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 Water Quality BMPs and BMP Maintenance Impact HYDRO-3 (page 4.3-36 through 4.2-47) details the proposed stormwater treatment systems for Alternatives A, B, C, D and E. Alternatives A, B and E will capture, convey and infiltrate the 20yr/1hr storm total runoff volume, while Alternatives C and D will capture, convey and infiltrate up to the 100yr/1hr storm total runoff volume. For Alternatives C and D, the stormwater treatment system schematic is illustrated in Figures 4.3-1, 4.3-2 and 4.3-3. For Alternatives A, B and E, the stormwater treatment system is described on pages 4.3-36 and 4.2- 37. Design Plans for the BMP Retrofit for Existing Conditions (Alternatives A, B and E) was first submitted to TRPA in August 2007 and referenced in the DEIS as Appendix P. These design plans were updated and resubmitted based on comments and questions received during the DEIS comment period and are provided as supplemental information for DEIS Appendix P in Appendix AB. Under all Alternatives, runoff from the TRPA 20yr/1hr design storm (i.e. the current regulatory requirement) will not leave the project area untreated or enter into NDOT ROWs. Under Alternatives C and D, runoff volumes from up to the 100yr/1hr storm event will not leave the project area untreated or enter into NDOT ROWs except possibly under very extreme antecedent soil moisture conditions. Long-term performance of any stormwater treatment system is reliant on the operations and maintenance of the system. The loss of efficiency over time will be minimized through proper operations and maintenance as determined in the inspection, operations and maintenance plan required for permitting of the selected Alternative. The supplemental analysis does consider the loss of gallery efficiency due to antecedent moisture in the system. The Inspection, Maintenance and Monitoring Plan is a standard practice of the Project (added as SP-10 in Chapter 6). The Plan will be developed for the selected Alternative through an RFP Process that includes a third party agreement between TRPA, Boulder Bay and a consultant. This detailed plan will be based on Chapter 6 of the EIS but can be tailored to the outcome of the Governing Board hearings that will decide the final design of the Project, if approved. Because some of the facilities are subsurface, access points are built into the linear treatment system for maintenance and monitoring. The costs associated with maintenance and monitoring will be determined during project permitting because these costs are directly related to the selected Alternative. Subsurface infiltration galleries and other Low Impact Development (LID) strategies including pervious pavers and rain water harvesting are in regular use at Lake Tahoe and have recently been installed in a number of public works projects including but not limited to: Lake Tahoe Unified School District (High School), City of South Lake Tahoe (Lakeview Commons), State of California (Department of General Services - Tahoe Base Center), and Placer County DPW (Tahoe City Transit Center). Although Boulder Bay will be required to properly maintain stormwater treatment systems as a condition of project permitting, the DEIS recommends mitigation measure HYDRO-1 to assure that stormwater treatment systems are operated and maintained to be effective in meeting TRPA discharge standards. The post project monitoring program will be finalized in accordance with the permitting conditions for the selected Alternative and will most likely include some level of stormwater monitoring in addition to BMP and stormwater treatment system inspections. Master Response 2 – Traffic Baseline Comment Summary – The traffic baseline used for the analysis does not accurately reflect current conditions or future vehicle miles traveled. The actual existing traffic counts should be used instead of a theoretical assumption of traffic levels when the existing facility is operating at full capacity. PAGE 8- 16 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 The DEIS traffic study determined baseline traffic volumes by applying trip generation assumptions used for determining the impacts of the Project and Alternatives to the existing land uses that operate within the project area. TRPA has confirmed that for purposes of determining the level of environmental impact in the DEIS and FEIS, the methods used in the original study contained in the DEIS is consistent with and in compliance, procedurally and substantively with the TRPA Code of Ordinances as well as other traffic studies conducted by TRPA for recent Environmental Impact Studies. The DEIS traffic study is also consistent with the guidelines for completion of traffic impact studies to determine level of impact published by the Community Development Departments for Washoe County, Placer County, Carson City/County, Douglas County and El Dorado County. In order to respond to comments regarding the adequacy of the DEIS traffic study, TRPA asked for the preparation of an alternative baseline conditions study. The Boulder Bay Alternative Baseline Existing Conditions Traffic Volumes Technical Memorandum (Fehr & Peers, 2010) addresses concerns raised during circulation of the DEIS about the existing and baseline existing trip generation of the Tahoe Biltmore. The memo is added as Appendix AA of the FEIS and presents an alternative traffic analysis using the actual 2008 traffic counts adjusted to the year 2006 to account for economic conditions that existed in 2008. The technical memorandum includes: • A detailed explanation of the traffic data collection process. • The methodology for determining PM and daily trip generation of the Tahoe Biltmore based on the collected traffic volumes, rather than the ITE and TRPA trip generation rates. • The methodology for correcting the baseline existing conditions based on operating conditions and economic fluctuations. • A comparison of each Alternative’s modeled trip generation to the existing and baseline existing trip generation of the Tahoe Biltmore and other land uses included in the project area. The overall existing trip generation of the Tahoe Biltmore project area was calculated based on the intersection traffic volumes collected in 2008, plus trip generation estimates from the Nugget Casino overflow parking lot, the Crystal Bay Motel, and the Crystal Bay office space, which were not included in the 2008 traffic counts, but are now included as part of the Boulder Bay project area. The trip generation estimates for Alternatives B, C, D and E are based upon Institute of Transportation Engineers (ITE) trip generation rates. These trip generation rates assume optimal operating conditions during the peak time of the year during a normal economic year. During the summer of 2008, Lake Tahoe and the broader US economy were in the midst of the worst economic downturn since the 1930’s. At the same time, gas prices were over $4.00/gallon. Both situations led to dramatic temporary declines in visitation to Lake Tahoe. Based on an analysis of Nevada Gaming numbers for North Lake Tahoe and Biltmore audited financials, it was estimated that visitation was off by 28% in 2008 vs. normal economic conditions in 2006. (It is important to note that this does not include the decline due to the growth of tribal gaming in California. This decline, estimated at 32%, was viewed as a permanent decline and was not adjusted for in the calculation. Estimated Average Peak Daily Trips would be 5,853 if a recovery in gaming was included.) Due to the unique conditions of 2008, the baseline existing conditions analysis looks back two years previous to when the traffic counts were collected, consistent with the two-year window that TRPA considers for an “existing” use. This two-year look back provides a more consistent comparison between the existing conditions and ITE trip generation estimates for Alternatives B, C, D, and E. Table 8.5-2 shows the daily and PM peak hour trip generation of the existing Tahoe Biltmore (based on the traffic volumes collected in 2008, plus trip generation estimates from the Nugget Casino overflow parking lot, the Crystal Bay Motel, and the Crystal Bay office space), the baseline existing conditions SEPTEMBER 8 , 2010 HAUGE BRUECK ASSOCIATES PAGE 8- 17
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FEIS - Tahoe Regional Planning Agency

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