Railyard <br />Project which may or may not happen. To allow adequate comparative analysis, why doesn’t <br />this DEIR propose a Canyon Springs Alternative with a density determined by what our <br />existing roads will bear, and without necessary and dependent improvements to mitigate <br />Canyon Springs’ traffic impact? This Alternative was specifically requested, by me, in the <br />project’s DEIR Scoping Meeting and appears in Appendix B, Scoping Meeting Comment <br />Matrix + Letters, page 107 of the submitted DEIR. It is unclear why this DEIR fails to <br />review a “no impact to traffic intersections” alternative, to allow consideration of a smaller <br />project that wouldn’t impact existing neighborhoods and streets. <br />