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March 5, 2013 <br /> <br />To: Denyelle Nishimori, Senior Planner <br />10183 Truckee Airport Rd. <br />Truckee, CA 96161 <br />dnishimori@townoftruckee.com <br /> <br />Re: Comments for Canyon Springs DEIR <br /> <br />Dear Denyelle Nishimori, <br /> <br />As a 13-year resident of Truckee and a professional biologist, I have grave concerns <br />about the DEIR for the proposed Canyon Springs housing development. <br /> <br />There is the clear and direct conflict with the Town of Truckee 2025 General Plan for <br />development to be concentrated in the core and not in the “rural fringe”. Please explain <br />how the proposed development does not constitute “rural sprawl” when 200+ units <br />are to be located within the “rural fringe”. <br /> <br />The following are some of the goals from the 2025 General Plan that are not aligned with <br />the large Canyon Springs development proposed at the easternmost fringe of the Town: <br /> <br />COS-P1.5 “…Preserve open space that, to the greatest extent possible, occurs in large <br />blocks and is contiguous and connected... Provide maximum benefit in terms of habitat <br />preservation. Enhance the overall character of Truckee as a scenic, mountain <br />community.” <br /> <br />COS-1 “Preserve existing open space in Truckee, and increase the amount of desired <br />types of open space under permanent protection” <br /> <br /> <br />In addition to the proposed development’s conflicts with the General Plan, I have serious <br />concerns about the methods and sufficiency of the DEIR biological survey and about the <br />DEIR’s conclusions regarding the Verdi mule deer subunit. <br /> <br />Biological survey insufficiencies <br /> <br />As documented below, the biological site surveys were not sufficient because they 1) <br />were conducted in a single, atypical year; 2) were biased against winter-occurring species <br />and nocturnal species; 3) made use of flawed survey methods. <br /> <br />Single, atypical year survey: <br /> <br />The year the focused plant survey was conducted (2011) was an unusually wet spring <br />following a high-snow winter. Plants specifically are sensitive to hydrologic conditions <br />and their presence and abundance can vary greatly from year to year. A single-year