FEIS - Tahoe Regional Planning Agency
FEIS - Tahoe Regional Planning Agency 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 Please see response to comment 100-b regarding the impact on trip generation from the expansion of Indian Gaming facilities. Comment 286-s: Comment Summary: - Identify how many slots and tables will be included in the 10,000 sf gaming area and explain how the inclusion of the proposed slots and tables will cause a reduction in vehicle trips compared to the existing 275 slots and 12 tables. Vehicle trips were generated for the casino based on the square footage of the facility, which is a typical method for calculating trip generation. The utilization of the reduced casino floor area proposed for Alternative C will be a market-driven decision at the time of opening in an evolving marketplace. See Master Response 2 for an alternative baseline analysis that estimates trip generation based on survey counts instead of trip generation tables. This provides information related to the alternative existing baseline analysis. This analysis confirms that trips are reduced without the assumptions on the utilization of gaming floor area. Comment 286-t: Comment Summary - Can any of the banked gaming floor area from the Biltmore Hotel facility be relocated to the Mariner Site, or across the street to the Crystal Bay Motel or Crystal Bay Building? Is this consistent with the intended uses of either site? Please see response to comment 93-c. Comment 286-u: Comment Summary - What are the impacts on traffic and air quality if more casino space can be created on site? The traffic analysis was performed using the project description provided in Chapter 2 of the DEIS. If the Project proponent revisits the size or type of uses on the site, it would require review by TRPA and potential re-evaluation of transportation impacts. Comment 286-v: Comment Summary - Address any changes to the trip generation calculations if the reserved gaming floor area is converted to CFA. The traffic analysis was performed using the project description provided in Chapter 2 of the DEIS. The designation as GFA or CFA would not result in changes to the trip generation calculations for the proposed project. Please refer to Master Response 4 for additional information on CFA designation. Comment 286-w: Comment Summary - Address all the potential effects of Boulder Bay's reservation of gaming floor area rights including VMT, traffic and air quality impacts. Please see response to comment 286-u. Comment 286-x: Comment Summary - What are the impacts on the trip calculations if the wellness center and spa are categorized as CFA instead of as an "accessory use" to the hotel? The TRPA Code of Ordinances provides definitions of Accessory Space and Commercial Floor Area (CFA) that are not related to the ITE definition of “accessory space” from a traffic analysis perspective. The CFA designation is unique to TRPA and does not influence the analysis of traffic impacts. The trip generation calculations of the spa (wellness center) will not change if it is categorized as CFA. A change in the designation of the spa to CFA will not change the project description, and therefore will not change the analysis. Please refer to Master Response 4 for additional information on CFA designation. PAGE 8- 70 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 Comment 286-y: Comment Summary - How can the wellness center and spa be considered accessory to the hotel if Boulder Bay promotes the spa/wellness center as a benefit to the community and not just hotel guests? Please see Master Response 4 regarding the trip generation analysis for the accessory uses. As discussed in Impact LU-1, the accessory uses proposed in the Project must be consistent with findings included in TRPA Code Subsection 33.3.A(1)(b). If TRPA determines that the accessory uses are not consistent with the applicable findings, then CFA will be required for all or a portion of the proposed accessory uses. The spa and wellness center can be considered accessory because there are no separate entrance (33.3.A.1.b.i), the size of these amenities are of comparable size ratio as other hotels in the area (33.3.A.1.b.ii), there is no separate or dedicated parking for this amenity (33.3.A.1.b.iii), it will not be separately advertised (33.3.A.1.b.iv), the primary use season corresponds to the primary use season of the hotel (33.3.A.1.b.v), and the use of this amenity does not generate a separate vehicle trip (33.3.A.1.b.vi). Comment 286-z: Comment Summary - If the TRPA Board determines the spa/wellness center is not an accessory use, the DEIS states additional CFA is available within the Project to accommodate this use. Therefore, the DEIS should include a traffic analysis for the spa/wellness center as CFA. Please see response to comment 286-x. Comment 286-aa: Comment Summary - Describe the impacts on parking if the wellness center and spa are categorized as CFA. The TRPA Code of Ordinances provides definitions of Accessory Space and Commercial Floor Area (CFA) that are not related to the ITE definition of “accessory space” from a traffic analysis perspective. The CFA designation is unique to TRPA and does not influence the analysis of traffic impacts. The parking analysis will not change if the spa (wellness center) is categorized as CFA. A change in the designation of the spa to CFA will not change the project description, and therefore will not change the analysis. Please refer to Master Response 4 for additional information on CFA designation. Comment 286-ab: Comment Summary - Would the classification of the wellness center and spa as CFA comply with the limits on total CFA set by the NSCP? Boulder Bay has TRPA verified CFA and GFA that may be used for the proposed accessory uses if TRPA determines that the accessory uses are not consistent with applicable findings. While the NSCP provides an additional CFA growth allocation of 19,616 square feet, it does not limit total CFA growth because it states "Existing and/or banked development, above and separate from the allocations, may also be transferred into the plan area, as permitted by the TRPA plan area statement (page 2- 10)." Comment 286-ac: Comment Summary - The DEIS runoff and drainage analysis is inadequate and incomplete. Comment is noted. The commenter supports this statement by reference to John V Bosche's comment letter (Comment Letter 137). Comment 286-ad: Comment Summary - Consider the impact of a 100-year 1-, 6-, and 24-hour storm on offsite properties. SEPTEMBER 8 , 2010 HAUGE BRUECK ASSOCIATES PAGE 8- 71
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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 />
Please see response to comment 100-b regarding the impact on trip generation from<br />
the expansion of Indian Gaming facilities.<br />
Comment 286-s: Comment Summary: - Identify how many slots and tables will be included in the<br />
10,000 sf gaming area and explain how the inclusion of the proposed slots and tables<br />
will cause a reduction in vehicle trips compared to the existing 275 slots and 12<br />
tables.<br />
Vehicle trips were generated for the casino based on the square footage of the<br />
facility, which is a typical method for calculating trip generation. The utilization of<br />
the reduced casino floor area proposed for Alternative C will be a market-driven<br />
decision at the time of opening in an evolving marketplace.<br />
See Master Response 2 for an alternative baseline analysis that estimates trip<br />
generation based on survey counts instead of trip generation tables. This provides<br />
information related to the alternative existing baseline analysis. This analysis<br />
confirms that trips are reduced without the assumptions on the utilization of gaming<br />
floor area.<br />
Comment 286-t: Comment Summary - Can any of the banked gaming floor area from the Biltmore<br />
Hotel facility be relocated to the Mariner Site, or across the street to the Crystal Bay<br />
Motel or Crystal Bay Building? Is this consistent with the intended uses of either<br />
site?<br />
Please see response to comment 93-c.<br />
Comment 286-u: Comment Summary - What are the impacts on traffic and air quality if more casino<br />
space can be created on site?<br />
The traffic analysis was performed using the project description provided in Chapter<br />
2 of the DEIS. If the Project proponent revisits the size or type of uses on the site, it<br />
would require review by TRPA and potential re-evaluation of transportation impacts.<br />
Comment 286-v: Comment Summary - Address any changes to the trip generation calculations if the<br />
reserved gaming floor area is converted to CFA.<br />
The traffic analysis was performed using the project description provided in Chapter<br />
2 of the DEIS. The designation as GFA or CFA would not result in changes to the<br />
trip generation calculations for the proposed project. Please refer to Master<br />
Response 4 for additional information on CFA designation.<br />
Comment 286-w: Comment Summary - Address all the potential effects of Boulder Bay's reservation of<br />
gaming floor area rights including VMT, traffic and air quality impacts.<br />
Please see response to comment 286-u.<br />
Comment 286-x: Comment Summary - What are the impacts on the trip calculations if the wellness<br />
center and spa are categorized as CFA instead of as an "accessory use" to the hotel?<br />
The TRPA Code of Ordinances provides definitions of Accessory Space and<br />
Commercial Floor Area (CFA) that are not related to the ITE definition of “accessory<br />
space” from a traffic analysis perspective. The CFA designation is unique to TRPA<br />
and does not influence the analysis of traffic impacts. The trip generation<br />
calculations of the spa (wellness center) will not change if it is categorized as CFA.<br />
A change in the designation of the spa to CFA will not change the project<br />
description, and therefore will not change the analysis. Please refer to Master<br />
Response 4 for additional information on CFA designation.<br />
PAGE 8- 70 HAUGE BRUECK ASSOCIATES SEPTEMBER 8 , 2010
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