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 Comment 335-k: Comment Summary - The EIS needs to provide evidence that Alts. C and D, and CEP projects provide a substantial net water quality benefits. Post-project monitoring is not considered adequate. Impact HYDRO-1 is addressed on page 4.2-32 of the DEIS. Post-project monitoring will be completed to further calibrate predictive models and substantiate assumed effectiveness of the proposed stormwater treatment systems, BMPs and LID strategies. The supplemental analysis in Appendix AB for further quantification of the water quality benefits. Comment 335-l: Comment Summary - The HYDRO-1 mitigation: the security deposit fee does not guarantee that the mitigation will be accomplished for water quality. The security deposit will be determined by TRPA once an Alternative is selected for permitting. The comment is noted that the security deposit should be an amount that is adequate to "cover additional, best available control technologies that could be implemented in addition to the planned systems if post-project monitoring shows that standards are not being met". Comment 335-m: Comment Summary - The EIS should disclose landscaping and fertilizer use. The Landscaping Plan will be developed in accordance with the selected Alternative and submitted to TRPA for approval during project permitting. The Landscaping Plan for Alternative C is included in Appendix O of the DEIS. The EIS discusses proposed landscaping on pages 2-17 for open space and parks and 2-26 for the high traffic areas in the pedestrian village. The Revegetation/Landscaping Plan is identified as a standard practice (SP-7) for the Project for compliance with TRPA codified regulations and is outlined in Chapter 6, Mitigation and Monitoring Program. Chapter 4.3 further discusses the requirements of the Revegetation/Landscaping Plan for disturbed areas on pages 4.3-25. Comment 335-n: Comment Summary - Describe if the stormwater treatment train will work with snow. The statement that the calculations on pages 4.3-40 to 4.3-41 assumes that only rain will fall is incorrect. The stormwater treatment system, which is primarily composed of underground components such as infiltration trenches and galleries are properly sized and located to treat "runoff" into the systems. The runoff will occur from rain, melting snow or a combination of rain and melting snow. Snow that falls on portions of the project area will be melted through advanced snow management as described on page 4.3-28 and captured and conveyed to the stormwater treatment systems. Snow that falls in above ground infiltration basins would affect the functioning of the basins by reducing the total capacity; however, runoff that eventually enters a basin would serve to melt this snow and recapture this capacity by initiating the melting and infiltration process. Comment 335-o: Comment Summary - Verify if 100-year storm runoff will be treated. See Table 4.3-12. See Appendix AB, which includes the LID summary table (termed Green Strategies) and support calculations (Table 1). Comment 335-p: Comment Summary - Provide documentation to support the quantified benefits of green roofs, previous pavers, and stormwater catchments on the treatment system. DEIS Appendix R details the support data and references for the LID strategies. The assumptions documented for the LID strategies are based on studies for cold weather climates and are conservative. For example, the effective reduction for pervious PAGE 8- 146 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 pavers is stated at 50% when other studies and reports assume effective reductions of 70-80%. Green roofs are calculated at a 20% reduction factor. See Appendix AB, Table 1 for calculations. Comment 335-q: Comment Summary - If treatment systems are a "test", then this cannot be claimed as mitigation until monitoring results are available, unless a back up plan is in place. Comment is noted. The calculations for capture of the 100yr/1hr storm total runoff volume is reported in the DEIS and support the conclusion that the proposed stormwater treatment systems will have the capacity to capture, convey and infiltrate this volume. Post-project monitoring is proposed as part of the Project as standard practice SP-9 and will be based on the selected Alternative. If TRPA discharge limits are not met (measured during post-project monitoring), then mitigation measure HYDRO-1 will apply. Comment 335-r: Comment Summary - The cumulative impact analysis on water quality, water supply, and air quality incorrectly finds no impact because projects have to adhere to standards. Rather the analysis should consider the small, incremental contributions of all projects to determine if they are cumulative impacts. Please refer to the cumulative analysis in each section of Chapter 4 of the DEIS. For some cumulative analyses, the DEIS does conclude that a significant cumulative impact would not occur because existing regulations prevent a significant impact from occurring; however, this statement is applied only to those resources that are protected with regulations that prevent a significant cumulative impact. For example, impacts related to water supply for the project are limited to water infrastructure for those projects within IVGID's jurisdiction, which excludes most of the cumulative projects for the area. Impacts to other water districts will not affect IVGID operations. Further, water supplies must be secured by each project. A project that does not secure water supplies cannot be built, thereby eliminating the project from consideration. In the case of impacts such as water quality, the regulations established for water quality significantly limit runoff pollutant levels to ensure water quality is not affected. Often, as is the case with this Project, water quality can improve with redevelopment and implementation of best management practices and treatments that improve the existing runoff quality. Since the Project results in beneficial impacts to water quality and hydrology, it would not contribute to an adverse cumulative impact. For traffic and air quality, vehicle queuing will actually improve with Alternative C development; therefore, the Project would not contribute to a negative cumulative impact, rather, it would help to reduce a cumulative impact. These conclusions are provided in the cumulative analysis provided in each section of Chapter 4. Comment 335-s: Comment Summary - The EIS should consider impacts on lake clarity from N and P sources. See Appendix AB, which presents the supplemental water quality analysis and the predicted reductions in annual loading for Total Nitrogen and Total Phosphorus. See Tables 2 and 3 and Figures 6a and 6b, which present predicted loading during a wet water year (e.g. worst case scenario). Comment 335-t: Comment Summary - Under SP-3, what will be the qualifications required for this inspector? Given the size of the project area, is one monitor enough? NPDES permits outline the level of professional training and experience necessary to complete SWPPP inspections. TRPA can require contractor training and additional SEPTEMBER 8 , 2010 HAUGE BRUECK ASSOCIATES PAGE 8- 147
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FEIS - Tahoe Regional Planning Agency

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