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Tioga Inn project goes before Planning Commission for decision on April 16, 2020

April 11th, 2020 by Bartshé, Eastern Sierra Policy Director

Despite the ongoing Covid-19 crisis, the Mono County Planning Commission is moving forward with a public hearing and vote on the Tioga Inn Specific Plan Amendment & Final Subsequent Environmental Impact Report (FSEIR).

A view of the site where the proposed Tioga Inn housing project would go, overlooking Mono Lake. Photo courtesy of Lynn Boulton.

The meeting will take place on Thursday, April 16 at 9:00am.

The Planning Commission meeting is a critical decision moment on the future of this poorly-planned development, and the Commissioners need to hear from you. If you are concerned about this project, the most effective thing you can do is to attend the virtual Planning Commission meeting prepared to make a verbal comment.

We anticipate that the individual time allotment for each commenter will be short. Therefore, we suggest the following for preparing your verbal comment:

  1. Clearly state your name and briefly explain your connection to the Mono Basin
  2. Immediately state your specific primary concern with the project as succinctly as possible (see bullet points below as launch points)
  3. Conclude with a clear statement such as: These adverse impacts could have been addressed by better project planning and design but there are insufficient mitigations required in the project documents. I am asking the Planning Commission to vote no on Resolution R20-01.

If you prefer to make your concern heard without speaking, you can prepare your comment ahead of time, and comment via email (before the end of the agenda item) and via chat directly during the meeting.

Read on for the Committee’s analysis of this problematic project, which should be helpful in formulating your comment(s) to the Planning Commission.

OverviewLasting negative impacts and no clear benefit

The Tioga Inn FSIER proposes to triple the population of Lee Vining by developing seven acres of ridgeline adjacent to the Mobil station (Tioga Gas Mart) and Whoa Nellie Deli at the Tioga Pass junction south of Lee Vining with multi-story market-rate housing units designated to support construction of a large, previously-approved hotel and restaurant. Extensive public concern about the visual impacts from the shore of Mono Lake, project location and design, wildlife impacts, fire safety, and lack of community connection were expressed during the draft document review period with 904 comments submitted, plus lengthy, detailed concerns from the Mono Lake Committee, state agencies, local fire departments, Lee Vining community members, and the public.

The final proposal does little to resolve the major public concerns. Although some changes were made in response to public comment, the new project package does not solve the major identified problems and does not eliminate the significant impacts identified in the environmental study. Even Mono County’s latest analysis of the project concludes the project will cause significant, unavoidable impacts in four areas of major concern. The Tioga Inn development will be the largest and most visible of its kind considered by Mono County in many years, and the negative impacts substantially outweigh the benefit of the project objective.

What are the impacts?

  1. Significant, unavoidable impacts to the scenic and visual resources of the Mono Basin, and the valuable dark-sky resources of the Mono Basin.
  2. Significant, unavoidable, cumulative impacts to the mule deer herd in Lee Vining Canyon.
  3. Exposed and dangerous travel conditions imposed on pedestrians and cyclists along Highway 395 between Lee Vining and the project site.
  4. Increased traffic dangers imposed at the junction of Highway 395 and Highway 120 West.

For the Mono Lake Committee, all of these impacts are concerning. The project places buildings directly into the iconic views of Mono Lake, tufa towers, and the Sierra Nevada that are enjoyed by hundreds of thousands of visitors each year. The irreversible impacts to the scenic nature of the Mono Basin would affect visitor experiences at locations throughout the Mono Lake Tufa State Natural Reserve and the Mono Basin National Forest Scenic Area. The cumulative significant impacts to mule deer and the cascading safety impacts due to vehicle-deer collisions around the project area also raise concerns. From a community and safety perspective, the lack of pedestrian and cyclist connectivity with Lee Vining directly threatens the health and safety of both visitors and Mono Basin community members and is a rejection of the goals of the Mono Basin Community Plan and modern principles of designing walkable communities.

What is the Tioga Inn project objective?

The Tioga Inn FSEIR proposes adding 100 units containing 150 bedrooms of housing, 190 additional parking spaces, a 30,000-gallon propane tank, a third gas pump island and overhead canopy, a wastewater treatment system, a replacement water tank, and changes to lot boundaries and land use designation. The additional 100 units of housing would be located on top of the ridge that extends south of the proposed restaurant.

The stated project objective is “To provide sufficient workforce housing on the project site to accommodate a majority of employees of the hotel, the full-service restaurant and other onsite land uses.” While most people would agree that well-planned housing is valuable and much in demand in Mono County, this project contains no provisions or promises for affordable housing, nor does it help solve the housing shortage in the region. While 100 units/150 bedrooms of housing may look great on paper, the reality is that the FSEIR makes clear that these units will not meet the projected workforce housing needs of the future new hotel and restaurant when employees and their families are considered in the housing needs. In other words, at full build-out, the complete project will likely increase the employee housing shortage in the Mono Basin and Mono County, making existing housing more expensive and creating challenges for existing businesses trying to house their workers. An integrated project plan for the hotel, restaurant, and worker housing would be the best way to solve this problem—and is something the Committee has pointed out in detail—but unfortunately, Mono County has declined to take a comprehensive approach.

The project proposes a long list of problems for the Mono Basin and Lee Vining Community 

The Tioga Inn project, if approved, will bring a multitude of potential problems and impacts. The points below represent some of the salient project issues. We are encouraging those willing to comment to use this list as a jumping off point for formulating your own specific comments to the Planning Commission.

If you are one of the over 900 people who commented on the draft document, you will be interested to see the response to your comments in the final document. If you are not satisfied with the response you will have a good point to bring up at the meeting. Responses can be reviewed here in sections 2–5 of the FSEIR. Comment letters can be reviewed in Appendix B of the documents.

The project will degrade the Mono Basin’s spectacular views

  • The Tioga Inn project will bring significant visual impacts to the shores of Mono Lake, the Mono Basin National Forest Scenic Area, and Mono Lake Tufa State Natural Reserve.
  • The project will be a major distraction from South Tufa—the #1 visitor destination site in Mono County, loved for its expansive views—because it will intrude into the striking view of Mono Lake and Sierra peaks with daytime visibility, sunrise reflections, and nighttime glowing lights.
  • The proponent claims in the FSEIR that the project will not be visible from the South Tufa parking lot, but this is irrelevant since visitors take maximum enjoyment from the lakeshore with tufa towers and lake vistas, compared to the views from a busy gravel parking lot with bathrooms.
  • The project will create a visual distraction from multiple recreation sites in the Mono Basin (Panum Crater, back porch of the Visitor Center, County Park Boardwalk, Black Point, etc.) within the Mono Basin National Forest Scenic Area and Mono Lake Tufa State Natural Reserve. Despite what the FSEIR claims, the project area will be visible from large swaths of the north part of Mono Lake and the Mono Basin.
  • A “new” alternative, Alternative 6, was added in the FSEIR that has visual mitigations (slightly lower elevational grading and one-story buildings along the eastern boundary of the moraine), but this partial improvement does not shield the full project from view and just highlights that more could have been done to fully hide the project from Mono Lake.
  • Even with a new alternative, Mono County’s own updated environmental analysis concludes the project will create significant, unavoidable visual impacts.
  • Night sky resources will be significantly and adversely impacted despite a more detailed lighting plan in the FSEIR. The Tioga Inn housing will create a new, concentrated ambient light source, which will broadcast from an elevated location across the Mono Basin.
  • New paved roads and new parking lots will enable moving vehicle headlights to sweep and broadcast out over the Mono Basin, ruining night photography activity at South Tufa and many other locations. Landscaped berms will not block all vehicle lights and not along connecting roads.
  • Mono County’s own updated environmental analysis concludes the project will create significant adverse impacts to the scenic and dark sky resources of the Mono Basin.

Negative impacts to deer are unavoidable 

  • The Tioga Inn project will bring significant, adverse, and unavoidable cumulative impacts to the Casa Diablo Mule Deer Herd.
  • While mitigation exists in the form of a narrow open space corridor below and east of the project area adjacent to Highway 395, and pet kennel and leashing requirements are outlined, these untested mitigations are not sufficient to reduce cumulative project impacts.
  • While the project area will not be considered for a future wildlife passageway according to Caltrans, the growing scope of the Tioga Inn project will further constrain migrating deer and will likely result in additional deer-vehicle collisions immediately north and south of the intersection of Highway 395 and Highway 120 West. Caltrans’ 2016 Wildlife Vehicle Collision Reduction Feasibility Study Report referenced in the Tioga Inn FSEIR indicates peak deer-vehicle impacts immediately south and north of the project intersection.
  • The cumulative impacts to the mule deer herd and the potential for further deer-vehicle collisions near the project area demonstrate that this project poses a threat to both deer and human safety.

Serious safety impacts

  • The increased traffic danger at the intersection of Highway 395 and Highway 120 West is an acknowledged significant adverse impact due to the large number of vehicle trips the project will add to existing traffic. The project will lead to more accidents, injuries, possible fatalities, and increased stress on the Lee Vining Volunteer Fire Department and Mono County emergency medical services.
  • The project provides no connectivity between Lee Vining and the project site, meaning kids cannot ride bicycles to school and project residents cannot walk to the market safely. Some will try anyway, inappropriately using the shoulder of US Highway 395, where they will be exposed and vulnerable, leading to more accidents and possible fatalities.
  • The project should not be approved without a solution that allows for safe and appropriately connected travel for pedestrians and cyclists between Lee Vining and the project site.
  • The project area does not have a safe evacuation route in case of wildfire. While the project meets existing fire regulations, there is no required escape route that would enable the safe and orderly evacuation of the fully built complex (hotel, restaurant, housing units, Tioga Gas Mart). Past wildfire activity in Lee Vining Canyon has shut down existing ingress/egress and the proposed “voluntary” evacuation route leads up-canyon and up-wind towards potential wildfire starts. As many as 500–1000 residents, hotel guests, visitors could be on site during peak visitor/wildfire season, and there is no safe evacuation alternative in the event of wildfire near the Tioga Inn site.
  • Increased vehicle impacts with deer will occur across Highway 395 with the full project development.

The community housing paradox

  • The Tioga Inn FSEIR will ultimately make the existing housing shortage problem worse for Mono County.
  • The FSEIR states “The proposed 100 units would have the capacity to house roughly two thirds of the forecast future onsite employees.” Clearly this does not solve a housing shortage, it would make it worse. Housing is prioritized for project site staff and their families, and the proponent consultant and Mono County planning staff have acknowledged that the project would not meet all the housing needs of on-site staff and their families when the restaurant and hotel are completed.
  • At full build-out, Mono Basin and surrounding communities will experience exacerbated seasonal housing shortages and increased rents.
  • The project deliberately avoids any guarantees that the housing will be affordable.
  • The FSEIR adds a new phasing approach to the project construction; however, the first phase—and resulting impacts—activates immediately and the triggers for subsequent construction phases are only weakly tied to the hotel project.
  • The second construction phase linked to hotel and restaurant construction may put existing tenants in competition with newly needed restaurant/hotel employees, exacerbating the housing shortage. New employees needed for the restaurant and hotel will not necessarily have housing if that housing is filled with other tenants.
  • The FSEIR notes that the Community Housing Phasing Plan “provides flexibility to construct fewer units if housing demand is lower than projected.” But why would the housing demand be lower than projected if 187 employees and their families need housing with build-out of the hotel and restaurant, and yet this is not enough housing to meet the needs of project completion? This leads to a serious question: is the FSEIR initiated to simply build an apartment complex with no intent to build a hotel and restaurant as identified in the 1993 Specific Plan? If this is merely an apartment complex project, then the FSEIR should be rejected, and low-impact approaches using the planned hotel site could easily be crafted into a new project that would avoid visual impacts and benefit the community.

The project is significantly at odds with the Mono Basin Community Plan

  • The Mono Basin Community Plan is the result of a community-based planning effort to guide future land use, development, and quality-of-life decisions. The plan was used to update the Mono Basin Area Plan in the Mono County General Plan Land Use Element.
  • The Tioga Inn FSEIR is in direct conflict with the spirit and intent of the Community Plan and it is contrary to most of the plan’s values, policies, goals, and objectives.
  • The Tioga Inn project threatens to erase the small, rural character of Lee Vining by tripling the population of Lee Vining and creating a distinct, separate, concentrated development that overshadows the town of Lee Vining.
  • The Community Plan places great value on Lee Vining retaining its small-town character. Mono County Planning Department staff and the proponent’s consultant stress that Lee Vining (population 400) will remain, by definition, a small town since its population will remain below 10,000 residents. Lee Vining residents, and the many Mono Basin community members who worked on the Community Plan, have found this insulting. Imposing a sliding scale on a small-town rural population that could increase up to 100-fold was neither expressed nor implied in the Community Plan.
  • Any town or community in Mono County—or anywhere in California—would be alarmed by a private development that threatened to triple its population.
  • Affordable community housing ideas that are located in Lee Vining and solve real community housing needs are already being pursued with the Mono Basin RPAC, interested community members, and Supervisor Bob Gardner.
  • Because of the lack of pedestrian and bicycle connectivity, the project will force visitors and residents of the Tioga Inn complex to overwhelm Lee Vining with vehicle-visits. Parking in Lee Vining is already constrained, and adding up to 300 residents in an adjacent development with no walkable connection threatens significant parking impacts for Lee Vining.

The Tioga Inn project is perpetually shifting and evolving

  • The public does not know what this project will be in the future because 27 years after the original project proposal, the project on the ground today is not what was envisioned in the original specific plan.
  • The hotel and restaurant, approved in 1993, have never been built.
  • Unapproved employee housing cabins were constructed on the bluff, south of the flagpole, many years ago. What might the proponent build or do in the future without Mono County approval?
  • A Planning Department-approved cell tower with a red light sits prominently on the property, creating visual and night-sky impacts that were never included/analyzed in the original specific plan.
  • The Whoa Nellie Deli and outdoor concert area, also not included in the original specific plan, have led to significant traffic use and impacts on Highway 120 West and at the junction of Highway 395.
  • The current FSEIR is the third specific plan amendment in an extensive history of amendment and director review changes to the project site. Two previous amendments totaling 15 changes and a retroactively permitted Director Review in 2012 demonstrate that the Tioga Inn project is in a perpetually confusing state of change. Future amendments are likely to be proposed and these could substantially change or alter the scope and scale of the project site.

The project threatens a classic gateway visitor experience

  • The Mono Lake-Yosemite gateway community of Lee Vining is small, rural, scenic, and unique. The area has escaped and resisted substantial over-development and poorly conceived projects that have plagued other gateway communities around the country.
  • The Tioga Inn project, as currently proposed with its multiple significant impacts, threatens the character of Mono County’s Yosemite gateway community, and sets a poor example for future projects in the county along the Highway 395 corridor.
  • The project is not consistent with Mono County’s “Wild by Nature” campaign, and it devalues the very resources that Mono County takes pride in.
  • The community of Lee Vining and Mono County deserve a project which is consistent and more thoughtfully aligned with community interests and the natural and scenic landscape values of Mono Lake and Yosemite National Park.

For all the points outline above, the Mono Lake Committee will be taking part in the Planning Commission meeting to ask that the Commission not vote in favor of this excessively impactful project. We hope you will be there with us as well.

If you have questions, please contact me, Policy Director Bartshe Miller, either by email or at (760) 647-6595 x121.


One Response to “Tioga Inn project goes before Planning Commission for decision on April 16, 2020”

  1. avatar Light Pollution By Mono Lake On Track To Increase - Jeff Sullivan PhotographyJeff Sullivan Photography Says:

    […] pollution certainly isn’t the only concern over this project (some others are detailed here), but I can assure you that the growing trend of night sky tourism that already occurs in Mono […]