FEIS - Tahoe Regional Planning Agency

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