HomeMy WebLinkAbout4 6160 Bridge Street Agenda Item # 4
Memorandum
To: Board of Directors
From: Peter Holzmeister
Date: October 12, 2001
Public hearing on 6160 Bridge Street water storage tanks project
We have been planning to construct two new water storage tanks on property that we
acquired from Steele Family Trust. A preliminary step in our planning for that project has
been to process an environmental review. A proposed negative declaration was
prepared and circulated to interested parties and public hearings were held. We received
comments from a variety of persons. In some cases the comments express concerns
with the adequacy of our environmental review.
Specifically, comments raised a concern that we had not identified the source of water
that would be used to supply the storage tanks. To the extent that groundwater is used
to supply the tanks we are cautioned to consider the safe yield of the basin in our
environmental analysis of the tanks project. Another comment raised a concern over
possible growth inducing impacts.
We have been carefully considering these comments and have scheduled another public
hearing on October 17 at 7:00 PM. We will then be able to discuss how to proceed
during item 6 on the agenda.
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October 17, 2001
Via Fucslrtalle
Iti4embors of the Board
Truckee Donner Public Utility District
F.O. Box 309
Truckee, CA 96160-0309
Re; Bridee Street 6160 Water 5toe.�:>
Dear Board Members;
On behnlf of SierraWatch and the Mountain Area Preservation Foundation
C'IYIAPF"), this leaer provides additional comments on the Mitigated Negative
Declaration and Initial Study ("NINDD")prepared by the Truckee Dom?er Public Utility
Disttict("District" or"PUD") as lead agency under the California Environmental Quality
ACE ("CEQA'l Pub, Res. Code §§ 21000 gS aa., for the Bridge Street 6160 Water
Storage Tank('`proposed project"), This letter supplements our earlier comments of
August 15,2001 and September 5, 2001.
We understand that the District is considering amdnding the MND and
adopting mitigation measures for the growth-inducing impacts of the proposed project
We strongly agree that the MND should be amended to address all potentially significant
effects of tLe project, including growth-inducing effects, the environmental effects
discussed in our earlier correspondence, and effects on visual resources dilicusscd by the
Town of Truckee. For the additional reasons discusser) below, we believe that the District
should amend and recirculate an environmental review"document, for the proposed
Project.
First, SierraWatch and MAPF ar4 concerned that the itiOID improperly
ekes on the Town of Truckee General Plan EIK("Oeneral Plan FJR") for analysis of the
proposed projcet's cumulative impacts. Tiering off of an earlier EIR is appropriate only
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Members of the Board
October 17,2001
Page 2
if the impacts of the proposed project were (1)mitigated or avoided as a re5ult of the prior
EI.R or(2) analyzed at a sufficient level of detail in The prior EIR such that the earlier
analysis cart be relied on to identify project-specific avoidance or mitigation measures in
subsequent environmental review. (& Pub, Res. Code §21094(a); jee fig,CEQA
Guidelines § 1 5152(f).) Reliance on an earlier EIR for analysis of a proposed project's
cumulative impacts is not appropriate if circumstances have changed significantly since
the prior EIR was prepared because the prior EIR could not have analyzed the project's
cumulative impacts under the now circumstances.
The cumulative impacts of the proposed project were not analyzed at a
sufliciont level of detail in the General Plan Elk. Even if it is appropriate to assume that
the cumulative impacts of the proposed pruject are incorporated in the Cenral Plan FIR`,
analysis of the cumulative impacts of buildout, the General Plan FIR should not be relied
on for analysis of the proposed projects cumulative impacts because the General Plan
EIR does not contain an adequate analysis of the cumulative impacts of buildout. For
example, the General Plan EIR does not analyze the cumulative impacts of buildout on
regional water supplies, such as the Martis Valley Ground Water Basin, The General
Plan EM contains some analysis of the cumulative effects of build-out on water quality
(= General Plan EIR at 12) but largely defers analysis of the cumulative effects of
buildout on the tvgioa's water supply to the District, ( ee General Plan, Final'1 Icchnicai
Appendix, Part 3 at 29 C:Ail of the special districts [including the PT ID]plan for the
provision of service to their district based on their own projections of fl-ture growth . . .
[and]include areas outside of Truckee,");,sue also Truckee General Plan at 140.) Giveu
tho lack of analysis in the General Plan EIR,the District cannot be confident that the
cumulative effects of the proposed project on regional water supplies will not be
significant.
The District also cannot rely an the General Plan EIR for analysis of the
proposed prcject's cumulative impacts because circumstances have changed since the
General Plan EIR was adopted. MAPP has identified several such changes:
(1) The District is poised to acquire the Glenshire Mutual Water Company,
which operates several wells"undergoing a degradation in water quality,
including increased levels of arsenic, radon, and iron."(Initial Study,
Glenshire Water System Acquisition and Improvements,at i.) The
proposed acquisition will require transfer of District water to supply
Glenshire customers. (JU a at 2.)
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(2) RQr4cQwners at Donner Lake roust obtain water frorn a new source because
their existing water system,is contaminated, and the Disaict has acquired
the Donner Lake Rater Company, requiring diversion of District supplies
for Dormer Lake customers.
(3) Development densities in the region have exceeded the densities
contemplated in the General Plan.
(4) Several new golf courses have been built or are under development in the
region, beyond those anticiputcd in the General Plan. Those new courses
will place additional,unanticipated demands on the Mart-is Valley
Groundwater Basin.
Coven the inadequacy of the General Plan EIR as a first•tirr document with
respect to cumulative impacts, the District must address fee prcject's cumulative impacts
in tht:MNE), or, if those effects are significant and cannot be rendered insignificant
dirough adoption of mitigation measures, in an EIR. (?uh. Res, Code § 21080(e)(2), (d).)
Second,as we noted in our two previous (utters, the water source For the
proposed project must be identified and the effects of the project's withdrawals from that
source. most be addressed in a revised MAD or an EIR, Aa described in our letter of
September 5, 2001 and the letter attached thereto prepared by ACrtin, Mickelson
Environmental, Inc. ("AMF°'), if'the proposed project requires withdrawals from the
hiatus Valley Ground Water Basin, the project me) indeed cause significant
environmental effects. Absent discussion of ibose effects; the MND does not comply
with UQA.
finally, we note that alteration of the MND to add discussion of anew
significant effect or mitigation measure would be a "substantial revision"requiring
recirculation of the document. Under CEQA Guidelines section 15073.5, a substantial
revision has occurred, and recirculation is required, if"[a]new, avoidable significant
rf}ect is identified and mitigation measures or project revisions must be added in order to
reduce the effect to insignificance." (CEQA Guidelines § 15073.5(b)(I).) The revisions
discussed in this letter, such as adoption cf new mitigation measures to address the
project's gruwth•inducing impacts,plainly come within the ambit of that subsection.
(The NIND presently indicates that there are no significant growth-inducing impacts of
the proposed project.) CEQA Guidelines section 15074,1,which provides for xILjWuJivn
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October 11.200I
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of one mitigation measure for aaother,is not to the contrary. Section 15074,1 allows the
replacement of existing`infeasible or otliernvise undesirable"mitigation measures fur an
already-idendfiad significant effect. ({ EQA Guidelines § .15074.!(a).) The resrisions
discussed in this letter involve the identification of new significant impacts and rrmitiaatiota
measures.
Thank you #'or the opportuidty to provide these comments. We would be
glad to discuss the issues that these comments raise.
Very truly yours,
SKUTE, 1�HAL7
ERGER LLP
MATTHEW D. ZINN
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October 17, 2001
Via Hand Delivery
Members of the Board
Truckee Donner Public Utility District
P.O. Box 309
Truckee, CA 96160-0309
RE: Negative Declaration Bridge Street 6160 Water Storage Tank
Dear Board Members:
I am writing as a concerned citizen and resident of the Prosser area. There are approximately 70
homes on Prosser Dam Rd. and in Panonia Ranchos, all of which use well water from wells
drilled upon each property. I am very concerned because the information coming from TDPUD
seems to indicate that there is an infinite amount of ground water in the Mantis Valley aquifer
with which to fill the proposed water storage tanks. It does not appear that this conclusion has
been reached using the best available hydrological testing and quantification methods, nor
evaluating all of the future cumulative impacts.
I am very concerned because in all the hearings conducted on PC-2, and all the other huge
development projects that are proposed or in the planning process, TDPUD seems to be willing
to give "will serve" letters without the knowing what the cost is to provide the infrastructure, and
if the aquifer really can serve all of the proposed development on an indefinitely sustainable
basis. In addition, it seems that with the Glenshire wells having been depleted, the sad state of
the Donner Lake water supply, and several of my neighbors' wells having to be drilled deeper,
that perhaps the aquifer is not in as bountiful position as the Nimbus Engineers seem to imply in
their report.
Nowhere to my knowledge has the cumulative effects of all the proposed golf courses, snow-
making,residential, commercial, and industrial water usage been quantified or estimated for the
aquifer. It is pretty obvious to me that living in the high desert, with Reno in an uncontrolled
growth mode, that Truckee and the Martis Valley have the distinct possibility of turning into the
next Owens Valley.
What steps and safeguards are being put into place to protect the quality and quantity of the
existing wells in the Prosser area? Will the project developers be required to hook all of us up to
TDPUD water, when our wells go dry, because they wasted water on all of the green desert golf
courses? How is TDPUD going to provide protection to the existing residential wells?
I would like these questions answered. I would also encourage TDPUD to prepare a full EIR for
all of the contemplated development in the Martis Valley as well as just Truckee. I would like to
see more than one hydrology company used, in order to determine what data interpretation the
experts agree and disagree upon. Thank you for your attention to this very critical issue.
Your ly,
i
Ja a S. Caughron
12584 Prosser Dam Rd., Truckee, CA 96161, 530-587-0106