Sierra Club Tahoe Area Group's letter to:

The Tahoe Area Group of the Sierra Club agrees that affordable housing is needed in the Tahoe Basin. However, Placer County’s proposed Tahoe Basin Area Plan (TBAP) amendments will hopefully spur workforce housing development, but it also contains provisions to appease high-end developers that will exacerbate an already overcrowded Tahoe Basin. The amendments will intensify the ever-increasing gridlock on Tahoe’s roads and cause further declines in Lake Tahoe’s water quality.

These amendments seem to be driven by (1) an economic study done in 2019 and (2) the California legislature enacting laws making it easier for development to occur. Regarding the latter, there needs to be exceptions made for the Tahoe Basin with its very unique environment and a nationally treasured lake at its center. The way the rest of California accommodates for its lack of housing should not dictate how the Tahoe Basin tries to do the same. Although the Sierra Club has generally long supported increasing density in city centers to prevent sprawl, to attempt to use this same model here in the Basin would be a mistake by ignoring the unique challenges here in the Basin with regard to limited carrying capacity and the need to protect the lake. These amendments should focus more on what is truly needed, which is workforce housing rather than placating developers for economic gain. There needs to be greater emphasis on protection of Lake Tahoe and the environment than on meeting the demands of developers. Regarding the economic study, yes, this is a tourist economy, but to solely base these amendments on this study ignores the current downward trends in the health of the lake (see UC Davis Report) and the current residents’ sentiments about being tired of the gridlock on the roads and agencies ignoring their voices over the developers’ and business interests’ voices.

The stated reason by Placer County staff on November 9, 2022 for the amendments are to “make it easier for the developers.” When it becomes easier for the developers, the environment always loses. Our concerns are increased height, scenic view threats, bigger footprints and obviously more density. With that comes threats to the lake’s clarity and air quality degradation.

The public opinion has been consistent: protecting the environment, concern for emergency evacuation in case of a wildland fire and workforce housing. The proposed plan calls for 50% deed restriction for local workforce for new development. Why only 50%? This will only encourage more tourist accommodations, more traffic, more air quality and traffic concerns.

The County’s PowerPoint presentation on November 9, 2022 contains contradictions and statements that are unsupported by verifiable facts. While slide 9 states that the proposed TBAP amendments will not increase overall building height, slide 27 clearly states that heights are proposed to be increased. Slide 9 also states the TBAP amendments will not increase overall density and carrying capacity, which appears to be exactly what is being proposed. Just saying something does not make it so. If this is indeed the case, verifiable evidence and all details quantifying and substantiating this claim must be disclosed to the public. How does creating “new high-quality lodging,” expediting building permits, increasing building length, and decreasing lot size so that more and more development can be squeezed into the area not lead to increases in both density and carrying capacity? And how does this increase workforce housing?

We are skeptical about the reduction of parking requirements for new buildings. It was suggested that public parking could be shared with current businesses. Although that sounds promising, what happens during business hours? Are residents and visitors expected to move their cars? How would local businesses feel about their lots being filled by non-customers? It was suggested that paid street parking could be instituted. Residents are already complaining that visitors are parking on residential streets to avoid parking fees. Instead of instituting additional parking fees that would penalize locals as well as visitors, street parking on neighborhood streets should be limited to vehicles with a “local’s sticker” – and that restriction should be enforced!

One idea in the proposal that we support enthusiastically is reducing the short-term rental (STR) cap for each new lodging unit. We would like to see this concept expanded to cover not just “new lodging”, but every new housing unit constructed. Let’s get tourists out of the neighborhoods and free up neighborhood housing for the people who work and live here full time.

The Tahoe Basin is in a high fire danger area. If the County plans to rely on what was stated in the 2016 Environmental Impact Report (EIR) for the TBAP regarding evacuation planning in its Initial Study, this would not be acceptable on the basis that the EIR did not actually provide any evidence, only conjecture, that impacts were either avoidable or insubstantial. Examples of this conjecture were statements such as “impacts would likely be immeasurable” and roadways “would likely be controlled by emergency personnel.”

Regarding using TRPA’s Vehicle Mile Transfer (VMT) standards, those were revised and no longer exist as such and therefore a full analysis of how this plan would affect transportation in the Basin needs to be done. Deferring and delegating to TRPA will not be acceptable.

The climate change impacts need to be fully analyzed with permanent, enforceable, verifiable, and quantifiable performance standards. Likewise, cumulative impacts must be fully analyzed and quantified with verifiable evidence, especially considering the numerous development projects in the County’s pipeline scheduled for environmental review (Boulder Bay, Tahoe Inn, Cal-Neva, 39 degrees, laulima, Martis Valley West, Condos at Jason’s in KB, Neptune Investments next to the bakery, Tahoe City Lodge, Boatworks, Homewood, and Palisades).

The University of California at Davis recently reported the lake water quality at its lowest since data collection has begun. Fodor’s Travel is advising its readers NOT to go to Lake Tahoe. And yet, we are being presented plans for more and more development. When does the conversation about the region’s capacity begin?

Alternatives to affordable housing that don’t include new development should be included in a full environmental review of any new amendments to the TBAP. An environmental document that does not fully analyze cumulative, climate change, evacuation, and transportation impacts or tries to use a previously approved EIR or relies on TRPA’s review of the amendments as its basis will open the County up to legal challenges.The TBAP should have much more environmental documentation than what is proposed and should be an EIR so that the public can properly review what the County is proposing.