FEIS - Tahoe Regional Planning Agency

FEIS - Tahoe Regional Planning Agency FEIS - Tahoe Regional Planning Agency

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RESPONSE TO COMMENTS ON THE DEIS B o u l d e r B a y C o m m u n i t y E n h a n c e m e n t P r o g r a m P r o j e c t E I S runoff volume, but the existing circulation and urban design deficiencies would remain. Comment 332-n: Comment Summary - In Table 3.2-1, Alt. C is not consistent with regional Plan Goal 2 and policies due to height limits. Please see response to comment 322-hb. Comment 332-o: Comment Summary - As a CEP project, the EIS must provide a better quantified analysis of water quality benefits (Code of Ordinances Chapter 33.3 D (3) a). Comment is noted. Please see Appendix AB for supplemental analysis for additional quantification of surface water quality benefits, notably predicted load reductions for total sediment, fine sediment and nutrients. The analyses for HYDRO-1 and HYDRO-3 are presented in the format determined and reviewed by TRPA Staff. The supplemental water quality analysis does not change the analysis for HYDRO-1 and HYDRO-3 but provides additional quantified results that support the conclusions that potential impacts discussed in HYDRO-1 and HYDRO-3 are reduced to a level of less than significant. Comment 332-p: Comment Summary - The EIS needs to clarify relation to EIP #732, Brockway Residential Water Quality Improvement Project, and cost share. Boulder Bay committed to implementation of EIP projects in the February 4, 2008 Resolution Letter for TRPA CEP participation. The Project's commitment to EIP projects is disclosed on page 2-18 of the Project Description. Boulder Bay will enter into a separate agreement with Placer County for completion of EIP project #732 (as will be required as a TRPA Permit Condition), a draft of which has been submitted to TRPA for review. Boulder Bay will construct Infiltration Basin #9 on the California Parcel and has proposed a cost share agreement with Placer County for long-term maintenance. Comment 332-q: Comment Summary - EIP # 114 (Washoe County Water Quality Improvement Project – Phase I/North Stateline Community Plan Lake Vista Mini Park) does not have a water quality component and therefore should not be listed as contributing to water quality benefits. This needs to be clarified in the EIS. Clarification concerning EIP Project #114 is added to DEIS page 4.3-26: EIP Project #114 is a recreation project that preserves open space and establishes park uses in the NSCP. The land underlying the park contributes to EIP # 732 for the treatment and infiltration of stormwater runoff. EIP #114 and 732 utilize the same parcel of land. The water quality benefits on this parcel of land include: a reduction in land coverage, installation of the infiltration gallery #9 and tie in with the Placer County Brockway Erosion Control Project. Bio retention systems for stormwater treatment will be installed in line with the underground infiltration galleries. The Stateline mini-park will be installed on top of the under ground infiltration galleries and will include water quality interpretive signage. Comment 332-r: Comment Summary - The EIS should quantify the different components and benefits, especially for fine sediment reduction, of the required 20-year, 1 hour runoff vs. the proposed 100-year storm capture designs. Impact HYDRO-3 details the "over and beyond" stormwater volume reductions proposed by the Project. Table 4.3-12 presents the calculations for the 100yr/1hr storm total runoff capacity of the proposed systems. The "over and beyond' is PAGE 8- 134 HAUGE BRUECK ASSOCIATES SEPTEMBER 8 , 2010

RESPONSE TO COMMENTS ON THE DEIS B o u l d e r B a y C o m m u n i t y E n h a n c e m e n t P r o g r a m P r o j e c t E I S determined by comparing this storm volume (13,201 cubic feet) to the 20yr/1hr storm total runoff volume (8,517 cubic feet - support calculations are provided in DEIS Appendix G). See Appendix AB for DEIS Appendix G supplemental information for predicted total sediment, fine sediment and nutrient load reductions. Comment 332-s: Comment Summary - The EIS should quantify fine sediment ( 50% of total sediment load for granitic soils and JBR data reported levels as high as 90%. Since Alternatives C and D aim to capture, convey and infiltrate the 100yr/1hr storm total runoff volume, then 97 - 100% of the total sediment can be captured and infiltrated for this storm volume. The EIS states a more conservative reduction estimate of 90%, but modeled results for example water year 1993-1994 predict higher reductions in total sediment. See Appendix AB for supplemental analysis of predicted load reductions, including fine sediments of 20 microns and less. Please see response to comment 129-a for additional information on the definition of fine particle size. Comment 332-t: Comment Summary - Requests additional water quality monitoring data. See Appendix AB for the supplemental surface water quality analysis, which incorporates data collected for the DRI Brockway Project Area Stormwater Runoff and Characterization Study and Upper Cutthroat Infiltration Testing and Stormwater Runoff Study (Heyvaert et al. 2008) into the LSPC model to predict existing total sediment loads and proposed reductions based on the 20yr/hr and 100yr/1hr storm events. Comment 332-u: Comment Summary - Utility undergrounding listed as a benefit in Alts C and D, but not A, B and E. But the work is completed and should be listed as a benefit in all Alternatives. Please see response to comment 322-ac. Comment 332-v: Comment Summary - The EIS claims (p. 4.2-16) that coverage mitigation can use ROWs under Code 20.5; but is not allowed under 20.3B. Provide the appropriate supporting code and language, and adjust coverage calculations as needed. The reference to TRPA Code Section 20.3.B is incorrect and should have been Code Section 20.3.D. Code Section 20.3.D defines the method for calculating land coverage. Subsection 20.3.D.1(b) doesn't allow the existing Washoe County ROW lands to be used for determination of base allowable land coverage. Therefore, the existing ROW was excluded from the project area for determination of allowable base land coverage. Because the ROW will be rescinded for the project to go SEPTEMBER 8 , 2010 HAUGE BRUECK ASSOCIATES PAGE 8- 135

RESPONSE TO COMMENTS ON THE DEIS<br />

B o u l d e r B a y C o m m u n i t y E n h a n c e m e n t P r o g r a m P r o j e c t E I S<br />

determined by comparing this storm volume (13,201 cubic feet) to the 20yr/1hr storm<br />

total runoff volume (8,517 cubic feet - support calculations are provided in DEIS<br />

Appendix G). See Appendix AB for DEIS Appendix G supplemental information for<br />

predicted total sediment, fine sediment and nutrient load reductions.<br />

Comment 332-s: Comment Summary - The EIS should quantify fine sediment ( 50% of total sediment<br />

load for granitic soils and JBR data reported levels as high as 90%. Since<br />

Alternatives C and D aim to capture, convey and infiltrate the 100yr/1hr storm total<br />

runoff volume, then 97 - 100% of the total sediment can be captured and infiltrated<br />

for this storm volume. The EIS states a more conservative reduction estimate of<br />

90%, but modeled results for example water year 1993-1994 predict higher<br />

reductions in total sediment. See Appendix AB for supplemental analysis of<br />

predicted load reductions, including fine sediments of 20 microns and less.<br />

Please see response to comment 129-a for additional information on the definition of<br />

fine particle size.<br />

Comment 332-t: Comment Summary - Requests additional water quality monitoring data.<br />

See Appendix AB for the supplemental surface water quality analysis, which<br />

incorporates data collected for the DRI Brockway Project Area Stormwater Runoff<br />

and Characterization Study and Upper Cutthroat Infiltration Testing and Stormwater<br />

Runoff Study (Heyvaert et al. 2008) into the LSPC model to predict existing total<br />

sediment loads and proposed reductions based on the 20yr/hr and 100yr/1hr storm<br />

events.<br />

Comment 332-u: Comment Summary - Utility undergrounding listed as a benefit in Alts C and D, but<br />

not A, B and E. But the work is completed and should be listed as a benefit in all<br />

Alternatives.<br />

Please see response to comment 322-ac.<br />

Comment 332-v: Comment Summary - The EIS claims (p. 4.2-16) that coverage mitigation can use<br />

ROWs under Code 20.5; but is not allowed under 20.3B. Provide the appropriate<br />

supporting code and language, and adjust coverage calculations as needed.<br />

The reference to TRPA Code Section 20.3.B is incorrect and should have been Code<br />

Section 20.3.D. Code Section 20.3.D defines the method for calculating land<br />

coverage. Subsection 20.3.D.1(b) doesn't allow the existing Washoe County ROW<br />

lands to be used for determination of base allowable land coverage. Therefore, the<br />

existing ROW was excluded from the project area for determination of allowable<br />

base land coverage. Because the ROW will be rescinded for the project to go<br />

SEPTEMBER 8 , 2010 HAUGE BRUECK ASSOCIATES PAGE 8- 135

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