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August 30, 2010
Final EIR
2030 Final EIR
www.buttegeneralplan.net
TABLE OF CONTENTS
i
1. INTRODUCTION .................................................................................... 1-1
2. REPORT SUMMARY................................................................................. 2-1
3. REVISIONS FOR THE DEIR ....................................................................... 3-1
4. LIST OF COMMENTORS........................................................................... 4-1
5. COMMENTS AND RESPONSES.................................................................. 5-1
6. MITIGATION MONITORING AND REPORTING PROGRAM ............................ 6-1
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
TABLE OF CONTENTS
ii
List of Figures
Figure 3-2 Planning Area.....................................................................3-4
Figure 3-5 Projected 2030 Residential Buildout ..................................3-5
Figure 4.6-5 Active Mines.....................................................................3-18
Figure 4.6-6 Mineral Resource Zone 2 Sites.........................................3-20
Figure 4.7-1 Fire Hazard Severity Zones..............................................3-22
List of Tables
Table 2-1 Summary of Impacts and Mitigation Measures..................2-8
Table 4.3-2 Ambient Air Quality Monitoring Data Measured at
Monitoring Stations within Butte County ......................3-10
Table 4.14-1 Water Supplier Overview.................................................3-45
Table 6-1 Mitigation Monitoring and Reporting Program................6-2
1 INTRODUCTION
1-1
A. Purpose of the Environmental Impact Report
This document has been prepared in the form of an addendum to the Draft
Environmental Impact Report (EIR) for the proposed General Plan 2030.
The Draft EIR identified the likely environmental consequences associated
with the project, and identified policies contained in the proposed General
Plan 2030 that help to reduce potentially significant impacts.
This Final EIR responds to comments on the Draft EIR and makes revisions
to the Draft EIR as necessary in response to these comments. Revisions to
the proposed General Plan 2030 made in response to these comments are
presented in a memorandum that will be considered by the Butte County
Board of Supervisors as part of the adoption of General Plan 2030. None of
these revisions result in significant changes to the Project Description or
findings of the Draft EIR that would trigger the need to recirculate the Draft
EIR.
This document, together with the Draft EIR, will constitute the Final EIR if
the Butte County Board of Supervisors certifies it as complete and adequate
under the California Environmental Quality Act (CEQA).
B. Environmental Review Process
According to CEQA, lead agencies are required to consult with public
agencies having jurisdiction over a proposed project, and to provide the
general public and project applicant with an opportunity to comment on the
Draft EIR. This Final EIR has been prepared to respond to those comments
received on the Draft EIR and to clarify any errors, omissions or
misinterpretations of discussions of findings in the Draft EIR.
The Draft EIR was made available for public review on April 8, 2010. The
Draft EIR was distributed to local and State responsible and trustee agencies,
and the general public was advised of the availability of the Draft EIR
through public notice published in the local newspaper and posted by the
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
INTRODUCTION
1-2
County Clerk as required by law. The CEQA-mandated 45-day public
comment period ended on June 7, 2010.
On April 22, 2010, a Planning Commission hearing was held to receive
comments on the Draft EIR during the official public review period. The
hearing was held in the Butte County Board of Supervisors Chambers,
located at 25 County Center Drive in Oroville, California.
Copies of all written comments received on the Draft EIR, as well as a
transcript of the Planning Commission hearing on the Draft EIR, are
contained in this document.
This Final EIR will be presented at a Planning Commission hearing at which
the Commission will advise the Board of Supervisors on certification of the
EIR as a full disclosure of potential impacts, mitigation measures and
alternatives.
However, the Planning Commission will not take final action on the EIR or
the proposed project. Instead, the Board of Supervisors will consider the
Planning Commission’s recommendations on the Final EIR and the proposed
General Plan 2030 during a noticed public hearing and make the final action
with regard to certification of the Final EIR. The Board of Supervisors is
currently scheduled to certify the Final EIR at a public hearing on September
29, 2010.
C. Document Organization
This document is organized into the following chapters:
♦ Chapter 1: Introduction. This chapter discusses the use and
organization of this Final EIR.
♦ Chapter 2: Report Summary. This chapter is a summary of the
findings of the Draft and the Final EIR. It has been reprinted from the
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
INTRODUCTION
1-3
Draft EIR with necessary changes made in this Final EIR shown in
double underline and strikethrough.
♦ Chapter 3: Revisions to the Draft EIR. Corrections to the text and
graphics of the Draft EIR are contained in this chapter. Double
underlined text represents language that has been added to the EIR; text
with strikethrough has been deleted from the EIR.
♦ Chapter 4: List of Commentors. Names of agencies and individuals
who commented on the Draft EIR are included in this chapter.
♦ Chapter 5: Comments and Responses. This chapter contains
reproductions of the letters received from agencies and the public on the
Draft EIR. The responses are keyed to the comments which precede
them.
♦ Chapter 6: Mitigation Monitoring and Reporting Program. This
chapter lists the mitigation measures included in the Draft EIR, and iden-
tifies programs for monitoring and reporting the progress on implement-
ing these measures.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
INTRODUCTION
1-4
2 REPORT SUMMARY
2-1
This is a summary of the findings of the Draft and Final EIRs. This docu-
ment has been reprinted from the Draft EIR with necessary changes made in
this Final EIR shown in double underline and strikethrough.
This summary presents an overview of the analysis contained in Chapter 4 of
the Draft EIR: Environmental Evaluation. CEQA requires that this chapter
summarize the following: 1) areas of controversy; 2) significant impacts; 3)
unavoidable significant impacts; 4) implementation of mitigation measures;
and 5) alternatives to the project.
A. Project Under Review
This EIR provides an assessment of the potential environmental consequences
of adoption of the Butte County General Plan 2030 and Airport Land Use
Compatibility Plan (ALUCP) override. The General Plan is the principal
policy document for future conservation and development in the county, and
it has a 20-year planning horizon. Because General Plan 2030 includes densi-
ties that are not consistent with the Airport Land Use Compatibility Zones
in the ALUCP, adoption of this document requires an override of the
ALUCP. The proposed project is described in a greater level of detail in
Chapter 3 of the Draft EIR.
B. Areas of Controversy
The County issued an official Notice of Preparation on September 15, 2008
and held a scoping meeting on October 1, 2008. The official Notice of Prepa-
ration for this Program EIR was issued to the Governor's Office of Planning
and Research, and forwarded to federal, State, and local agencies, and inter-
ested parties. The official scoping period for this EIR was between September
15, 2008 and October 14, 2008, during which interested agencies and the pub-
lic could submit comments about the proposed project. The comments re-
ceived focused primarily on the following issues:
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REPORT SUMMARY
2-2
♦ Impacts related to farmland conversion and conflicts with Williamson
Act contracts, and mitigation options, such as conservation easements
and mitigation fees;
♦ Impacts related to air pollution;
♦ Impacts related to historical and archaeological resources;
♦ Impacts related to hazards;
♦ Impacts related to stormwater quality and drainage;
♦ Consistency with municipal plans;
♦ Impacts on public services;
♦ Impacts on the State Highway System;
♦ Strategies to reduce vehicle miles traveled and increase use of transit and
alternative modes of transportation;
♦ Impacts related to rail safety;
♦ Wastewater treatment capacity; and
♦ Impacts related to greenhouse gas (GHG) emissions.
All of these issues were addressed in the General Plan 2030 process. To the
extent that these issues have environmental impacts, they are also addressed in
this EIR.
C. Significant Impacts
Under CEQA, a significant impact on the environment is defined as a sub-
stantial, or potentially substantial, adverse change in any of the physical con-
ditions within the area affected by the project, including land, air, water, min-
erals, flora, fauna, ambient noise, and objects of historic and aesthetic signifi-
cance.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REPORT SUMMARY
2-3
As described in Chapter 3 of the Draft EIR, Project Description, implementa-
tion of the proposed General Plan 2030 and ALUCP override is anticipated to
result in the development of approximately 13,700 new dwelling units and the
addition of 33,800 new residents, as well as the development of 1.8 million
square feet of new retail and office space and 1.1 million square feet of new
industrial space by 2030. This development, in combination with long-term,
region-wide growth and development, has the potential to generate environ-
mental impacts in a number of areas, including direct construction impacts on
biological and cultural resources; indirect impacts associated with use of this
built environment on areas such as transportation, air quality, and noise; and
capacity impacts to utilities and public services, such as water service, waste-
water, solid waste, schools, and parks.
However, by incorporating policies intended to avoid environmental impacts
and by steering development to existing incorporated and unincorporated
cities and communities, General Plan 2030 is largely self-mitigating. Rather
than mitigating impacts from implementation of General Plan 2030 through
mitigation measures in this EIR, the policies and land use map in General
Plan 2030 are intended to prevent the majority of environmental impacts al-
together.
The ALUCP override also has the potential to generate environmental im-
pacts within the county; however, the ALUCP override is not a policy docu-
ment and therefore is not self-mitigating.
The implementation of the proposed General Plan 2030 has the potential to
generate 24 26 significant environmental impacts. Of these impacts, 18 19 are
the result of the proposed General Plan 2030 and ALUCP override, and six
are the result of General Plan 2030 combined with other cumulative devel-
opment in the larger region, and one is considered an impact of both the pro-
posed General Plan 2030 and cumulative development. Throughout this EIR,
the terms “project” or “proposed project,” are used to refer to the implemen-
tation of General Plan 2030 and the ALUCP override, which will govern all
development in unincorporated Butte County over the life of the document.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REPORT SUMMARY
2-4
The term “cumulative” refers to General Plan 2030 as well as development
that will happen in the incorporated municipalities and the surrounding re-
gion.1
The significant project impacts are in the following topic areas:
♦ Agriculture (two project impacts)
♦ Hydrology and Water Quality (two project impacts)
♦ Land Use (one project impact)
♦ Noise (one project impact)
♦ Transportation and Circulation (13 project impacts)
The significant cumulative impacts are in the following topic areas:
♦ Agriculture
♦ Biological Resources
♦ Hydrology and Water Quality
♦ Land Use
♦ Noise
♦ Transportation and Circulation
The significant impact considered to result from both the project and cumula-
tive development in the region is in the GHG emissions analysis. This is be-
cause climate change is the result of cumulative global emissions. There is no
single project, when taken in isolation, that can “cause” climate change, as a
single project’s emissions are insufficient to change the radiative balance of
the atmosphere. Because climate change is the result of GHG emissions, and
GHGs are emitted by innumerable sources worldwide, global climate change
is a significant cumulative impact of human development and activity. The
global increase in GHG emissions that has occurred and will occur in the fu-
ture is the result of the actions and choices of individuals, businesses, local
governments, states, and nations. Therefore, the analysis in Chapter 4.15 of
the Draft EIR addresses project and cumulative impacts in combination.
1 See also Section B in Chapter 4.0, Environmental Evaluation, and Section
D in Chapter 6, CEQA Required Assessment Conclusions, for an expanded discussion
about the cumulative analysis.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REPORT SUMMARY
2-5
General Plan 2030 contributes to all of the impacts on a programmatic level.,
while the ALUCP override contributes only to the project and cumulative
impact in the land use topic.
All of the impacts are considered significant and unavoidable. They are dis-
cussed in the following two sections and summarized in Table 2-1.
D. Mitigation Measures
This EIR suggests specific mitigation measures to reduce the significant im-
pacts of General Plan 2030. Of the 24 26 significant impacts, Impacts TRAF-
1 through TRAF-13 provide mitigation measures. However, they are found
to be significant and unavoidable after mitigation. The mitigation measures
in this EIR will form the basis of a Mitigation Monitoring and Reporting Pro-
gram, provided in Chapter 6 of this Final EIR, to be implemented in accor-
dance with State law.
E. Unavoidable Significant Impacts
Section 15126.2(b) of the CEQA Guidelines requires that an EIR describe any
significant impacts that cannot be avoided, even with the implementation of
feasible mitigation measures. As described in Chapter 4 of the Draft EIR, and
shown in Table 2-1, 24 26 significant unavoidable impacts were identified in
the areas of agriculture, biological resources, hydrology and water quality,
land use, noise, transportation and circulation, and greenhouse gas emissions.
F. Alternatives to the Project
This EIR analyzes alternatives to the proposed project. Three alternatives to
the proposed project are considered and described in detail in Chapter 5 of
the Draft EIR:
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REPORT SUMMARY
2-6
♦ No Project Alternative
♦ Concentrated Growth Alternative
♦ Rural Extension Alternative
As shown in the alternatives analysis in Chapter 5 of the Draft EIR, the Con-
centrated Growth Alternative has the least environmental impact and is
therefore the environmentally superior alternative. By focusing growth into
the spheres of influence (SOI) of the county’s municipalities and into existing
unincorporated communities, the Concentrated Growth Alternative would
make the least contribution to the significant and unavoidable impacts that
have been identified in relation to biological resources, hydrology and water
quality, noise, transportation and circulation, and greenhouse gas emissions.
The Rural Extension Alternative and the No Project Alternative would have
greater impacts than General Plan 2030 and the ALUCP override.
G. Summary Table
Table 2-1 presents a summary of impacts and mitigation measures identified
in this report. It is organized to correspond with the environmental issues
discussed in Chapter 4 of the Draft EIR. Table 2-1 distinguishes between two
types of significant impacts: on the one hand impacts that directly result from
the proposed project, which is the implementation of General Plan 2030 and
the ALUCP override and which will govern all development in unincorpo-
rated Butte County over the life of the document; and on the other hand,
impacts that result from the combination of General Plan 2030 and other
regional development, including in the incorporated municipalities and the
surrounding region.2 Although this is a programmatic EIR, CEQA defines a
“project” as any action that “has the potential for resulting in either a direct
physical change in the environment, or a reasonably foreseeable indirect
physical change in the environment (CEQA Guidelines Section 15378). Im-
2 See also Section B in Chapter 4.0, Environmental Evaluation, and Section
D in Chapter 6, CEQA Required Assessment Conclusions, for an expanded discussion
about the cumulative analysis.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REPORT SUMMARY
2-7
pacts that are the result of the proposed project are termed “project impacts,”
while impacts that are the result of the cumulative condition are termed “cu-
mulative impacts.”
The table is arranged into six columns: 1) significant impacts; 2) classification
as a project impact, as discussed above; 3) classification as a cumulative im-
pact, as discussed above; 4) significance prior to mitigation; 5) mitigation
measures; and 6) significance after mitigation. For a complete description of
potential impacts, please refer to the specific discussions in Chapter 4 of the
Draft EIR.
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SU
TR
A
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-
6
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9
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SU
TR
A
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-
7
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9
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A
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SU
TR
A
F
-
8
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SU
TR
A
F
-
9
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SU
TR
A
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-
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9
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.
SU
TR
A
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-
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9
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SU
TR
A
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9
S
T
R
A
F
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k
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tw
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.
SU
TR
A
F
-
1
4
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9
SU
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BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REPORT SUMMARY
2-16
3 REVISIONS FOR THE DEIR
3-1
This chapter presents specific changes to the text of the Draft EIR that are
being made in response to comments made by the public and/or reviewing
agencies. In each case, the revised page and location on the page is set forth,
followed by the textual, tabular or graphical revision. New text is double-
underlined and text removed is shown in strikethrough. None of the changes
constitute significant changes to the Draft EIR, so the Draft EIR does not
need to be recirculated.
All changes to Chapter 2 of the Draft EIR, including changes to the Summary
of Impacts and Mitigation Measures, are included in Chapter 2 of this Final
EIR.
The changes to the Draft EIR reflected in this chapter are supported and ex-
plained by the responses to comments in Chapter 5. As explained further in
Chapter 5, the changes to the Draft EIR include changes based on direction
by the Butte County Board of Supervisors to revise General Plan 2030 to be
consistent with the Airport Land Use Compatibility Plan (ALUCP), thus
eliminating the need for an ALUCP override. Therefore, this chapter in-
cludes extensive changes to the Draft EIR in areas that refer to the ALUCP
override and compatibility with the ALUCP.
The text on page 1-1 and the top of page 1-2 is hereby amended as fol-
lows:
This Environmental Impact Report (EIR) provides an assessment of the po-
tential environmental consequences of adoption and implementation of the
proposed Butte County General Plan 2030 and Airport Land Use Compati-
bility Plan (ALUCP) override. This assessment is intended to inform county
residents, decision-makers, and responsible and trustee agencies of the nature
of General Plan 2030 and the ALUCP override, and their effect on the envi-
ronment. This EIR was prepared in accordance with and in fulfillment of
California Environmental Quality Act (CEQA) requirements. Butte County
is the Lead Agency for this EIR.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-2
A. Proposed Action
The proposed project is a comprehensive update of the existing Butte County
General Plan, as well as the associated override of the ALUCP. The General
Plan is the principal policy document for future conservation and develop-
ment in the county, and it has a 20-year planning horizon. Because General
Plan 2030 includes densities that are not consistent with the Airport Land Use
Compatibility Zones in the ALUCP, adoption of this document requires an
override of the ALUCP. The proposed project is described in a greater level
of detail in Chapter 3.
B. EIR Scope, Issues, and Concerns
This document is a countywide Program EIR that analyzes potential envi-
ronmental impacts of the adoption of the proposed General Plan 2030 and
ALUCP override. Program EIRs are not project-specific and do not evaluate
the impacts of specific development ‘projects’ that may be proposed under
General Plan 2030. Such projects will require separate environmental review
to secure the necessary development entitlement. This EIR is intended,
where appropriate, to be used as a first-tier environmental document for fu-
ture projects, but it is not intended to address impacts of individual develop-
ment projects.
The third and fifth bullet points at the bottom of page 1-4 and the top of
page 1-5 is hereby amended as follows:
This document is organized into the following chapters:
♦ Chapter 3: Project Description. This chapter describes General Plan
2030 and the ALUCP override in detail, including a listing of proposed
land use designation changes.
♦ Chapter 5: Alternatives to the Proposed Project. This chapter consid-
ers three alternatives to the proposed project, including the CEQA-
required “No Project Alternative.”
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-3
The text at the bottom of page 1-5 and the top of page 1-6 is hereby
amended as follows:
Following the close of the public review period, a Final EIR will be prepared
to respond to all substantive comments regarding the Draft EIR. The Final
EIR will be made available for public review prior to consideration of its cer-
tification by Butte County. The County will hold public hearings to con-
sider the certification of the Final EIR and the adoption of the Butte County
General Plan 2030, and Findings of Overriding Consideration, and ALUCP
override, which may be approved as drafted or modified.
Figure 3-2 on page 3-6 is replaced as shown on the following page.
Figure 3-5 on page 3-6 is replaced as shown on page 3-5.
The text on page 3-11 is hereby amended as follows:
1. General Plan 2030 Process
The process to update the existing Butte County General Plan began in Sep-
tember 2006 and is scheduled to be completed with the adoption of the Gen-
eral Plan and ALUCP override by the Board of Supervisors, in 2010. General
Plan 2030 was developed with extensive community input and reflects the
community’s vision for Butte County.
The text at the bottom of page 3-15 and top of page 3-16 is hereby
amended as follows:
As required by State law, the Public Review Draft General Plan 2030 has
been available for public comment, and this EIR will be circulated for a re-
view period at least 45 days in length. In addition, the summary of changes to
the Public Review Draft General Plan 2030 from the Butte County Board of
Supervisors meetings on January 19 and 21, 2010 is being circulated for re-
view with this EIR. During this time, the public will be allowed to submit
additional comments on General Plan 2030 and this EIR. All of the com-
ments received will be taken into consideration at the public hearings held
pp Airports
Highways
Railroad
Major Roads
Sphere of Influence
City/Town Limits
Butte County Boundary
Other County Boundary
0 2.5 5 Miles
pp
pp pp
pp
|
|
|
|
|
|
|
|
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
DURHAMDURHAM
COHASSETCOHASSET
BANGORBANGOR
FOREST FOREST
RANCHRANCH
BERRY CREEKBERRY CREEK
CONCOWCONCOW
PALERMOPALERMO
FORBESTOWNFORBESTOWN
YANKEE HILLYANKEE HILL
HONCUTHONCUT
BUTTE BUTTE
MEADOWSMEADOWS
CLIPPER MILLSCLIPPER MILLS
STIRLING STIRLING
CITYCITY
NELSONNELSON
DAYTONDAYTON
NORDNORD
RICHVALERICHVALE
THERMALITOTHERMALITO
FEATHERFEATHER
FALLSFALLS
CHICOCHICO PARADISEPARADISE
OROVILLEOROVILLE
GRIDLEYGRIDLEY
BIGGSBIGGS
Glenn
County
Colusa
County
Sutter County
Tehama County
Yuba
County
Plumas
County
Nevada
County
99
99
70
70
32
191
162
162
Source: Butte County GIS, 2009.
PLANNING AREA
FIGURE 3-2
BUTTE COUNTY
GENERAL PLAN 2030
DRAFT EIR
PROJECT DESCRIPTION
|ÿÿ149
pp
pp pp
pp
|
|
|
|
|
|
|
|
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
DURHAMDURHAM
COHASSETCOHASSET
BANGORBANGOR
FOREST FOREST
RANCHRANCH
BERRY CREEKBERRY CREEK
CONCOWCONCOW
PALERMOPALERMO
FORBESTOWNFORBESTOWN
YANKEE HILLYANKEE HILL
HONCUTHONCUT
BUTTE BUTTE
MEADOWSMEADOWS
CLIPPER MILLSCLIPPER MILLS
STIRLING STIRLING
CITYCITY
NELSONNELSON
DAYTONDAYTON
NORDNORD
RICHVALERICHVALE
THERMALITOTHERMALITO
FEATHERFEATHER
FALLSFALLS
C H I C OCHICO P A R A D I S EPARADISE
O R O V I L L EOROVILLE
G R I D L E YGRIDLEY
B I G G SBIGGS
MAGALIAMAGALIA
99
99
70
70
32
191
162
162
P R O J E C T E D 2 0 3 0 R E S I D E N T I A L B U I L D O U T
F I G U R E 3 -5
0 2.5 5 Miles
0 - 30
31 - 100
101 - 250
251 - 750
751 - 2700
Source: DC&E GIS, 2009.
B U T T E C O U N T Y G E N E R A L P L A N 2 0 3 0DRAFT E I R
P R O J E C T D E S C R I P T I O N
Note: Represents only residential growth. Non-residential development is not represented.
Deer Herd Migration Area Overlay (425 units)
Agriculture (1,050 units)
Timber Mountain (30 units)
Areas Designated for Non-Residential Use (0 units)
pp Airports
Greenline
Highways
Railroad
Major Roads
Sphere of Influence
City/Town Limits
County Boundary
Number of Dwelling Units Estimated for
Purposes of Projected 2030 Buildout
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-7
before the Planning Commission and Board of Supervisors prior to certifica-
tion of this EIR and adoption of General Plan 2030 and the ALUCP override.
In considering General Plan 2030 and the ALUCP override, the Planning
Commission and Board of Supervisors will review the comments received and
this accompanying EIR.
The text at the top of page 3-34 is hereby amended as follows:
g. Airport Overlay
This overlay pertains to areas that are within Airport Land Use Compatibil-
ity Zones and are subject to additional restrictions under the ALUCP. Land
uses and densities within the Airport Land Use Compatibility Zones must
comply with the current adopted ALUCP where those allowed land uses and
densities differ from General Plan 2030 land use designations, unless a devia-
tion from the ALUCP is approved by a two-thirds majority of the Butte
County Board of Supervisors.
Section E, beginning at the bottom of page 3-36, is hereby amended as
follows:
E. Conforming Amendments to Existing Area and Specific Plans
In order to maintain consistency between General Plan 2030 and existing
Area and Specific Plans, the following actions would be required at the same
time that General Plan 2030 and the ALUCP override are is adopted. Thus,
they are considered part of the proposed project evaluated by this EIR:
Footnote “c” of Table 3-5 on page 3-46 of the Draft EIR is hereby
amended as follows:
c The Timber Mountain permit history has been adjusted for the geographic
area of Timber Mountain under General Plan 2030 compared to the existing
General Plan. The geographic area assumed for Timber Mountain excludes
the Timber Preserve areas, which do not allow residential uses, and the Na-
tional Forest areas.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-8
The following text on pages 3-56 through 3-58 is hereby deleted:
H. Airport Land Use Compatibility Plan Override
The Butte County Airport Land Use Commission (ALUC) is charged with
promoting land use compatibility around the county’s airports in order to
minimize public exposure to excessive noise and safety hazards. This is pri-
marily accomplished through the preparation and periodic update of an
ALUCP, the most recent of which was adopted in 2000. The ALUCP en-
compasses the four principal airports in the county: Chico Municipal Air-
port, Oroville Municipal Airport, Paradise Skypark Airport and the
Ranchaero Airport. Public Utilities Code Section 21676 requires that the
Butte County General Plan be in conformance with the ALUCP, unless the
Board of Supervisors makes specific findings to overrule the ALUCP or por-
tions of it.
General Plan 2030 includes land use designations that are not consistent with
the Airport Land Use Compatibility Zones included in the ALUCP. In gen-
eral, General Plan 2030 would allow more residential units to be built than
would be allowed by the ALUCP within the Airport Land Use Compatibil-
ity zones. General Plan 2030 would not allow a different type of use or in-
creased heights above what is allowed under the ALUCP. The specific incon-
sistencies between the land use designations in General Plan 2030 and the
Airport Land Use Compatibility Zones in the ALUCP are as follows:
♦ Chico Municipal Airport: The VLDR land use designation, which al-
lows from 1 dwelling unit per 5 acres to 1 dwelling unit per acre, is in-
consistent with the B1 Compatibility Zone. The VLDR land use desig-
nation would be inconsistent with B2, C and C1 Compatibility Zones
unless the zoning requires a 5-acre minimum. The VLDR land use desig-
nation is inconsistent with C2 Compatibility Zone.
♦ Oroville Municipal Airport: The Rural Residential land use designa-
tion, which allows up to 1 dwelling unit per 5 acres, would be considered
inconsistent with the B1 Compatibility Zone, unless the zoning requires
a 10-acre minimum.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-9
♦ Ranchaero Airport: The VLDR, LDR and MDR land use designations
are inconsistent with the B1 and B2 Compatibility Zones. There are two
parcels in the C Compatibility Zone which are designated as VLDR.
This designation would be inconsistent.
♦ Paradise Skypark Airport: The Rural Residential land use designation,
which allows up to 1 dwelling unit per 5 acres, would be considered in-
consistent with the B1 Compatibility Zone, unless the zoning requires a
10-acre minimum. In addition, the VLDR land use designation is incon-
sistent with the C Compatibility Zone, unless the zoning requires a
5-acre minimum.
Therefore, in order to adopt General Plan 2030, the Board of Supervisors
must also override the ALUCP. Implementation of the ALUCP override
would have potential land use impacts, which are discussed in Chapter 4.9,
Land Use.
Section I on page 3-58 is hereby amended as follows:
I. Intended Uses of the General Plan
As mentioned at the beginning of this chapter, this programmatic EIR is in-
tended to review potential environmental impacts associated with the adop-
tion and implementation of the Butte County General Plan 2030 and
ALUCP override, and determine corresponding mitigation measures, as nec-
essary. Subsequent projects will be reviewed by the County for consistency
with General Plan 2030, the ALCUP override and this EIR, and adequate
project-level environmental review will be conducted as required by CEQA.
Projects successive to this EIR could include the following:
Table 4.3-2 on pages 4.3-11 and 4.3-12 is replaced as shown on the follow-
ing page.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-10
TABLE 4.3-2 AMBIENT AIR QUALITY MONITORING DATA MEASURED AT MONITORING STATIONS
WITHIN BUTTE COUNTY
Chico
Paradise Airport
Road
Paradise Fire
Station
Pollutant Standards 2006 2007 2008 2006 2007 2008 2006 2007 2008
Ozone (O3)
Maximum 1-hour
concentration (ppm) 0.090 0.094 0.111 0.104 0.102 0.125 – – –
Maximum 8-hour
concentration (ppm) 0.080 0.084 0.096 0.094 0.095 0.108 – – –
Number of days standard
exceeded:a
CAAQS 1-hour (>0.09
ppm) 0 0 2 8 1 3 – – –
NAAQS 8-hour (>0.075
ppm) 4 3 6 33 12 16 – – –
CAAQS 8-hour (>0.070
ppm) 19 10 14 59 30 23 – – –
Carbon Monoxide (CO)
Maximum 8-hour
concentration (ppm) 2.70 2.16 2.74 – – – – – –
Maximum 1-hour
concentration (ppm) 4.3 3.3 3.1 – – – – – –
Number of days standard
exceeded:a
NAAQS 8-hour (>9 ppm) 0 0 0 – – – – – –
CAAQS 8-hour (>9.0 ppm) 0 0 0 – – – – – –
NAAQS 1-hour (>35 ppm) 0 0 0 – – – – – –
CAAQS 1-hour (>20 ppm) 0 0 0 – – – – – –
Particulate Matter (PM10)b
Nationalc maximum 24-hour
concentration (μg/m3) 76.0 61.9 143.5 – – – 52.0 116.0 31.3
Nationalc second-highest 24-
hour concentration (μg/m3) 65.0 61.0 112.4 – – – 51.0 50.0 20.8
Stated maximum 24-hour
concentration (μg/m3) 81.0 66.1 140.8 – – – 48.0 108.0 30.0
Stated second-highest 24-hour
concentration (μg/m3) 70.0 65.0 111.6 – – – 48.0 47.0 20.9
National annual average
concentration (μg/m3) 26.3 21.3 27.3 – – – 19.6 17.5 9.2
State annual average
concentration (μg/m3)e 26.9 21.8 27.7 – – – 18.4 – –
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-11
Chico
Paradise Airport
Road
Paradise Fire
Station
Pollutant Standards 2006 2007 2008 2006 2007 2008 2006 2007 2008
Number of days standard
exceeded:a
NAAQS 24-hour (>150
μg/m3)f 0 0 0 – – – 0 0 –
CAAQS 24-hour (>50
μg/m3)f 26 21 27 – – – 0 – –
Particulate Matter (PM2.5)
Nationalc maximum 24-hour
concentration (μg/m3) 67.0 53.9 107.6 – – – – – –
Nationalc second-highest 24-
hour concentration (μg/m3) 59.0 53.0 93.8 – – – – – –
Stated maximum 24-hour
concentration (μg/m3) 76.1 83.7 190.9 – – – – – 39.0 –
Stated second-highest 24-hour
concentration (μg/m3) 74.0 70.2 180.1 – – – – – 27.1 –
Nationalb annual average
concentration (μg/m3) 13.2 10.7 16.4 – – – – – –
Statec annual average
concentration (μg/m3)e 14.6 14.4 18.2 – – – – – –
Number of days standard
exceeded:a
NAAQS 24-hour (>35
μg/m3)f 29 24 37 – – – – – –
Notes: CAAQS = California ambient air quality standards.
NAAQS = national ambient air quality standards.
– = insufficient data available to determine the value.
The air monitoring data for 2008 for both fine particulate matter (PM10 and PM2.5) and ozone were impacted by wildfires and
have been submitted to the State Air Resources Board and the U.S. EPA as exceptional events.
a An exceedance is not necessarily a violation.
b Measurements usually are collected every 6 days.
c National statistics are based on standard conditions data. In addition, national statistics are based on samplers using federal
reference or equivalent methods.
d State statistics are based on local conditions data, except in the South Coast Air Basin, for which statistics are based on standard
conditions data. In addition, State statistics are based on California approved samplers.
e State criteria for ensuring that data are sufficiently complete for calculating valid annual averages are more stringent than the
national criteria.
f Mathematical estimate of how many days concentrations would have been measured as higher than the level of the standard had
each day been monitored. Values have been rounded.
Sources: California Air Resources Board, 2009, CARB Databases: Aerometric Data Analysis and Management System (ADAM),
http://www.arb.ca.gov/html/databases.htm, accessed September 1, 2009; US Environmental Protection Agency, January 10,
2009, Air Data, http://www.epa.gov/air/data/reports.html, accessed September 1, 2009.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-12
The first paragraph on page 4-1 is hereby amended as follows:
This chapter consists of 15 sections that evaluate the environmental impacts
of the proposed General Plan 2030 and Airport Land Use Compatibility Plan
(ALUCP) override projected by General Plan 2030 for unincorporated Butte
County, in combination with impacts from projected growth within the in-
corporated municipalities in Butte County and adjacent counties. Therefore,
the geographic scope covered by the cumulative analysis is a larger area than
the geographic scope of the proposed project, which is unincorporated Butte
County. As described in Chapter 6, the projected growth in other jurisdic-
tions was estimated based on planning documents and conversations with the
applicable city or county’s planning staff. In each section of Chapter 4, the
cumulative impacts discussion is based on the cumulative development de-
scribed in Chapter 6.
The first paragraph on page 4.1-1 is hereby amended as follows:
This chapter discusses the existing aesthetic character of Butte County and
evaluates the potential impacts to aesthetics associated with General Plan 2030
and the Airport Land Use Compatibility Plan (ALUCP) override. The fol-
lowing evaluation assesses visual character, scenic vistas, scenic highways, and
light and glare resulting from the spatial location of development that would
be allowed by General Plan 2030.
The last paragraph on page 4.1-8 is hereby amended as follows:
C. Standards of Significance
General Plan 2030 and the ALUCP override would have a significant aesthet-
ics impact if it they would:
♦ Have a substantial adverse effect on a scenic vista.
♦ Substantially degrade the view from a scenic highway, including, but not
limited to, trees, rock outcroppings, and historic buildings.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-13
♦ Substantially degrade the existing visual character or quality of Butte
County.
♦ Expose people to substantial light or glare.
The first paragraph on page 4.1-9 is hereby amended as follows:
D. Impact Discussion
The following discussion provides an analysis of potential project and cumu-
lative aesthetic impacts that could occur as a result of implementation of Gen-
eral Plan 2030. Implementation of the ALUCP override would have no aes-
thetic impact in Butte County, and is not discussed further in this section.
The first paragraph on page 4.2-1 is hereby amended as follows:
This chapter discusses agricultural resources in Butte County and evaluates
the potential agricultural impacts associated with General Plan 2030 and the
Airport Land Use Compatibility Plan (ALUCP) override. The following
evaluation assesses farmland conversion, conflicts with Williamson Act con-
tracts, and changes in the environment that could contribute to farmland
conversion resulting from the spatial location of development that would be
allowed by General Plan 2030.
The second and third paragraphs on page 4.2-8 are hereby amended as
follows:
C. Standards of Significance
General Plan 2030 and the ALUCP override would have a significant agricul-
ture impact if it they would:
♦ Convert Prime Farmland, Unique Farmland, or Farmland of Statewide
Importance (or “farmlands of concern under CEQA”), as shown on the
maps prepared pursuant to the Farmland Mapping and Monitoring Pro-
gram of the California Resources Agency, to non-agricultural use.
♦ Conflict with a Williamson Act contract.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-14
♦ Involve other changes in the existing environment which, due to their lo-
cation or nature, could result in conversion of farmlands of concern un-
der CEQA to non-agricultural use.
D. Impact Discussion
The following discussion provides an analysis of potential project and cumu-
lative agriculture impacts that could occur as a result of implementation of
General Plan 2030. Implementation of the ALUCP override would have no
agriculture impact in Butte County and is not discussed further in this sec-
tion.
The first paragraph on page 4.3-1 is hereby amended as follows:
This chapter discusses air quality in Butte County and evaluates potential
local and regional air quality impacts associated with General Plan 2030 and
the Airport Land Use Compatibility Plan (ALUCP) override. This chapter is
based on both quantitative and spatial analyses, and was prepared using in-
formation from the California Air Resources Board, US Environmental Pro-
tection Agency, and the Butte County Air Quality Management District.
Traffic conditions were modeled by the project traffic engineers, Fehr &
Peers, using the CT-EMFAC, EMFAC2007, and CALINE4 computer mod-
els. Greenhouse gases are discussed in Section 4.15, Greenhouse Gas Emis-
sions.
The last paragraph on page 4.3-14 and the top of page 4.3-15 is hereby
amended as follows:
C. Standards of Significance
General Plan 2030 and the ALUCP override would have a significant impact
on air quality if it they would:
♦ Conflict with or obstruct implementation of the applicable air quality
plan.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-15
♦ Violate any air quality standard or contribute substantially to an existing
or projected air quality violation.
♦ Result in a cumulatively considerable net increase of any criteria pollut-
ant for which the project region is non-attainment under an applicable
federal or State ambient air quality standard (including releasing emis-
sions which exceed quantitative thresholds for ozone precursors).
♦ Expose sensitive receptors to substantial pollutant concentrations.
♦ Create objectionable odors affecting a substantial number of people.
The following text on page 4.3-17 is hereby deleted:
Implementation of the ALUCP override would have no air quality impact in
Butte County, and is not discussed further in this section.
A new subsection under Section A.1 on page 4.4-4 is hereby added:
f. Recovery Plan for Vernal Pool Ecosystems in California and Southern
Oregon
The USFWS’ Recovery Plan for Vernal Pool Ecosystems in California and
Southern Oregon (Recovery Plan) identifies several core preservation areas in
the northeastern Sacramento Valley vernal pool area that lie within Butte
County, and part of these core areas was ultimately designated as Critical
Habitat.1 The Recovery Plan states that “alternative strategies such as devel-
opment of Habitat Conservation Plans (HCPs) or other site-specific planning
methods may present opportunities to conserve species habitat and meet the
recovery criteria described in this plan.” The Butte Regional Habitat Conser-
vation Plan (HCP) and Natural Community Conservation Plan (NCCP),
which is described in Section A.3, is such a site-specific planning tool and in-
cludes the critical habitat for the vernal pool species included in the Recovery
Plan. Therefore, this EIR discusses the protection of vernal pools and vernal
1 US Fish and Wildlife Service, 2006, 50 CFR Part 17, Endangered and Threat-
ened Wildlife and Plants: Designation of Critical Habitat for Four Vernal Pool Crusta-
ceans and Eleven Vernal Pool Plants, Final Rule, Federal Register 71:7117, February 10,
2006.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-16
pool species in the context of the local HCP/NCCP rather than the more
regional Recovery Plan. Requirements and strategies in the HCP/NCCP
must be compatible with the Recovery Plan.
The last paragraph on page 4.4-69 and the top of page 4.4-70 is hereby
amended as follows:
C. Standards of Significance
General Plan 2030 and the ALUCP override would have a significant biologi-
cal resource impact if it they would:
♦ Have a substantial adverse effect, either directly or through habitat modi-
fications, on a plant or animal population, or essential habitat, defined as a
candidate, sensitive or special-status species.
♦ Have a substantial adverse effect on any riparian habitat or other sensitive
natural community type.
♦ Have a substantial adverse effect on federally-protected wetlands as de-
fined by Section 404 of the Clean Water Act, through direct removal, fill-
ing, hydrological interruption or other means.
♦ Interfere substantially with the movement of any native resident or migra-
tory fish or wildlife species, their wildlife corridors or nursery sites.
♦ Conflict with any local ordinances or policies protecting biological re-
sources.
♦ Conflict with an adopted Habitat Conservation Plan, Natural Commu-
nity Conservation Plan or other approved local, regional or State habitat
conservation plan.
The first full paragraph on page 4.4-70 is hereby amended as follows:
D. Impact Discussion
The following discussion provides an analysis of potential project and cumu-
lative biological resource impacts that could occur as a result of implementa-
tion of General Plan 2030. Implementation of the ALUCP override would
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-17
have no biological resource impact in Butte County, and is not discussed fur-
ther in this section.
The last paragraph on page 4.5-12 and the top of page 4.5-13 is hereby
amended as follows:
C. Standards of Significance
General Plan 2030 and the ALUCP override would have a significant cultural
resource impact if it they would:
♦ Cause a substantial adverse change in the significance of a historical re-
source.
♦ Cause a substantial adverse change in the significance of an archaeological
resource.
♦ Directly or indirectly destroy a unique paleontological resource or site or
unique geologic feature.
♦ Disturb any human remains, including those interred outside of formal
cemeteries.
The first full paragraph on page 4.5-13 is hereby amended as follows:
D. Impact Discussion
The following discussion provides an analysis of potential project and cumu-
lative cultural resource impacts that could occur as a result of implementation
General Plan 2030. Implementation of the ALUCP override would have no
cultural resource impact in Butte County, and is not discussed further in this
section.
The first sentence under Section B.4 on page 4.6-14 is hereby amended as
follows, and the corresponding Figure 4.6-5 is provided on the following
page:
There are currently 20 mines with permits to operate in Butte County, which
are shown in Figure 4.6-5.
ACTIVE MINES
FIGURE 4.6-5
!Active Mines
pp Airports
Greenline
Highways
Railroad
Major Roads
Sphere of Influence
City/Town Limits
County Boundary
02.55Miles
pp
pp pp
pp
|
|
|
|
|
|
|
|
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
DURHAMDURHAM
COHASSETCOHASSET
BANGORBANGOR
FOREST FOREST
RANCHRANCH
BERRY CREEKBERRY CREEK
CONCOWCONCOW
PALERMOPALERMO
FORBESTOWNFORBESTOWN
YANKEE HILLYANKEE HILL
HONCUTHONCUT
BUTTE BUTTE
MEADOWSMEADOWS
CLIPPER MILLSCLIPPER MILLS
STIRLING STIRLING
CITYCITY
NELSONNELSON
DAYTONDAYTON
NORDNORD
RICHVALERICHVALE
THERMALITOTHERMALITO
FEATHERFEATHER
FALLSFALLS
CHICOCHICO PARADISEPARADISE
OROVILLEOROVILLE
GRIDLEYGRIDLEY
BIGGSBIGGS !
!
!!
!
!
!
!!!!!!
!!!
!
!
!
!
!Pine Creek Mine/
Anderson Brothers
Carr Mine
Ohio Dix Mine
Little Chico
Creek/Stephens
Rock Quarry
Franklin Construction
Lucky 7 Pit
Daimler Rock
Pentz Aggreagates
Pentz Pit
Meridian Table
Mountain Quarry
Mineral Resources LLC
Robinson Pit
Vance Avenue
#1 and #2
Statelands
Wildlife Area
Almond Avenue Mine
Dunstone Quarry
Blue Lead Mine
Bangor Rock Quarries Site "A"
Bangor Rock Quarries Site "B"
99
70
32
191
162
162
Source: Butte County GIS, 2007.
BUTTE COUNTY
GENERAL PLAN 2030
GEOLOGY, SOILS AND
MINERAL RESOURCES
DRAFT EIR
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-19
The last sentence on page 4.6-16 is hereby amended as follows, and the
corresponding figure is updated as shown on the following page:
These two mineral resource areas are shown in Figure 4.6-5 4.6-6.
The text on page 4.6-18 and the top of page 4.6-19 is hereby amended as
follows:
C. Standards of Significance
General Plan 2030 and the ALUCP override would have a significant impact
on geology, soils or mineral resources if it they would:
♦ Expose people or structures to potential substantial adverse effects, in-
cluding the risk of loss, injury, or death involving:
y Rupture of a known earthquake fault, as delineated on the most recent
Alquist-Priolo Earthquake Fault Zoning Map issued by the State Ge-
ologist for the area or based on other substantial evidence of a known
fault.
y Strong seismic ground shaking.
y Seismic-related ground failure, including liquefaction.
y Landslides, mudslides or other similar hazards.
♦ Result in substantial soil erosion or the loss of topsoil.
♦ Be located on a geologic unit or soil that is unstable, or that would be-
come unstable as a result of the project, and potentially result in on- or
off-site landslide, lateral spreading, subsidence, liquefaction or collapse.
♦ Be located on expansive soil, creating substantial risks to life or property.
♦ Have soils incapable of adequately supporting the use of septic tanks or
alternative waste water disposal systems where sewers are not available
for the disposal of wastewater.
MINERAL RESOURCE ZONE 2 SITES
pp
pp pp
pp
|
|
ÿÿ
ÿÿ
DURHAMDURHAM
NELSONNELSON
DAYTONDAYTON
DD
RICHVALERICHVALE
THERMALITOTHERMALITO
70
191
Source: Butte County GIS, 2009.
FIGURE 4.6-6
012Miles
pp Airports
Greenline
Highways
Railroad
Major Roads
Sphere of Influence
City/Town Limits
County Boundary
Mineral Resource Zone 2 Site
BUTTE COUNTY GENERAL PLAN 2030
GEOLOGY, SOILS AND MINERAL RESOURCES
DRAFT EIR
M&T Chico Ranch
Martin Marietta Materials
Table Mountain Quarry
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-21
♦ Result in the loss of availability of a known mineral resource that would
be of value to the region or the state, or of a locally-important mineral re-
source recovery site delineated on a mineral resource plan, local general
plan, specific plan or other land use plan.
D. Impact Discussion
The following discussion provides an analysis of potential project and cumu-
lative geology, soils, and mineral resource impacts that could occur as a result
of implementation of General Plan 2030. Implementation of the ALUCP
override would have no geology, soils or mineral resource impact in Butte
County, and is not discussed further in this section.
The second paragraph in Section A.4.h on page 4.7-12 is hereby amended
as follows:
h. Office of Emergency Services (OES)
h. Office of Emergency Management (OEM)
Butte County maintains an Office of Emergency Services (OES) Office of
Emergency Management (OEM) to coordinate interagency and intergovern-
mental comprehensive emergency management planning, operations, and
disaster assistance claims management for the county. OESM works with
State and local agencies to develop effective emergency response systems
within the county. OESM acts as the requesting and coordinating agency
when situations require the involvement of State and other outside agencies.
Figure 4.7-1 on page 4.7-20 is replaced as shown on the following page.
The last paragraph on page 4.7-21 and the top of page 4.7-22 is hereby
amended as follows:
C. Standards of Significance
General Plan 2030 and the ALUCP override would have a significant hazards
and safety impact if it they would:
F I R E H A Z A R D S E V E R I T Y Z O N E S
F I G U R E 4 .7 -1
0 2 4 Miles
pp
pp pp
pp
|
|
|
|
|
|
|
|
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
ÿÿ
DURHAMDURHAM
COHASSETCOHASSET
BANGORBANGOR
FOREST FOREST
RANCHRANCH
BERRY CREEKBERRY CREEK
CONCOWCONCOW
PALERMOPALERMO
FORBESTOWNFORBESTOWN
YANKEE HILLYANKEE HILL
HONCUTHONCUT
BUTTE BUTTE
MEADOWSMEADOWS
CLIPPER MILLSCLIPPER MILLS
STIRLING STIRLING
CITYCITY
NELSONNELSON
DAYTONDAYTON
NORDNORD
RICHVALERICHVALE
THERMALITOTHERMALITO
FEATHERFEATHER
FALLSFALLS
C H I C OCHICO P A R A D I S EPARADISE
O R O V I L L EOROVILLE
G R I D L E YGRIDLEY
B I G G SBIGGS
99
99
70
70
32
191
162
162
Sources: Butte County GIS, 2009; California Department of Forestry and Fire Protection, 2007.
Moderate
High
Very High
Federal Responsibility Area
pp Airports
Major Roads
Highways
Railroad
Greenline
Sphere of Influence
County Boundary
City/Town Limits
0 2.5 5 Miles
B U T T E C O U N T Y
G E N E R A L P L A N 2 0 3 0
H A Z A R D S A N D S A F E T YDRAFT E I R
(not classified by CALFIRE)
MAGALIA
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-23
♦ Create a significant hazard to the public or the environment through the
routine transport, use, or disposal of hazardous materials.
♦ Create a significant hazard to the public or the environment through rea-
sonably foreseeable upset and accident conditions involving the release of
hazardous materials into the environment.
♦ Emit hazardous emissions or handle hazardous materials, substances or
waste within one-quarter mile of an existing or proposed school.
♦ Be located on a site which is included on a list of hazardous materials sites
compiled pursuant to Government Code Section 65962.5 and, as a result,
create a significant hazard to the public or the environment.
♦ For a project located within an airport land use plan or, where such a
plan has not been adopted, within two miles of a public airport or public
use airport, result in a safety hazard for people residing or working in the
project area.
♦ For a project within the vicinity of a private airstrip, result in a safety
hazard for people residing or working in the project area.
♦ Impair implementation of or physically interfere with an adopted emer-
gency response plan or emergency evacuation plan.
♦ Expose people or structures to a significant risk of loss, injury, or death
involving wildland fires.
The first full paragraph on page 4.7-22 is hereby amended as follows:
D. Impact Discussion
The following discussion provides an analysis of potential project and cumu-
lative hazard and safety impacts that could occur as a result of implementa-
tion of General Plan 2030 and the ALUCP override.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-24
The second full paragraph on page 4.7-23 is hereby deleted:
Since the ALUCP does not address hazardous materials, implementation of
the ALUCP override would have no impact regarding the routine transport,
use, or disposal of hazardous materials.
The second full paragraph on page 4.7-24 is hereby deleted:
Since the ALUCP does not address hazardous materials, implementation of
the ALUCP override would have no impact regarding reasonably foreseeable
accident and/or upset conditions involving the release of hazardous materials.
The first full paragraph on page 4.7-25 is hereby deleted:
Since the ALUCP does not address hazardous materials, implementation of
the ALUCP override would have no impact regarding hazardous materials
emissions near schools.
The first full paragraph on page 4.7-26 is hereby deleted:
Since the ALUCP does not address hazardous materials, implementation of
the ALUCP override would have no impact regarding development on haz-
ardous materials sites.
The text in Sections D.1.e and D.1.f on pages 4.7-26 through 4.7-29 is
hereby amended as follows:
e. For a project located within an airport land use plan or, where such a
plan has not been adopted, within two miles of a public airport or public
use airport, result in a safety hazard for people residing or working in the
project area.
As indicated in Section A.4.d, the ALUC has adopted the ALUCP, which
establishes land use restrictions for the areas around the four principal air-
ports in Butte County. As discussed further in Chapter 4.9, Land Use, Gen-
eral Plan 2030 requires consistency with the regulations of the ALUCP and
therefore does not conflict with the ALUCP. conflicts with the ALUCP’s
Airport Land Use Compatibility Zones in various locations around all four
airports. However, with the exception of two conflict areas discussed below,
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-25
the ALUCP and General Plan 2030 both allow a similar type of residential
development within these conflict areas; the conflicts are only related to the
density of development allowed. These impacts from inconsistency with the
ALUCP are land use impacts, and they do not relate to the safety of people
residing or working in the areas around the airports.
There are two locations where the General Plan 2030 land use map designates
an area for residential use and where the ALUCP prohibits residential use.
At the Paradise Skypark Airport, the Rural Residential General Plan designa-
tion extends into the A Compatibility Zone, which prohibits residential uses.
However, as shown in Figure 4.7-2, only a portion of each of the parcels with
this designation is within the A Compatibility Zone, so any residential devel-
opment on the parcels would be required to be constructed outside of the A
Compatibility Zone area. In addition, at the Ranchaero Airport, the Medium
Density Residential General Plan designation extends into the A Compatibil-
ity Zone. However, as shown in Figure 4.7-3, only a portion of each of the
parcels with this designation is within the A Compatibility Zone, so any resi-
dential development on the parcels would be required to be constructed out-
side of the A Compatibility Zone area. In addition, all of the parcels that
extend into the A Compatibility Zone near the Ranchaero Airport area are
currently developed with residential uses. Therefore, no additional residential
development would occur inside of Airport Compatibility Zones, so no
safety impacts would occur.
As indicated in Chapter 3, because of the inconsistencies between General
Plan 2030 and the ALUCP, an ALUCP override is required.
Because General Plan 2030 allows development only where development is
deemed safe by is consistent with the ALUCP, it would not result in a safety
hazard in the vicinity of an airport, and the impact is less than significant.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-26
f. For a project within the vicinity of a private airstrip, result in a safety
hazard for people residing or working in the project area.
As noted in Section B.2, there are two private airstrips in Butte County: the
Richvale and Jones Ag-Viation private airstrips. The Richvale airstrip is ap-
proximately 1 mile west of Richvale, while Jones Ag-Viation is located just
west of the Thermalito Afterbay. Both airstrips primarily serve nearby agri-
cultural uses and are used to fertilize crops.
Both private airstrips are surrounded by the Agriculture designation under
the General Plan 2030 land use map. The closest residential, commercial, or
industrial land use designations under General Plan 2030 are approximately
1 mile from the Richvale airstrip. Therefore, there would be a sufficient
buffer of agricultural land between the airstrip and residential, commercial,
and industrial development, and the proposed project would have a less-than-
significant impact related to potential hazards for people living or working in
the project area.
Since the ALUCP does not address private airstrips, implementation of the
ALUCP override would have no impact regarding hazards associated with
private airstrips.
The fourth paragraph on page 4.7-30 is hereby deleted:
Since the ALUCP does not address emergency planning, implementation of
the ALUCP override would have no impact regarding emergency planning.
The text on pages 4.7-30 and pages 4.7-31 is hereby amended as follows:
As discussed in Section B.3.a, much of Butte County faces threats from wild-
land fires. General Plan 2030 would allow new development, particularly in
the foothill and mountain areas of the county where there are high fire risks
that could expose new populations to loss, injury, or death due to wildfires.
Although the majority of the land within the High and Very High Fire Haz-
ard Severity Zones is designated for Timber Mountain and Agriculture, Foot-
hill Residential and Rural Residential land uses are also allowed in these areas.
The development of single-family homes on existing vacant parcels would not
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-27
be subject to additional discretionary review or associated environmental re-
view prior to the issuance of a building permit.
In particular, fire safety and evacuation concerns on the Upper Ridge and
Paradise area present a significant challenge due to the lack of alternative cir-
culation routes. Fire safety and evacuation concerns are even more pro-
nounced for the Paradise Pines and Magalia communities due to a single point
of ingress and egress over the Magalia Reservoir dam. A Capitol Improve-
ment Program administered by the Butte County Department of Public
Works includes a long-range plan to make road improvements along the
Skyway, and to additionally improve the Skyway northward to connect with
Highway 32 to provide alternative access. This plan is in the early stages and
funding has not been fully acquired.
However, General Plan 2030 includes a number of goals, policies and actions
that would reduce wildfire impacts. Health and Safety Element Goal HS-11
and its associated policies and actions seek to reduce risks from wildland and
urban fire. Specifically, Policy HS-P11.1 requires that the County consider
fire hazards in all land use and zoning decisions, environmental review, sub-
divisions review, and the provision of public services. Since all structures,
even those without discretionary review, are subject to the provisions of the
Zoning Ordinance, this policy will reduce the risk for new development on
existing vacant parcels.
The second full paragraph on page 4.7-33 is hereby deleted:
Since the ALUCP does not address wildfire hazards, implementation of the
ALUCP override would have no impact regarding wildfire hazards.
The last paragraph on page 4.7-34 is hereby amended as follows:
F. Impacts and Mitigation Measures
Since there are no significant impacts related to hazards and safety as a result
of General Plan 2030 and the ALUCP override, no mitigation measures are
required.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-28
The first paragraph in Section B.2.b, Groundwater Contamination, on
page 4.8-13 of the Draft EIR is hereby amended as follows:
There are two large groundwater contamination plumes in Butte County: the
Central Plume and the Southwest Plume. Both of these plumes are in the
Chico area, originated from former dry cleaners, and involve perchloroethyl-
ene (PCE) groundwater contamination. Other groundwater contaminants of
concern are found elsewhere in Butte County and include arsenic, chromium,
copper, dioxin, and polynuclear aromatic hydrocarbons.
The first sentence in Section B.3, Groundwater Supply and Recharge, on
page 4.8-14 of the Draft EIR is hereby amended as follows:
Approximately 75 percent of the County’s residential water supply is ex-
tracted from groundwater.2
The text at the top of page 4.8-15 of the Draft EIR is hereby amended as
follows:
Figure 4.8-2 illustrates the groundwater basin and subbasins within Butte
County from the Basin Management Ordinance process. This figure shows
hydrologic basins as depicted in California Department of Water Resources
(DWR) Bulletin 118.
The first full paragraph on page 4.8-15 is hereby amended as follows:
The major sources of groundwater recharge in Butte County are percolation
of rainfall, infiltration from streams, subsurface inflow, and deep percolation
of applied irrigation water in agricultural areas. Subsurface inflow from
higher elevations and percolation of precipitation are the major sources of
groundwater recharge in the mountain areas. Some recharge probably occurs
adjacent to through-flowing streams in areas of deeper soils or alluvial depos-
its. Deep subsurface inflow occurs in mountainous areas, flowing west to
2 Glenn County Department of Agriculture, June 2005, Northern Sacramento
Valley (Four County) Drinking Water Quality Strategy Document, page 6-3.
Butte County Department of Water and Resource Conservation, 2008, Butte
County Water Inventory and Analysis.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-29
recharge the adjacent valley area. Most of this recharge occurs on alluvial fans
where streams have sustained flow and the soil is highly permeable. Of the
3.77 MAF of annual rainfall, less than half is used.3 Therefore, more than 2
MAF are currently available for recharge or discharge via surface and subsur-
face outflow, although this amount will not always be available.
The second paragraph under Section B.5.a on pages 4.8-17 and 4.8-18 is
hereby amended as follows:
In addition to the hazard areas listed above, flooding in Rock Creek and
Keefer Slough, located north of Chico, occurred on several occasions in the
1980s, 1990s, and 2000s, inundating State Routes 99 and 32 and several
County roadways, as well as impacting extensive residential and agricultural
areas around Chico and the unincorporated community of Nord. In addi-
tion, Dry Creek-Cherokee Canal poses a flood risk to the Richvale area, in-
cluding rice research grounds, rice storage, and chemical storage facilities.
The text on page 4.8-21 and the top of page 4.8-22 is hereby amended as
follows:
C. Standards of Significance
General Plan 2030 and the ALUCP override would have a significant hydrol-
ogy or water quality impact if it they would:
♦ Violate any water quality standards or waste discharge requirements.
♦ Substantially deplete groundwater supplies or interfere substantially with
groundwater recharge such that there would be a net deficit in aquifer
volume or a significant lowering of the local groundwater table level.
♦ Substantially alter the existing drainage pattern of the site or area in a
manner which would result in substantial erosion, siltation or flooding
on- or off-site.
3 Butte County, August 8, 2005, General Plan Technical Update Background
Report, page 12-16.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-30
♦ Create or contribute runoff water which would exceed the capacity of ex-
isting or planned stormwater drainage systems.
♦ Provide substantial additional sources of polluted runoff, or otherwise
substantially degrade water quality.
♦ Place occupied development within a 100-year flood hazard area as
mapped on a federal Flood Hazard Boundary or Flood Insurance Rate
Map or other flood hazard delineation map.
♦ Place within a 100-year flood hazard area structures which would impede
or redirect flood flows.
♦ Expose people or structures to a significant risk of loss, injury or death
involving flooding, including flooding as a result of the failure of a levee
or dam.
♦ Potentially be inundated by seiche, tsunami, or mudflow.
D. Impact Discussion
The following discussion provides an analysis of potential project and cumu-
lative hydrology and water quality impacts that could occur as a result of im-
plementation of General Plan 2030. Implementation of the ALUCP override
would have no hydrology or water quality impact in Butte County, and is
not discussed further in this section.
The second paragraph under Section D.1.a on pages 4.8-22 to 4.8-23 is
hereby amended as follows:
However, General Plan 2030 contains policies that address water quality stan-
dards and waste discharge requirements. Water Resources Element Goal W-1
and its associated policies seek to maintain and enhance water quality. Spe-
cifically, Policy W-P1.2 directs the County to cooperate with State and local
agencies in efforts to identify and eliminate or minimize all sources of existing
and potential point and non-point sources of pollution to ground and surface
waters, including leaking fuel tanks, discharges from storm drains, auto dis-
mantling, dump sites, sanitary waste systems, parking lots, roadways, and
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-31
logging and mining operations. Policy W-P1.3 requires that regulations that
protect water quality from the impacts from agricultural activities be main-
tained. Policy W-P1.4 requires that new development, where appropriate, be
Low Impact Development (LID) that minimizes impervious area, minimizes
runoff and pollution, and incorporates best management practices. Policy W-
P1.5 encourages pest-tolerant landscapes in order to minimize the need for
pesticides. Policy W-P1.6 continues educational programs and outreach that
promote water quality protection and limit pollution from pesticides and
nutrients in urban and domestic settings. Policy W-P1.8 W-P1.7 requires ag-
riculture, logging, mining, recreational vehicle use, and other open space uses
to follow best management practices to minimize erosion and protect water
resources. Policy P1.11 requires enforcement of grading and construction
regulations to minimize erosion and urban stormwater runoff pollution. Fur-
thermore, Policy W-P3.3 directs the County to protect groundwater recharge
and groundwater quality when considering new development projects.
The first paragraph under Section D.1.b on page 4.8-23 is hereby
amended as follows:
Some urban development and agricultural uses allowed by General Plan 2030
would use groundwater. An increased demand on groundwater could result
in a net deficit in aquifer volume or significantly lower groundwater levels.
Proposed developments in the Ridge areas that rely on groundwater may face
water supply reliability issues. In addition, new construction could include
impervious surfaces, which would decrease the amount of land area available
for rainfall to infiltrate into the ground and recharge the underlying water
table.
The second paragraph on page 4.8-24 is hereby amended as follows:
General Plan 2030 also contains policies and actions designed to promote
groundwater recharge and minimize impervious land cover. Policy W-P3.3
protects groundwater recharge and groundwater quality in new development
projects. Action W-A3.1 directs the County to seek funding for and conduct
comprehensive, countywide mapping of water resources and groundwater
recharge areas, and Action W-A3.2 directs the County to develop standards to
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-32
preserve groundwater recharge and protect groundwater quality. In addition,
Policy W-P1.4 encourages requires Low Impact Development where appro-
priate, which minimizes impervious surfaces, minimizes runoff and pollution,
and incorporates best management practices. Conservation and Open Space
Element Policy COS-P1.4 encourages new development to provide above-
ground and natural stormwater facilities and use building designs and materi-
als that promote groundwater recharge.
The second paragraph under Section D.1.c on page 4.8-25 is hereby
amended as follows:
However, General Plan 2030 includes policies designed to minimize the im-
pact of erosion, siltation and flooding as a result of site drainage alteration.
The Water Resources Element addresses construction-related impacts through
Policy W-P5.4, which requires that temporary facilities be installed as neces-
sary during construction activities in order to adequately treat stormwater
runoff from construction sites. In addition, Policy W-P1.4 requires Low Im-
pact Development where appropriate, which minimizes impervious surfaces,
minimizes runoff and pollution, and incorporates best management practices.
Policy W-P1.7 requires that agriculture, logging, mining, recreational vehicle
use, and other open space uses follow best management practices to minimize
erosion and protect water resources. Policy W-P6.1 requires that any altera-
tion of natural channels for flood control retain and protect riparian vegeta-
tion to the extent possible while still accomplishing the goal of providing
flood control. Where removing existing riparian vegetation is unavoidable,
the alteration must allow for reestablishment of vegetation without compro-
mising the flood flow capacity. Policy W-P6.2 requires that, where stream-
banks are already unstable, proponents of new development prepare a hy-
draulic and/or geomorphic assessment of on-site and downstream drainage-
ways that are affected by project area runoff.
The second paragraph under Section D.1.d on page 4.8-26 is hereby
amended as follows:
However, General Plan 2030 Water Resources Element contains policies that
address stormwater runoff capacity. Policy W-P1.4 encourages requires,
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-33
where appropriate, Low Impact Development, which minimizes impervious
area, minimizes runoff and pollution, and incorporates best management
practices. Policy W-P5.3 allows and encourages pervious pavements. Policy
W-P5.5 requires that stormwater collection systems be installed concurrently
with construction of new roadways to maximize efficiency and minimize
disturbance due to construction activity.
The first paragraph on page 4.9-1 is hereby amended as follows:
This chapter discusses land uses in Butte County and evaluates the potential
land use impacts associated with General Plan 2030 and the Airport Land Use
Compatibility Plan (ALUCP) override. The following evaluation assesses
physical divisions of communities, conflicts with land use plans, and conflict-
ing land uses resulting from the spatial location of development that would be
allowed by General Plan 2030.
The last paragraph on page 4.9-29 and the first paragraph on page 4.9-30
are hereby amended as follows:
C. Standards of Significance
General Plan 2030 and the ALUCP override would have a significant land use
impact if they would:
♦ Physically divide an established community.
♦ Conflict with any applicable plan, policy, or regulation of a govern-
ment agency with jurisdiction over land in unincorporated Butte County
that has been adopted for the purpose of avoiding or mitigating an envi-
ronmental effect.
♦ Create or exacerbate a conflict between land uses.
D. Impact Discussion
The following discussion provides an analysis of potential project and cumu-
lative land use impacts that could occur as a result of implementation of Gen-
eral Plan 2030 and the ALUCP override.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-34
The third paragraph on page 4.9-31 is hereby deleted:
The ALUCP override would itself not physically divide an established com-
munity, since the Plan addresses airport land use conflicts and airport safety.
Therefore, the ALUCP override would have no impact regarding the physical
division of existing communities.
The second full paragraph on page 4.9-32 is hereby amended as follows:
As a result of General Plan 2030 policies, implementation of General Plan
2030 and the ALUCP override would result in a less-than-significant impact in
relation to conflicts with federal plans.
The first paragraph on page 4.9-33 is hereby amended as follows:
As a result of General Plan 2030 policies, implementation of General Plan
2030 and the ALUCP override would result in a less-than-significant impact in
relation to conflicts with State plans.
The text on pages 4.9-34 through 4.9-40 is hereby amended as follows:
General Plan 2030 includes residential densities that are not consistent with
the Airport Land Use Compatibility Zones in the ALUCP. Specifically,
General Plan 2030 includes the following inconsistencies with the ALUCP
for the Chico Municipal Airport, as shown in Figure 4.9-5:
♦ The Very Low Density Residential (VLDR) General Plan designation is
inconsistent with the B1, B2 and C1 Compatibility Zones because it al-
lows greater residential density. THE VLDR designation allows a den-
sity up to 1 unit per acre, while the B1 Compatibility Zone requires a
minimum 10-acre lot size, and the B2 and C1 Compatibility Zones re-
quire a minimum 5-acre lot size.
♦ The VLDR General Plan designation is inconsistent with the C Com-
patibility Zone, which requires either a minimum 5-acre lot size or four
dwelling units per acre density.
♦ The VLDR General Plan designation is inconsistent with the C2 Com-
patibility Zone because it would not allow sufficient residential density.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-35
The C2 Compatibility Zone requires a minimum density of 4 dwelling
units per acre, while the VLDR designation would allow a maximum of 1
unit per acre.
General Plan 2030 also includes residential densities that are not consistent
with the ALUCP for the Oroville Municipal Airport, as shown in Figure
4.9-6. Specifically, the Rural Residential General Plan and zoning designa-
tion, which allows lot sizes up to 5 acres in size, is inconsistent with the B1
Compatibility Zone, which requires a minimum 10-acre lot size.
General Plan 2030 includes land uses that are not consistent with the ALUCP
for the Paradise Skypark Airport, as shown in Figure 4.9-7.
♦ The Rural Residential General Plan designation extends into the A Com-
patibility Zone, which prohibits residential uses. However, only a por-
tion of each of the parcels with this designation is within the A Com-
patibility Zone, and any residential development on the parcels would be
required to be constructed outside of the A Compatibility Zone area.
♦ The Rural Residential General Plan designation is not consistent with the
B1 Compatibility Zone. The Rural Residential designation allows up to
1 dwelling unit per 5 acres, while the B1 Compatibility Zone requires a
minimum lot size of 10 acres.
♦ The VLDR General Plan designation is inconsistent with the C Com-
patibility Zone, which requires either a minimum 5-acre lot size or four
dwelling units per acre density.
Finally, General Plan 2030 includes residential densities that are not consis-
tent with the ALUCP for the Ranchaero Airport, as shown in Figure 4.9-8.
♦ The VLDR, Low Density Residential (LDR), and Medium Density Resi-
dential (MDR) General Plan designations are not consistent with the B1
and B2 Compatibility Zones. The VLDR, LDR and MDR designations
allow densities up to 1, 3, and 6 units per acre, respectively, while the B1
Compatibility Zone requires a minimum lot size of 10 acres and the B2
Compatibility Zone requires a minimum lot size of 5 acres.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-36
♦ There are two parcels with the VLDR General Plan designation, which
allows a density up to 1 unit per acre, within the C Compatibility Zone.
This would be inconsistent with the C Compatibility Zone requirement
of either a minimum 5-acre lot size or four dwelling units per acre den-
sity.
In addition, the MDR General Plan designation extends into the A Compati-
bility Zone for the Ranchaero Airport, which prohibits residential uses.
However, only a portion of each of the parcels with this designation is within
the A Compatibility Zone, so any residential development on the parcels
would be required to be constructed outside of the A Compatibility Zone
area.
As indicated in Chapter 3, because of these inconsistencies between General
Plan 2030 and the ALUCP, an ALUCP override is required. The ALUCP
override would recognize the inconsistency with the ALUCP, and allow the
County to adopt General Plan 2030.
To make this override possible, General Plan 2030 includes policies that pro-
mote consistency with the ALUCP. Policy LU-P12.5 directs the County to
consider the ALUCP in General Plan and Zoning decisions, and to be consis-
tent with it where appropriate. Policy LU-P12.6 encourages the ALUC to
revise the density requirements in some compatibility zones where there are
inconsistencies with the General Plan designations.
General Plan 2030 encourages consistency with other land use plans, policies
and regulations. Goal LU-12 and its associated policies direct the County to
coordinate planning efforts within the county and region. In particular, Pol-
icy LU-P12.1 directs the County to coordinate County government plans and
programs so that they are mutually supportive.
To ensure consistency with the Butte Regional HCP/NCCP, Conservation
and Open Space Element Action COS-A6.1 directs the County to continue to
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-37
work with BCAG and the five municipalities to develop and implement the
Butte Regional HCP/NCCP, and subsequently update it as necessary.
Much of the areas that conflict with the ALUCP are already parcelized to a
density that is similar to the General Plan 2030 designations. Although there
are a number of policies and actions that promote consistency with land use
plans, policies, and regulations, they would not mitigate the significant im-
pacts from inconsistencies with the ALUCP. Therefore, the impact is signifi-
cant and unavoidable.
General Plan 2030 includes an Airport Overlay that applies to areas that are
within the Airport Land Use Compatibility Zones defined in the 2000 Air-
port Land Use Compatibility Plan (ALUCP). Properties within the Airport
Overlay are subject to additional restrictions under the ALUCP, such as re-
strictions on the height and location of structures. In addition, land uses and
densities within the Airport Land Use Compatibility Zones must comply
with the regulations of the current adopted ALUCP where those allowed
land uses and densities differ from General Plan 2030 land use designations,
unless a deviation from the ALUCP is approved by a two-thirds majority of
the Butte County Board of Supervisors.
General Plan 2030 also includes a policy and an action that support consis-
tency with the ALCUP. Policy LU-P12.5 directs the County to be consistent
with the ALUCP in General Plan and Zoning decisions. Action LU-A12.3
directs the County and the Airport Land Use Commission to work coopera-
tively to update the Butte County Airport Land Use Compatibility Plan.
Due to the General Plan 2030 policies and actions discussed above, General
Plan 2030 would have a less-than-significant impact with respect to conflicts
with Butte County plans, policies and regulations.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-38
The first paragraph on page 4.9-42 is hereby amended as follows:
Therefore, implementation of General Plan 2030 and the ALUCP override
would result in a less-than-significant impact in relation to conflicts with mu-
nicipal plans.
The text on pages 4.9-44 and 4.9-45 is hereby amended as follows:
General Plan 2030 includes land uses that are not consistent with the
ALUCP, and an ALUCP override is required. The land use inconsistencies
between General Plan 2030 and the ALUCP are nuisance-related, and dis-
cussed fully in D.1.b of this chapter.
As a result of General Plan 2030 policies and the land use map, implementa-
tion of General Plan 2030 and the ALUCP override would result in a less-
than-significant impact in relation to conflicts between land uses.
2. Cumulative Impacts
Future development allowed by General Plan 2030 would be subject to the
policies and actions set forth in the Land Use Element, a number of which
have been identified in this chapter. Implementation of the policies and ac-
tions would mitigate potential land use impacts related to physically dividing
established communities and conflicts between land uses, but would not miti-
gate impacts related to consistency with applicable land use plans due to in-
consistencies with the ALUCP.
As noted in Section A.4, Chico is currently updating its General Plan, and the
Cities of Oroville and Gridley recently updated their General Plans in 2009.
The Oroville 2030 General Plan is consistent with the ALUCP for the Oro-
ville Municipal Airport. The existing Chico General Plan is not consistent
with the ALUCP for the Chico Municipal Airport, but the City intends to
resolve this inconsistency the majority of the inconsistencies with the updated
General Plan.
Because Although there are other jurisdictions with General Plans that are
not consistent with the ALUCP, General Plan 2030 and the ALUCP override
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-39
would not contribute to a significant and unavoidable cumulative impact be-
cause it is consistent with the ALUCP. Overall, General Plan 2030 would
have a less-than-significant cumulative impact.
E. Impacts and Mitigation Measures
Impact LU-1: General Plan 2030 includes residential densities that are incon-
sistent with the Airport Land Use Compatibility Plan, which necessitates the
Airport Land Use Compatibility Plan override.
Much of the areas that are inconsistent with the ALUCP are already parcel-
ized to a density that is similar to the General Plan 2030 designations. Gen-
eral Plan 2030 policies and actions would promote consistency with land use
plans, policies, and regulations, but would not mitigate the significant impacts
from inconsistencies with the ALUCP. Therefore, the impact is significant
and unavoidable.
Impact LU-2: General Plan 2030 and the Chico General Plan include resi-
dential densities that are inconsistent with the ALUCP, which necessitates the
ALUCP override. This contributes to a significant cumulative impact.
Although General Plan 2030 policies and actions would promote consistency
with land use plans, policies, and regulations, they would not mitigate the
significant impacts from inconsistency with the ALUCP. Furthermore, deci-
sions of the City of Chico regarding consistency with the ALUCP are outside
the control of Butte County. Therefore, this cumulative impact is considered
significant and unavoidable.
Since there are no significant impacts, no mitigation measures are necessary.
The first paragraph on page 4.10-1 is hereby amended as follows:
This chapter discusses noise in Butte County and evaluates the potential noise
impacts associated with General Plan 2030 and the Airport Land Use Com-
patibility Plan (ALUCP) override. The following evaluation is based on both
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-40
a quantitative and spatial analysis, and assesses human exposure to unaccept-
able noise levels, generation of unacceptable noise levels, groundborne vibra-
tion, and noise from airports.
The last paragraph on page 4.10-23 and the top of page 4.10-24 is hereby
amended as follows:
D. Standards of Significance
General Plan 2030 and the ALUCP override would have a significant noise-
related impact if they would:
♦ Expose people to or generate noise levels in excess of standards estab-
lished in the local general plan or noise ordinance, or other applicable
standards.
♦ Expose people to or generate excessive groundborne vibration or ground-
borne noise levels.
♦ Create a substantial temporary, periodic or permanent increase in ambi-
ent noise levels in the project vicinity above levels existing without the
project.
♦ Expose people living or working in the project area to excessive noise
from a public or private airport.
The first full paragraph on page 4.10-24 is hereby amended as follows:
The following discussion provides an analysis of potential project and cumu-
lative noise impacts that could occur as a result of the projected 2030 buildout
of General Plan 2030 and the ALUCP override.
The last sentence on page 4.10-34 is hereby deleted:
Noise impacts from the ALUCP override are discussed in Section D.1.d.
The sentence preceding the last paragraph on page 4.10-36 is hereby de-
leted:
Noise impacts from the ALUCP override are discussed in Section D.1.d.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-41
The first sentence on page 4.10-46 is hereby deleted:
Noise impacts from the ALUCP override are discussed in Section D.1.d.
Under Section D.1.d, the second paragraph on page 4.10-46 is hereby de-
leted as follows:
As discussed in Chapter 4.9, Land Use, the General Plan 2030 land use map
includes land use designations that are inconsistent with the ALUCP Airport
Land Use Compatibility Zones. However, as discussed in Chapter 4.6, Haz-
ards and Safety, both General Plan 2030 and the ALUCP allow a similar type
of residential development within the conflict areas; the conflicts are only
related to the density of development allowed. Therefore, General Plan 2030
allows residential development only where residential development is deemed
appropriate by the ALUCP. The impact from inconsistency with the AL-
CUP is a land use impact, and not related to the exposure of people to noise
in excess of typically acceptable levels. Therefore, the ALUCP override
would have a less-than-significant noise impact.
The first paragraph on page 4.11-1 is hereby amended as follows:
This chapter discusses population and housing in Butte County and evaluates
the potential impacts associated with General Plan 2030 and the Airport Land
Use Compatibility Plan (ALUCP) override. The following evaluation is
based on both a quantitative and spatial analysis, and assesses population
growth and the displacement of housing and people that would necessitate the
construction of housing elsewhere.
The last paragraph on page 4.11-5 and the first paragraph on page 4.11-6
are hereby amended as follows:
C. Standards of Significance
General Plan 2030 and the ALUCP override would have a significant popula-
tion or housing impact if it they would:
♦ Induce substantial unexpected population growth or growth for which
inadequate planning has occurred, either directly (for example, by pro-
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-42
posing new homes and businesses) or indirectly (for example, through ex-
tension of roads or other infrastructure).
♦ Displace substantial numbers of existing housing units, necessitating the
construction of replacement housing elsewhere.
♦ Displace substantial numbers of people, necessitating the construction of
replacement housing elsewhere.
D. Impact Discussion
The following discussion provides an analysis of potential project and cumu-
lative population and housing impacts that could occur as a result of the pro-
jected 2030 buildout of General Plan 2030. Implementation of the ALUCP
override would have no population or housing impact in Butte County, and
is not discussed further in this section.
The first paragraph on page 4.12-1 is hereby amended as follows:
This chapter discusses public services and recreation in Butte County, and
includes evaluation of the impacts associated with the projected 2030 buildout
of General Plan 2030 with regard to police, fire, schools, libraries, and parks
and recreation. This section is based on a quantitative analysis of anticipated
population growth, although it also considers the spatial distribution of popu-
lation growth across public service and recreation districts. Implementation
of the Airport Land Use Compatibility Plan (ALUCP) override would have
no public service or recreation impact in Butte County, and is not discussed
further in this chapter.
The first paragraph on page 4.13-1 is hereby amended as follows:
This chapter summarizes the potential transportation impacts associated with
implementation of General Plan 2030 and the Airport Land Use Compatibil-
ity Plan (ALUCP) override. This section is based on both a quantitative and
spatial analysis, and considers the operations of key roadway segments in the
county under three scenarios: Existing Conditions, Year 2030 Plus General
Plan Projected Buildout Conditions, and Year 2030 No Project Conditions.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-43
The second paragraph on page 4.13-27 is hereby amended as follows:
C. Standards of Significance
General Plan 2030 and the ALUCP override would have a significant trans-
portation and circulation impact if it they would:
♦ Cause an increase in traffic which is substantial in relation to the existing
traffic load and capacity of the street system. Specifically, cause a road-
way facility to exceed, either individually or cumulatively, a level of ser-
vice standard established by the State, County, or municipality that de-
termines acceptable operations on that facility. Table 4.13-5 summarizes
the level of service criteria for each jurisdiction.
♦ Substantially increase hazards due to a design feature (e.g. sharp curves or
dangerous intersections) or incompatible uses (e.g. farm equipment).
♦ Result in inadequate emergency access.
♦ Result in inadequate parking capacity.
♦ Conflict with adopted policies, plans, or programs supporting alternative
transportation.
♦ Result in a change in air traffic patterns, including either an increase in
traffic levels or a change in location that results in substantial safety risks.
The last paragraph on page 4.13-29 is hereby amended as follows:
D. Impact Discussion
This section describes how implementation of General Plan 2030 would in-
fluence Butte County’s roadway segment operations, as well as other aspects
of transportation and circulation, including traffic hazards, emergency access,
parking supply, alternative transportation modes, and air traffic. Implemen-
tation of the ALUCP override would have no transportation or circulation
impact in Butte County, and is not discussed further in this section.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-44
The first paragraph on page 4.14-1 is hereby amended as follows:
This chapter describes the existing water, wastewater, stormwater, solid
waste, and energy service in unincorporated Butte County and discusses po-
tential impacts associated with the projected 2030 buildout of General Plan
2030. This section is based on a quantitative analysis, although it also consid-
ers the spatial distribution of anticipated population growth across utilities
districts. Implementation of the Airport Land Use Compatibility Plan
(ALUCP) override would have no utilities impact in Butte County, and is not
discussed further in this chapter.
Table 4.14-1 on pages 4.14-7 is revised as shown on the following page.
The second paragraph in Section A.4.a.i on page 4.14-18 is hereby
amended as follows:
PID has sufficient supplies to meet existing water demands during normal and
wet rainfall years, but not during periods of drought. The District will re-
quire additional supplies to accommodate projected growth in the Town of
Paradise. However, since no new residential, retail/office or industrial devel-
opment is projected within the unincorporated area of this District by 2030,
General Plan 2030 would not impact the water supply needs of this District.
There is no unincorporated area within Paradise Irrigation District. Persons
annexing unincorporated lands into the District will be required by District
policy to mitigate the water demand as a condition of annexation.
The first paragraph in Section A.4.a.i.l on page 4.14-20 is hereby amended
as follows:
The proposed General Plan 2030 Water Resources Element includes goals,
policies, and actions that address the need for comprehensive planning and
management of water supplies in the county to meet water demands of future
growth. Action W-A2.1 commits the County to implementing and updating
the Integrated Water Management Plan to ensure the sustainability of water
resources within the county. Policy W-P2.6 supports water development
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BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-46
projects that are needed to supply local demands, and Policy W-P2.5 encour-
ages the expansion of public water systems to areas identified for future de-
velopment on the General Plan land use map. Policy W-P2.2 promotes con-
tinued regional cooperation surrounding water issues; however, Butte County
users should be prioritized for Butte County water supplies, according to Pol-
icy W-P2.4 and W-P2.8, which. Policy W-P2.4 supports the full utilization of
the County’s State Water Project allocation within the county and. Policy
W-P2.8 supports Area of Origin water rights. Policy W-P2.9 requires applica-
tions for new development to demonstrate adequate water supply to meet the
needs of the project. Policy W-P3.1 requires sustainable management of
groundwater resources. Goal W-4 and the eight policies that follow encour-
age water conservation, drought-tolerant landscaping, and use of reclaimed
wastewater.
The first paragraph in Section A.4.a.ii on page 4.14-21 is hereby amended
as follows:
General Plan 2030 would allow development that would likely require new
and/or expanded water supply facilities. Based on the projected 2030
buildout, water districts estimated to require expansion of water supply,
treatment and/or storage facilities to meet the increased demand include:
♦ Buzztail Community Services District
♦ Cal Water Chico
♦ Cal Water Oroville
♦ Del Oro Water Company
♦ Thermalito Irrigation District Thermalito Water and Sewer District
The first paragraph in Section A.4.b on page 4.14-25 is hereby amended as
follows:
There is a possibility that growth in other areas within the region could im-
pact regional water supplies. The regional water supplies at risk would be the
large supply of groundwater located within the permeable soils of the Sacra-
mento Valley floor. If new development were to penetrate that supply, a
water shortage could potentially develop. However, the Integrated Water
Resource Plan Water Inventory and Analysis report, revised in 2008, indicates
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-47
that currently, there is no water supply shortfall during normal years, but
that shortages occur during dry conditions in specific areas. Drought period
shortages are concentrated in the southwestern portion of the county, where
supply is limited by groundwater fluctuations during drier summer months,
heavier agricultural use, and the geology of the aquifer.
The second paragraph in Section A.4.b on page 4.14-25 is hereby amended
as follows:
The General Plan 2030 Water Resources Element addresses cooperation with
regional water users to protect Butte County’s water resources. General Plan
Policy W-P2.2 requires the County to continue the Four-County Memoran-
dum of Understanding (MOU) with Colusa, Glenn, Tehama, and Sutter
Counties, and foster regional cooperation with other counties and water pur-
veyors. The MOU will serve to protect the region’s water supply as the re-
gion experiences increasing growth and development pressure. The Four
County MOU Group was joined by Shasta County and was renamed the
Northern Sacramento Valley Integrated Regional Water Management Plan
Group. Therefore, implementation of General Plan 2030 would result in a
less-than-significant cumulative impact to water supplies.
The first paragraph on page 4.15-1 is hereby amended as follows:
This chapter discusses greenhouse gas (GHG) emissions in Butte County and
evaluates the potential GHG emission impacts associated with General Plan
2030 and the Airport Land Use Compatibility Plan (ALUCP) override. This
chapter is based on both a quantitative and spatial analysis, and assesses GHG
levels that would result from the proposed project and impacts of projected
climate change on Butte County.
The first full paragraph on page 4.15-31 is hereby amended as follows:
For the purposes of this EIR, General Plan 2030 and the ALUCP override
would result in a cumulatively considerable contribution if GHG emissions
in 2020 associated with unincorporated Butte County are greater than 85 per-
cent of current GHG emissions. If they are, Butte County would contribute
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-48
considerably to global GHG emissions and related climate change effects. If
the emissions of new development allowed by General Plan 2030, combined
with the on-going emissions of existing development, are less than 85 percent
of current GHG emissions, then General Plan 2030 would not contribute
considerably to global GHG emissions and related climate change effects.
The first, second, and third full paragraphs on page 4.15-32 are hereby
amended as follows:
Thus, for this EIR, the proposed project would result in a cumulatively con-
siderable contribution to a significant impact if development allowed by Gen-
eral Plan 2030 and the ALUCP override is unprepared for reasonably foresee-
able environmental changes that will occur due to climate change, and thus
subject property and persons to additional risk of physical harm related to
flooding, public health, wildfire risk and other impacts.
For the purposes of this EIR, General Plan 2030 and the ALUCP override
would result in a cumulatively significant contribution to climate change if
they would:
♦ Result in GHG emissions that do not achieve a 15 percent reduction
from current levels by 2020.
♦ Subject property and persons to additional risk of physical harm related
to flooding, public health, wildfire risk and other impacts resulting from
climate change.
D. Impact Discussion
The following discussion provides an analysis of the project’s cumulative con-
tribution to GHG emission and climate change impacts that could occur as a
result of implementation of General Plan 2030. In addition, this discussion
includes an analysis of the potential GHG emissions from residential land
uses that would be allowed in the ALUCP area under the ALUCP override,
which is a very small fraction of the projected 2030 buildout that would con-
tribute to GHG emissions.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-49
Under Section D.2.a, the first paragraph on page 4.15-33 is hereby
amended as follows:
The assessment of GHG emissions in this section is based on a quantitative
analysis of impacts resulting from the projected 2030 buildout of General
Plan 2030. The estimate of GHG emissions in 2020 is based on projected
2030 buildout, adjusted to the year 2020. As discussed below, General Plan
2030 and the ALUCP override will result in cumulatively considerable GHG
emissions that exceed the significance criteria noted above.
The second paragraph in Section D.b.iii on pages 4.15-60 to 4.15-61 is
hereby amended as follows:
At present, it is uncertain whether areas like Butte County will experience
increases, decreases, or no change in precipitation due to climate change.
Atmospheric modeling at scales that can provide meaningful precipitation
projections at the county level is an active area of research, and in coming
decades, a better scientific foundation for forecasting this impact at the
county level will likely be available. However, regional climate change mod-
eling for northern California shows a decrease in precipitation falling as snow
and an increase in rainfall during the winter, as well as an increase in the fre-
quency of intense rainfall events.4 These conditions will heighten local flood
risk. Furthermore, as reliability of the snowpack declines and snowmelt oc-
curs earlier in the year, water managers must adapt infrastructure and proce-
dures to capture and bank winter rainfall to avoid summer shortages. Short-
ages in surface water availability could increase the reliance on groundwater.
Additionally, changes in snowmelt and stream flow could reduce groundwa-
ter recharge.
The first paragraph on page 5-1 is hereby amended as follows:
General Plan 2030 and the Airport Land Use Compatibility Plan (ALUCP)
override have been described and analyzed in the previous sections with an
4 Knowles, et al., 2006, as cited in California Energy Commission, May 2009,
The Future Is Now – An Update on Climate Change Science Impacts and Response Options
For California, CEC-500-2008-071, prepared by the California Climate Change Center.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-50
emphasis on potentially significant impacts and recommended mitigation
measures to avoid those impacts to the extent feasible. The State CEQA
Guidelines also require the description and comparative analysis of a reason-
able range of alternatives to the proposed project that could feasibly attain the
objectives of the project.
The last paragraph on page 5-2 and the top of page 5-3 is hereby amended
as follows:
The three alternatives are as follows:
♦ No Project Alternative. The proposed General Plan 2030 and the A-
LUCP override would not be adopted, and the existing Butte County
General Plan would remain in effect.
♦ Concentrated Growth Alternative. In this alternative, development
would be directed toward the existing urban areas. Concentrated growth
would occur at a county-wide scale, in which little development occurs in
outlying areas, which are instead designated for very low density residen-
tial, agriculture, and resource conservation. Meanwhile, higher density
development would occur in and around the existing urban areas.
♦ Rural Extension Alternative. In this alternative, development would be
distributed more widely throughout the county with less emphasis on the
existing urban areas. Typically, outlying areas under this alternative
would allow more dwelling units than under the Concentrated Growth
Alternative, and densities are often lower in and around the existing urban
areas. This alternative is considered because some participants in the
General Plan 2030 process suggested that lower-density development
would be likely to have less environmental impact.
The last paragraph on page 5-3 is hereby amended as follows:
Table 5-1, along with Figures 5-1, 5-2, and 5-3, summarize the level of devel-
opment and illustrate the likely land use pattern for each alternative, while
Table 5-2 summarizes the result of analyzing each alternative against the im-
pact factors considered for General Plan 2030 and the ALUCP override, ac-
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-51
cording to whether it would have a mitigating or adverse effect. This analysis
is presented in greater detail in the following sections.
The text on page 5-4 and the top of page 5-12 is hereby amended as fol-
lows:
C. The No Project Alternative
This section analyzes the No Project Alternative against General Plan 2030
and the ALUCP override.
3. Principal Characteristics
Under this alternative, the proposed General Plan 2030 and ALUCP override
would not be adopted and the existing General Plan would remain in effect.
Thus, new development would occur according to the existing General Plan
land use designations, as well as the County’s existing General Plan policies.
The No Project Alternative differs from the proposed General Plan 2030 and
ALUCP override in terms the amount of residential and non-residential
growth proposed. The No Project Alternative would allow more residential
and industrial development than the proposed project, but less commercial
development, as shown in Table 5-1. The projected 2030 buildout of the No
Project Alternative would be approximately:
♦ 14,200 new dwelling units
♦ 35,100 new residents
♦ 0.5 million square feet new retail/office space
♦ 1.5 million square feet new industrial space
Under Section C.2, the first sentence on page 5-12 is hereby amended as
follows:
4. Impact Analysis
The No Project Alternative would have the following impacts relative to
adoption of General Plan 2030 and the ALUCP override.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-52
The last paragraph on page 5-17 is hereby deleted:
The proposed project would result in a significant and unavoidable land use
impact because it would conflict with the ALUCP. The No Project Alterna-
tive also conflicts with the ALUCP, so this impact would remain.
The last sentence on page 5-22 is hereby amended as follows:
This section analyzes the Concentrated Growth Alternative against General
Plan 2030 and the ALUCP override.
Under Section D.2, the first sentence on page 5-23 is hereby amended as
follows:
2. Impact Analysis
The Concentrated Growth Alternative would have the following impacts
relative to adoption of General Plan 2030 and the ALUCP override.
The last paragraph on page 5-26 and the top of page 5-27 is hereby
amended as follows:
i. Land Use
The Concentrated Growth Alternative would allow a similar type of land
uses as the proposed General Plan 2030, although growth patterns would be
more focused to urban areas. Neither the proposed project nor the Concen-
trated Growth Alternative would physically divide existing communities
within Butte County, and both would include new policies and actions that
would address impacts related to land use conflicts. In addition, both the
proposed General Plan 2030 and the Concentrated Growth Alternative
would conflict with the ALUCP, require an ALUCP override, and cause a
significant and unavoidable land use impact. As a result, the Concentrated
Growth Alternative would have substantially similar land use impacts as the
proposed project.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-53
Under Section E, the first sentence on page 5-29 is hereby amended as
follows:
E. The Rural Extension Alternative
This section analyzes the Rural Extension Alternative against General Plan
2030 and the ALUCP override.
Under Section E.2, the first sentence on page 5-30 is hereby amended as
follows:
2. Impact Analysis
The Rural Extension Alternative would have the following impacts relative
to adoption of General Plan 2030 and the ALUCP override.
The second paragraph on page 5-33 is hereby amended as follows:
i. Land Use
Under the Rural Extension Alternative, the type of land uses allowed would
be relatively similar to that which would occur under the proposed General
Plan 2030, although growth patterns would be extended into rural areas. Nei-
ther the proposed project nor the Rural Extension Alternative would physi-
cally divide existing communities within Butte County, and both would in-
clude new policies and actions that would address impacts related to land use
conflicts. In addition, both the proposed General Plan 2030 and the Rural
Extension Alternative would conflict with the ALUCP, require an ALUCP
override, and cause a significant and unavoidable land use impact. As a result,
the Rural Extension Alternative would have a substantially similar impact as
the proposed project with regard to land use.
The first paragraph on page 6-1 is hereby amended as follows:
As required by CEQA, this chapter provides an overview of the impacts of
the proposed General Plan 2030 and the Airport Land Use Compatibility
Plan (ALUCP) override based on the technical analyses presented in this EIR.
The topics covered in this chapter include growth inducement, unavoidable
significant impacts, expected significant irreversible environmental changes,
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-54
and cumulative impacts. A more detailed analysis of the project-level and
cumulative effects of the proposed project on the environment is provided in
Chapter 4 of this report.
The last paragraph on page 6-1 and the top of page 6-2 is hereby amended
as follows:
1. Direct Impacts
The proposed General Plan 2030 and ALUCP override would directly induce
population, employment, and economic growth by allowing development in
areas not currently designated for urban growth. Implementation of the pro-
posed project would result in the following growth under projected buildout
conditions in 2030 based on the expected growth assumptions for the unin-
corporated county:
♦ Add approximately 33,800 new residents.
♦ Add approximately 13,700 new residential units.
♦ Add approximately 1.8 million new square feet of retail and office uses.
♦ Add approximately 1.1 million new square feet of industrial uses.
The first full paragraph on page 6-3 is hereby amended as follows:
As a result, while the proposed General Plan 2030 and ALUCP override
would result in increased local growth, policies included in General Plan 2030
would reduce the potential for negative impacts associated with direct growth
inducement to a less-than-significant level.
The last paragraph on page 6-3 is hereby amended as follows:
While the proposed General Plan 2030 and ALUCP override allows addi-
tional growth, General Plan 2030 also includes specific policies that direct
growth to existing urbanized areas. For example, Policy LU-P15.2 requires
that new urban development be primarily located in or immediately adjoin-
ing already urbanized areas. The proposed General Plan 2030 land use map
also works to limit the expansion of urban growth by providing designations
that allow urban development primarily within the SOIs for the incorporated
municipalities and the existing unincorporated communities. Outside of
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-55
those areas, the General Plan land use designations would not allow urban
levels of development. The principles that guided the development of the
land use map for General Plan 2030 are also included as policies in the Land
Use Element. In particular, Policy LU-P15.1 requires that the County pre-
vent scattered development patterns and encourage development in existing
urbanized areas, and in particular areas that have access to public services and
infrastructure.
The first and second paragraphs on page 6-4 are hereby amended as fol-
lows:
In addition, the General Plan 2030 land use map provides a mixture of hous-
ing, retail, and employment opportunities within Butte County so that as the
number of residents increase, they do not pressure adjacent communities to
provide new commercial and employment opportunities. As a result, the
proposed General Plan 2030 and ALUCP override would result in a less-than-
significant indirect negative growth inducing impact.
B. Unavoidable Significant Impacts
While the majority of impacts associated with General Plan 2030 and the
ALCUP override would be reduced to a less-than-significant level, adoption
and implementation of the proposed project would result in the following
significant and unavoidable impacts:
The second paragraph on page 6-5 is hereby deleted:
4. Land Use
General Plan 2030 conflicts with the ALUCP, which necessitates the ALUCP
override. In addition, The City of Chico General Plan conflicts with the
ALUCP, so the proposed project would contribute to a cumulative impact.
No feasible mitigation is available. Therefore, the project and cumulative
impacts are significant and unavoidable.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-56
The text on page 6-7 under Sections C.1 and C.2 is hereby amended as
follows:
5. Changes in Land Use that Commit Future Generations
Development allowed by General Plan 2030 and the ALUCP override would
result in the conversion of vacant land to residential, commercial and indus-
trial uses, and the intensification of underutilized areas. This development
would constitute a long-term commitment to residential, commercial, indus-
trial, parking, and other urban uses.
6. Commitment of Resources
Development allowed by General Plan 2030 and the ALUCP override would
irretrievably commit nonrenewable resources, both from within and outside
Butte County, to the construction and maintenance of buildings, infrastruc-
ture and roadways. These non-renewable resources include mined materials
such as sand, gravel, steel, lead, copper, and other metals. Buildout of General
Plan 2030 and the ALUCP override also represents a long-term commitment
to the consumption of fossil fuels, natural gas, and gasoline. Increased energy
demands would be used for construction, lighting, heating, and cooling of
residences, and transportation of people within, to, and from the planning
area. General Plan 2030 Goals COS-3 and COS-4 and their associated policies
and actions would promote energy conservation, which could minimize or
incrementally reduce the consumption of these resources.
Implementation of General Plan 2030 and the ALUCP override would also
result in an irreversible commitment of limited, renewable resources such as
lumber and water. General Plan 2030 Goals COS-3 and COS-4 and their as-
sociated policies and actions would also result in some savings of renewable
resources.
The first paragraph on page 6-8 is hereby amended as follows:
3. Irreversible Damage from Environmental Accidents
Irreversible changes to the physical environment could occur from accidental
release of hazardous materials associated with development activities. How-
ever, compliance with State and federal hazardous materials regulations and
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-57
the countywide response plan, as discussed in Section 4.7, Hazards and Safety,
would reduce this potential impact to a less-than-significant level. No other
irreversible changes are expected to result from the adoption and implementa-
tion of General Plan 2030 and the ALUCP override.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
REVISIONS FOR THE DEIR
3-58
4 LIST OF COMMENTORS
4-1
A. Written Comments
Written comments were received from the following agencies, organizations,
and members of the public.
State and Regional Agencies
1. Scott Morgan, Acting Director, State Clearinghouse. State of California,
Governor’s Office of Planning and Research. June 8, 2010.
2. Lilibeth Green, District 3 Chief, Department of Transportation. State of
California, Business, Transportation and Housing Agency. June 3, 2010.
3. Sandy Hesnard, Aviation and Environmental Specialist, Division of
Aeronautics. State of California, Business, Transportation and Housing
Agency. June 1, 2010.
4. Bill Pfanner, Supervisor, Local Energy & Land Use Assistance Unit,
Special Projects Office, Fuels and Transportation Division. State of
California, Natural Resources Agency. April 27, 2010.
5. Katy Sanchez, Program Analyst, Native American Heritage
Commission. State of California. May 13, 2010.
County Agencies
6. Gail Williams, Senior Air Quality Planner, Butte County Air Quality
Management District. June 7, 2010.
7. Paul Gosselin, Director, Butte County Department of Water and
Resource Conservation. June 2, 2010.
8. John Gulserian, Emergency Services Officer, Butte County Office of
Emergency Management. April 13, 2010.
9. Robert Hennigan, Chair, Butte County Airport Land Use Commission.
May 10, 2010.
Local Governments and Municipal Providers
10. George Barber, District Manager, Paradise Irrigation District. May 27,
2010.
11. Brendan Vieg, Principal Planner, City of Chico. June 3, 2010.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
LIST OF COMMENTORS
4-2
Non-Profit Associations
12. Carol Perkins, Water Resource Advocate, Butte Environmental Council.
May 14, 2010.
13. Robin Huffman, Advocacy Director, Butte Environmental Council.
June 2, 2010.
14. Robin Huffman, Advocacy Director, Butte Environmental Council.
June 4, 2010.
15. Robin Huffman, Advocacy Director, Butte Environmental Council.
June 5, 2010.
16. Barbara Vlamis, Executive Director, AquAlliance. June 7, 2010.
Members of the Public
17. Carol Burr. CBurr@csuchico.edu. April 21, 2010.
18. Tony St. Amant. 27 Garden Park Drive, Chico, CA 95973. May 11,
2010.
19. Tony St. Amant. 27 Garden Park Drive, Chico, CA 95973. May 11,
2010.
20. Tony St. Amant. 27 Garden Park Drive, Chico, CA 95973. June 3,
2010.
B. Public Hearing Comments
Planning Commission Hearing
21. Robin Huffman, Butte Environmental Council
Gene Willet, Bangor Resident
5 COMMENTS AND RESPONSES
5-1
This chapter includes a reproduction of, and responses to, each letter received
during the public review period. Each letter is reproduced in its entirety, and
is immediately followed by responses to the comments in it. Letters follow
the same order as listed in Chapter 4 of this Final EIR and are categorized by:
♦ State Agencies
♦ Regional Agencies
♦ County Agencies
♦ Local Agencies
♦ Organizations
♦ Private Citizens
Each comment and response is labeled with a reference number in the mar-
gin.
In addition, the chapter includes responses to comments received at the public
hearing on the Draft EIR, which was held on April 22, 2010.
Where the same comment has been made more than once, a response may
direct the reader to another numbered comment and response. Where a re-
sponse requires revisions to the Draft EIR, these revisions are explained and
shown in Chapter 3 of this Final EIR document.
Some comments address the General Plan itself and not the Draft EIR. They
do not require a response in this Final EIR, and so the statement "no response
is required" is used. However, the comments will be considered by the Board
of Supervisors when considering the General Plan 2030 adoption.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-2
A. State and Regional Agencies
COMMENT LETTER #1
1-1
5-3
1-1
5-4
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-5
Letter 1: Scott Morgan, Acting Director, State Clearinghouse, State of
California, Governor’s Office of Planning and Research. June 8, 2010.
1-1: This comment states that the Draft EIR was submitted to select State
agencies for review and acknowledges that the County has complied with the
State Clearinghouse review requirements for environmental documents. No
additional response is required.
COMMENT LETTER #2
2-1
5-6
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-7
Letter 2: Lilibeth Green, District 3 Chief, Department of
Transportation, State of California, Business, Transportation and
Housing Agency. June 3, 2010.
2-1: This comment states that the Circulation Element of the General Plan
should include the expansion of Highway 99 north of Chico to the Tehama
County line from a two-lane highway to a four-lane expressway.
The Butte County Board of Supervisors considered adding this improvement
to the Circulation Element of the General Plan during a January 19, 2010
study session, based on a previous comment letter from Caltrans, but decided
not to include it. In addition, this project was not assumed to be funded in
the Butte County Association of Governments 2008-2035 Regional Transpor-
tation Plan. While this project would facilitate interregional travel on the
State system, due to uncertain funding, it was not assumed to be constructed
within the planning horizon. Because this project was not included in the
proposed General Plan Circulation Element, and because it was not assumed
to be constructed within the planning horizon, it was not included in the EIR
traffic analysis.
“Caltrans improves mobility across California”
STATE OF CALIFORNIA------- BUSINESS, TRANSPORTATION AND HOUSING AGENCY ARNOLD SCHWARZENEGGER, Governor
DEPARTMENT OF TRANSPORTATION
DIVISION OF AERONAUTICS – M.S.#40
1120 N STREET
P. O. BOX 942874
SACRAMENTO, CA 94274-0001
PHONE (916) 654-4959
FAX (916) 653-9531
TTY 711
Flex your power!
Be energy efficient!
June 1, 2010
Mr. Dan Breedon
Butte County
7 County Center Drive
Oroville, CA 95965
Dear Mr. Breedon:
Re: Butte County Draft Environmental Impact Report for the Butte County 2030 General Plan
Update; SCH# 2008092062
The California Department of Transportation (Caltrans), Division of Aeronautics (Division), reviewed
the above-referenced document with respect to airport-related noise and safety impacts and regional
aviation land use planning issues pursuant to the California Environmental Quality Act (CEQA). The
Division has technical expertise in the areas of airport operations safety and airport land use
compatibility. We are a funding agency for airport projects and we have permit authority for public-
use and special-use airports and heliports.
The proposal is for an update to the 2030 Butte County General Plan. According to the
Environmental Impact Report (EIR), it “provides an assessment of the potential environmental
consequences of adoption of the Butte County General Plan 2030 and Airport Land Use
Compatibility Plan (ALUCP) override.” The EIR further states that “the proposed project is a
comprehensive update of the existing Butte County General Plan, as well as the associated override
of the ALUCP. The General Plan is the principal policy document for future conservation and
development in the county, and it has a 20-year planning horizon. Because General Plan 2030
includes densities that are not consistent with the Airport Land Use Compatibility Zones in the
ALUCP, adoption of this document requires an override of the ALUCP.”
This project description sets the stage for tying the General Plan adoption process to the ALUCP
overrule appeal process, however, procedurally there is no nexus for doing this. An Airport Land Use
Commission (ALUC) overrule, cannot be noticed, processed or “implemented through the EIR” until
the ALUC has deliberated and voted to make a determination that the draft General Plan and its
companion documents are either consistent or inconsistent with the ALUCP. Once the ALUC has
made a determination of inconsistency, they would notify Butte County of their decision. Butte
County could then proceed with the overrule process. The County may wish to discuss the
anticipated inconsistencies between the General Plan densities and ALUCP criteria in a separate
section of the EIR or include the overrule process as an appendix.
The EIR impact analysis and findings cannot be combined with the overrule appeal process since
there are no environmental impacts associated with the procedural act of overruling the ALUCP.
CEQA does not apply to an appeal of a local government land use decision or a local government
overruling the ALUC. It is the General Plan densities that have direct or indirect adverse
environmental impacts that would require analysis and CEQA findings of overriding considerations.
COMMENT LETTER #3
3-2
3-3
3-1
5-8
Mr. Dan Breedon
June 1, 2010
Page 2
Additionally, language in Chapters 3 and 4 confuse the term “override findings” with “ALUCP
overrule findings.” The overriding consideration findings required by CEQA for significant, but
unavoidable adverse environmental impacts related to the approval of the General Plan are
different than the findings needed for an ALUCP consistency overrule as required by California
Public Utilities Code (PUC) Sections 21676.5(a) and 21670(a) (1 and 2). For clarity, we
recommend removing from the EIR, all references to ALUCP override “impacts” and focus only
on evaluating the environmental impacts of the General Plan.
The California Airport Land Use Planning Handbook, available on-line at
http://www.dot.ca.gov/hq/planning/aeronaut/documents/ALUPHComplete-7-02rev.pdf, provides a
“General Plan Consistency Checklist” in Table 5A and a “Possible Airport Combining Zone
Components” in Table 5B.
Federal and State regulations regarding aircraft noise do not establish mandatory criteria for
evaluating the compatibility of proposed land use development around airports with the exception of
the 65 decibel (dB) Community Noise Equivalent Level (CNEL) “worst case” threshold established in
the State Noise Standards for the designated “noise problem” airports. For most airports in
California, 65 dB CNEL is considered too high a noise level to be appropriate as a standard for land
use compatibility planning. This is particularly the case for evaluating new development in the
vicinity of the airport. The 60 dB CNEL, or even 55 dB CNEL, may be more suitable for new
development around most airports. Consideration should also be given to cumulative noise impacts
associated with the project site’s proximity to roadways and railway lines.
Sound insulation, buyer notification and avigation easements are typical noise mitigation measures.
These measures, however, do not change exterior aircraft noise levels. Noise mitigation measures are
not a substitute for good land use compatibility planning for new development
PUC Section 21659 prohibits structural hazards near airports. The planned height of buildings,
antennas, and other objects should be checked with respect to Federal Aviation Regulation (FAR)
Part 77 criteria if development is close to the airport, particularly if situated within the runway
approach corridors. General plans must include policies restricting the heights of structures to protect
airport airspace. To ensure compliance with FAR Part 77 “Objects Affecting Navigable Airspace”
submission of a Notice of Proposed Construction or Alteration (Form 7460-1) to the Federal Aviation
Administration (FAA) may be required. Form 7460-1 is available on-line at
https://oeaaa.faa.gov/oeaaa/external/portal.jsp and should be submitted electronically.
PUC Section 21688 states that “no payments shall be made from the Aeronautics Account for
expenditure on any airport or for the acquisition or development of any airport, if the department
determines that the height restrictions around the airport are inadequate to provide reasonable
assurance that the landing and taking off of aircraft at the airport will be conducted without
obstruction or will be otherwise free from hazards.” The airport-owner must have sufficient control
over obstructions in the airspace in the vicinity of the airport to assure that height restrictions can be
maintained. This control may be in the form of ownership of any land from which obstructions may
3-4
3-5
3-6
3-7
3-8
5-9
Mr. Dan Breedon
June 1, 2010
Page 3
rise, air navigation (avigation) easements to guarantee maintenance of restrictions, or height limitation
or land use zoning which will prohibit obstructions which would violate the obstruction standards.
Education Code Section 17215 requires a school site investigation by the Division prior to acquisition
of land for a proposed school site located within two miles of an airport runway. The Division
submits recommendations to the State Department of Education for use in determining acceptability
of the site. This should be a consideration prior to designating residential uses or increasing
residential densities in the vicinity of an airport. The Division’s school site evaluation criteria are
available on-line at http://www.dot.ca.gov/hq/planning/aeronaut/regulations.html.
Business and Professions Code Section 11010 and Civil Code Sections 1102.6, 1103.4, and 1353
address buyer notification requirements for lands around airports and are available on-line at
http://www.leginfo.ca.gov/calaw.html. Any person who intends to offer subdivided lands, common
interest developments and residential properties for sale or lease within an airport influence area is
required to disclose that fact to the person buying the property.
Land use practices that attract or sustain hazardous wildlife populations on or near airports can
significantly increase the potential for wildlife-aircraft collisions. The Federal Aviation
Administration (FAA) recommends that landfills, wastewater treatment facilities, surface mining,
wetlands and other uses that have the potential to attract wildlife, be restricted in the vicinity of an
airport. FAA Advisory Circular (AC150/5200-33B) entitled “Hazardous Wildlife Attractants on or
Near Airports” and AC 150/5200-34 entitled “Construction or Establishment of Landfills near Public
Airports” address these issues. For further information, please refer to the FAA website
http://wildlife-mitigation.tc.faa.gov/.
Aviation plays a significant role in California’s transportation system. This role includes the
movement of people and goods within and beyond our state’s network of over 250 airports. Aviation
contributes nearly 9 percent of both total state employment (1.7 million jobs) and total state output
($110.7 billion) annually. These benefits are discussed in the study “Aviation in California: Benefits
to Our Economy and Way of Life” available on-line at
http://www.dot.ca.gov/hq/planning/aeronaut/econstudy2003.html. Aviation improves mobility,
generates tax revenue, saves lives through emergency response, medical and fire fighting services,
annually transports air cargo valued at over $170 billion and generates over $14 billion in tourist
dollars, which in turn improves our economy and quality of life.
The protection of airports from incompatible land use encroachment is vital to California’s economic
future and should be protected through effective airport land use compatibility planning and
awareness. Although the need for compatible and safe land uses near airports is both a local and State
issue, airport land use commissions and airport land use compatibility plans are key to protecting an
airport and the people residing and working in the vicinity of an airport. Consideration given to the
issue of compatible land uses in the vicinity of an airport should help to relieve future conflicts
between airports and their neighbors.
3-8
cont.
3-9
3-10
3-11
3-12
3-13
5-10
Mr. Dan Breedon
June 1, 2010
Page 4
To ensure the General Plan’s compatibility with future as well as existing airport operations, the
proposal should be coordinated with the Chico Municipal Airport Manager, Dave Burkland, at
(530) 896-7200 or dburkland@ci.chico.ca.us, the Oroville Municipal Airport Manager, Rick Walls
at (530) 538-2420 or wallsr@cityoforoville.org, the Ranchaero Airport Manager, Gary Grigg, at
(530) 342-5242 or ranchaero1@aol.com, and Paradise Skypark owner, John Franklin, at (530) 343-9600
or franklin@franklinconstruction.com.
These comments reflect the areas of concern to the Division of Aeronautics with respect to airport-
related noise, safety, and regional land use planning issues. We advise you to contact our District 3
office concerning surface transportation issues.
Please contact the Division’s ALUC coordinator for Butte County, Ms. Terry Farris, at (916) 653-9603,
for questions regarding the ALUCP consistency issue.
Thank you for the opportunity to review and comment on this proposal. If you have any questions,
please call me at (916) 654-5314 or by email at sandy.hesnard@dot.ca.gov.
Sincerely,
Original Signed by
SANDY HESNARD
Aviation Environmental Specialist
c: State Clearinghouse, Butte County ALUC, Chico Municipal Airport, Oroville Municipal Airport,
Ranchaero Airport, Paradise Skypark
3-13
cont.
3-14
5-11
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-12
Letter 3: Sandy Hesnard, Aviation and Environmental Specialist,
Division of Aeronautics, State of California, Business, Transportation
and Housing Agency. June 1, 2010.
3-1: As noted in the revisions to the Draft EIR shown in Chapter 3 of
this Final EIR, in response to this and other comments received on the Draft
EIR, the Butte County Board of Supervisors has directed County staff to re-
vise General Plan 2030 to:
♦ Use the Airport Overlay to require that land uses and densities within
the Airport Land Use Compatibility Zones must comply with the cur-
rent adopted ALUCP where those allowed land uses and densities differ
from General Plan 2030 land use designations, unless a deviation from the
ALUCP is approved by a two-thirds majority of the Butte County Board
of Supervisors.
♦ Revise Policy LU-P12.5 to direct the County to be consistent with the
ALUCP in General Plan and Zoning decisions.
♦ Delete Policy LU-P12.6.
♦ Add a new Action LU-A12.3 that directs the County and the Airport
Land Use Commission to work cooperatively to update the ALUCP.
Therefore, General Plan 2030 would be consistent with the ALUCP, and no
ALUCP override is necessary.
3-2: See response 3-1.
3-3: See response 3-1.
3-4: See response 3-1.
3-5: See response 3-1.
3-6: This comment directs the environmental evaluators to the California
Airport Land Use Planning Handbook as a source for further environmental
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-13
review. It is not a comment on the adequacy of the Draft EIR, and therefore
no response is necessary.
3-7: This comment discusses noise levels in the vicinity of airports and
notes that mitigation measures are not a substitute for good land use plan-
ning. The purpose of the noise analysis in the Draft EIR was to address the
noise impacts of implementation of General Plan 2030 on the public. As in-
dicated in Section D.1.d on page 4.10-46 of the Draft EIR, General Plan poli-
cies HS-P1.3 and HS-P1.4 address noise impacts near airports. Cumulative
noise impacts are also discussed in Section D.2 on pages 4.10-46 and 4.10-47 of
the Draft EIR. In addition, as indicated in the response to Comment 3-1,
General Plan 2030 has been revised to be consistent with the ALUCP. Fur-
thermore, this is not a comment on the adequacy of the Draft EIR, and no
further response is necessary.
3-8: See response 3-1.
3-9: This comment suggests further environmental evaluation should be
considered for school siting, based on recommendations of the Division of
Aeronautics. As indicated in the response to Comment 3-1, General Plan
2030 has been revised to be consistent with the ALUCP; all residential densi-
ties and public uses are now consistent with the ALUCP. Furthermore, this
is not a comment on the adequacy of the Draft EIR, and therefore no re-
sponse is necessary.
3-10: This comment provides information regarding buyer/renter disclo-
sures for properties located within an airport influence area. It is not a com-
ment on the adequacy of the Draft EIR, and therefore no response is neces-
sary.
3-11: This comment provides information regarding conflict between land
uses that attract wildlife populations and airports. As indicated in the re-
sponse to Comment 3-1, General Plan 2030 has been revised to be consistent
with the ALUCP; all public and open space uses are consistent with the
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-14
ALUCP. Furthermore, this is not a comment on the adequacy of the Draft
EIR, and therefore no response is necessary.
3-12: This comment pertains to the significance of aviation in California as
a means of transportation of people and goods. It is not a comment on the
adequacy of the Draft EIR, and therefore no response is necessary.
3-13: This comment makes a connection between California’s economic
prosperity and compatible land use planning surrounding airports, and rec-
ommends that all future land use projects are coordinated with Butte County
local airport managers. As indicated in the response to Comment 3-1, Gen-
eral Plan 2030 has been revised to be consistent with the ALUCP. Further-
more, this is not a comment on the adequacy of the Draft EIR, and therefore
no response is necessary.
3-14: This comment provides follow-up contact information for the De-
partment of Transportation District 3 and the Butte County ALUCP coordi-
nator, and expresses Ms. Hesnard’s appreciation for the opportunity to re-
view and comment on the Draft EIR. It is not a comment on the adequacy of
the Draft EIR, and therefore no response is necessary.
COMMENT LETTER #4
4-2
4-1
5-15
4-3
5-16
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-17
Letter 4: Bill Pfanner, Supervisor, Local Energy & Land Use Assistance
Unit, Special Projects Office, Fuels and Transportation Division, State of
California, Natural Resources Agency. April 27, 2010.
4-1: This comment confirms receipt of the Draft EIR by the California
Energy Commission. The comment also states that the Commission would
like to assist in reducing the energy usage involved in the project and refers
environmental reviewers to Appendix F of the California Environmental
Quality Act (CEQA). It is not a comment on the adequacy of the Draft EIR,
and therefore no response is necessary.
4-2: This comment provides information on the Energy Commission’s
Aware Planning Guide. The comment also expresses appreciation from the
California Energy Commission for the opportunity to review and comment
on the Draft EIR. Additional environmental review is not recommended by
the comment. It is not a comment on the adequacy of the Draft EIR, and
therefore no response is necessary.
4-3: This comment presents Appendix F of the CEQA Guidelines which
describes how an EIR may address energy conservation. The specific EIR
contents described in Section II of Appendix F are tailored to project-specific
EIRs which analyze site design, construction and operation of a building or
buildings. Appendix F acknowledges that it may not be possible to analyze
each of these components at a programmatic level, stating that “[i]n many
instances, specific items may not apply.”
Both General Plan 2030 and the Draft EIR address energy consumption and
conservation. Specifically, the Draft EIR includes a program-level analysis of
the General Plan’s electricity and natural gas consumption and energy effi-
ciency measures in three locations:
♦ Chapter 4.14, Section E.4.a.i, on pages 4.14-59 and 4.14-60, which pre-
sents a programmatic analysis of energy consumption under General Plan
2030.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-18
♦ Chapter 4.15, Sections D.2.a.ii and D.2.a.iii on pages 4.15-39 to 4.15-42,
which analyzes how the energy efficiency and conservation measures in
General Plan 2030 would affect GHG emissions.
♦ Chapter 6, Section C.2, on page 6-7, which discloses that “[b]uildout of
General Plan 2030 and the ALUCP override also represents a long-term
commitment to the consumption of fossil fuels, natural gas, and gasoline.
Increased energy demands would be used for construction, lighting, heat-
ing, and cooling of residences, and transportation of people within, to,
and from the planning area. General Plan 2030 Goals COS-3 and COS-4
and their associated policies and actions would promote energy conserva-
tion, which could minimize or incrementally reduce the consumption of
these resources.”
The Draft EIR appropriately addresses the potential energy impacts of the
proposed General Plan 2030.
COMMENT LETTER #5
5-1
5-19
5-2
5-20
5-2
cont.
5-21
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-22
Letter 5: Katy Sanchez, Program Analyst, Native American Heritage
Commission, State of California. May 13, 2010.
5-1: This comment states that, to comply with CEQA, the County is
required to assess whether the project will have an adverse effect on historical
resources, and lists the steps required to adequately assess and mitigate pro-
ject-related impacts.
The actions necessary to comply with CEQA, as recommended by the Native
American Heritage Commission (NAHC), were all completed for the Draft
EIR. These actions include: conducting a records search of the project area at
the Northeast Information Center, requesting a sacred lands search and Na-
tive American representative list from the NAHC, consulting with local Na-
tive American representatives provided by the NAHC, and analyzing poten-
tial impacts to cultural resources resulting from the project. Additionally,
because this is an update to a General Plan, a list for tribal consultation in
accordance with Senate Bill (SB) 18 was requested from the NAHC, and those
individuals and groups were contacted by the County. This information is
presented in Chapter 4.5 of the Draft EIR.
5-2: This comment provides a “Native American Contact List” for Butte
County, dated May 11, 2010. At the outset of the General Plan 2030 project,
the County contacted Native American tribes that were identified by NAHC
in November 2006 as having traditional lands or cultural places located
within the General Plan 2030 project area. The list of tribes that were identi-
fied in 2006 is slightly different from the list provided in this comment due to
changing knowledge and records of tribal resources. This comment is not a
comment on the adequacy of the Draft EIR, and no additional response is
necessary.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-23
B. County Agencies
COMMENT LETTER #6
6-2
6-1
5-24
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-25
Letter 6: Gail Williams, Senior Air Quality Planner, Butte County Air
Quality Management District. June 7, 2010.
6-1: This comment expresses appreciation by the Butte County Air Qual-
ity Management District for the opportunity to review the Draft EIR. The
comment also states that the District finds the Draft EIR to be compatible
with the District’s CEQA Air Quality Handbook and encouraging in its ef-
fort to reduce the emission impacts of development. It is not a comment on
the adequacy of the Draft EIR, and therefore no response is necessary.
6-2: This comment provides corrections to Table 4.3-2. These correc-
tions have been incorporated into Table 4.3-2, as shown in Chapter 3 of this
Final EIR.
COMMENT LETTER #7
7-1
7-2
7-3
7-4
5-26
7-4
cont.
7-5
7-6
7-7
7-8
7-9
7-10
5-27
7-11
7-12
7-13
5-28
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-29
Letter 7: Paul Gosselin, Director, Butte County Department of Water
and Resource Conservation. June 2, 2010.
7-1: This comment states that the Butte County Water Commission has
approved comments to the Draft EIR, and overall, finds the Draft EIR to be
comprehensive, clear, and adequately assessed with regards to potential sig-
nificant impacts to water resources. No response is required.
7-2: This comment states that the completeness of the cumulative impact
analysis should be evaluated to ensure adequacy and completeness. The ap-
proach to the cumulative analysis is fully described in Section D of Chapter 6
on pages 6-8 and 6-9 of the Draft EIR. As described in that section, cumula-
tive effects are those that combine impacts from implementation of the pro-
ject in the unincorporated county with effects of development in other por-
tions of the region, including the incorporated municipalities and the sur-
rounding counties. The potential cumulative effects of the proposed project
are discussed at the regional level within each section of Chapter 4, Environ-
mental Evaluation, of the Draft EIR.
7-3: This comment recommends that the Draft EIR incorporate all of the
relevant actions, so that the Draft EIR consistently references appropriate
actions. The Draft EIR consistently references policies and actions that
would reduce potential environmental impacts to a less-than-significant level.
The Draft EIR impact discussions focus on those policies and actions that are
required; however, some non-required policies and actions are cited when
they are particularly relevant to the impact discussion and would support the
mitigation of the potential impact, but not fully mitigate on their own.
7-4: This comment states that additional General Plan 2030 policies
should be cited in the discussion about project impacts related to violations of
water quality standards or waste discharge requirements. The discussion has
been revised to cite these additional policies, as shown in Chapter 3 of this
Final EIR.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-30
7-5: The comment identifies an error on page 4.8-22 of the Draft EIR.
Chapter 3 of this Final EIR document contains the correction to this error.
No further response is required.
7-6: The comment recommends adding a new statement on page 4.8-23 of
the Draft EIR. Chapter 3 of this Final EIR document contains this addition.
No further response is required.
7-7: The comment recommends rewording language on pages 4.8-24 and
4.8-26 of the Draft EIR. Chapter 3 of this Final EIR document contains these
edits. No further response is required.
7-8: This comment suggests additional text on page 4.8-25 of the Draft
EIR. Chapter 3 of this Final EIR document contains this addition. No fur-
ther response is required.
7-9: This comment recommends rewording language on page 4.14-20 of
the Draft EIR. Chapter 3 of this Final EIR document contains these edits.
No further response is required.
7-10: This comment identifies an error on page 4.14-21 of the Draft EIR.
Chapter 3 of this Final EIR document contains the correction to this error.
No further response is required.
7-11: This comment identifies an error on page 4.14-25 of the Draft EIR.
Chapter 3 of this Final EIR document contains the correction to this error.
No further response is required.
7-12: This comment suggests additional text on page 4.14-25 of the Draft
EIR. Chapter 3 of this Final EIR document contains this addition. No fur-
ther response is required.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-31
7-13: This comment suggests additional text on page 4.15-61 of the Draft
EIR. Chapter 3 of this Final EIR document contains this addition. No fur-
ther response is required.
From: Gulserian, JohnSent: Tuesday, April 13, 2010 1:18 PM
To: Breedon, Dan
Subject: EIR Update
Hello Dan,
Concerning the EIR the Hazards & Safety Element Page 4.7‐12 Para h. It has our Office as the Office of Emergency
Services. Last year we changed our name to Office of Emergency Management (OEM). If that could be updated that
would be great.
Thanks,
John
John Gulserian
Emergency Services Officer
Butte County Office of Emergency Management
25 County Center Drive Suite 200
Oroville, CA 95965
530-538-7373
Fax 530-538-7120
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file:///L:/805/02_Background%20Data/Comment%20Letters/Draft%20E...
1 of 1 6/23/2010 10:49 AM
COMMENT LETTER #8
8-1
5-32
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-33
Letter 8: John Gulserian, Emergency Services Officer, Butte County Of-
fice of Emergency Management. April 13, 2010.
8-1: This comment identifies an error on page 4.14-12 of the Draft EIR.
Chapter 3 of this Final EIR document contains the correction to this error.
No further response is required.
5-34
5-35
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-36
Letter 9: Robert Hennigan, Chair, Butte County Airport Land Use
Commission. May 10, 2010.
9-1: This comment states that under California law, local agency General
Plans are required to be compatible with an Airport Land Use Commission
(ALUC) Plan. This comment also discusses the importance of airports, and
the planning process required for an ALUC Plan. It is not a comment on the
adequacy of the Draft EIR, and therefore no response is necessary.
9-2: See response 3-1.
9-3: See response 3-1.
9-4: This comment recommends land use policies be removed from the
Butte County 2030 Draft General Plan that pertain to the ALUCP override,
and to generally comply with Public Utilities Code Section 21676.5. See re-
sponse 3-1 for an explanation of how General Plan 2030 has been revised to
be consistent with the ALUCP and why an ALUCP override is no longer
necessary.
5-37
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-38
Letter 10: George Barber, District Manager, Paradise Irrigation District.
May 27, 2010.
10-1: This comment identifies an error in Table 4.14-1 on page 14.14-7 of
the Draft EIR. Chapter 3 of this Final EIR document contains the correction
to this error. No further response is required.
10-2: This comment identifies an error on page 4.14-18 of the Draft EIR
and recommends revised language. Chapter 3 of this Final EIR document
corrects this error using the recommended language. No further response is
required.
COMMENT LETTER #11
11-2
11-1
5-39
11-2
cont.
5-40
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-41
Letter 11: Brendan Vieg, Principal Planner, City of Chico. June 3, 2010.
11-1: This comment expresses appreciation by the City of Chico for the
opportunity to provide comments on the Draft EIR, and states that the Draft
EIR has done a good job identifying cumulative environmental impacts from
future development. No further response is required.
11-2: This comment suggests that General Plan 2030’s contribution to air
quality impacts would be cumulatively considerable, and that the Draft EIR’s
conclusion of a less-than-significant impact should be revised to indicate a
significant and unavoidable impact.
The commentor is correct that it may not be feasible to fully offset criteria
pollutant emissions from future development. However, the cumulative
analysis for air quality is not based on offsetting emissions associated with
General Plan 2030, but rather on how implementation of General Plan 2030
will affect regional pollutant levels relative to the existing conditions, in con-
sideration of the significance thresholds in the Butte County Air Quality
Management District (BCAQMD) CEQA Air Quality Handbook. As shown
in Table 4.3-7, compared to existing conditions, the proposed General Plan
2030 will result in net decreases in all nonattainment pollutants from traffic
operations, which typically represent the largest source of regional emissions
associated with the General Plan. It is likely that emissions from non-vehicle
sources will also occur as a result of implementation of General Plan 2030.
However, the reductions in traffic emissions, as shown in Table 4.3-7, are
anticipated to outweigh any increases in non-vehicle emissions resulting from
implementation of General Plan 2030 and development in the Sacramento
Valley Air Basin. In addition, development would be subject to the require-
ments of the applicable air quality district and General Plan policies of the
applicable municipality or county that address air quality.
Furthermore, the BCAQMD CEQA guidelines require that General Plans be
evaluated for consistency with the most recently adopted Air Quality At-
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-42
tainment Plan (AQAP) and/or State Implementation Plan (SIP). Consistency
with the AQAP and SIP is, essentially, a cumulative analysis, because the
AQAP and SIP look at all projects and emissions within the region. As indi-
cated in Pages 4.3-17 through 4.3-21 of the Draft EIR, General Plan 2030 was
evaluated for consistency with the Northern Sacramento Valley Planning
Area 2006 AQAP, and it was found that the project would not exceed coun-
tywide growth estimates, would incorporate numerous transportation control
measures, and would result in net decreases in vehicle miles traveled (VMT)
and emissions. Consequently, it was concluded General Plan 2030 would not
obstruct efforts to achieve federal and State air quality standards.
Therefore, the less-than-significant conclusion is appropriate for the air qual-
ity cumulative analysis.
May 14, 2010
Dan Breedon, Principal Planner Butte County Department of Development Services 7 County Center Drive
Oroville, CA 95965
Re: Water – Draft General Plan 2030’s Draft EIR, dated April 8, 2010
The following is a draft of Butte Environmental Council’s comments to the DEIR
for early review today by the Water Commission sub-committee for the General
Plan. Since the DEIR is connected to the Draft General Plan 2030, some comments
provide further input to the Water Element. The Water Element must address
specific and comprehensive monitoring and enforcement systems for management of our local water resources. All proposed policies and actions must promote long-
term sustainability of Butte County’s water resources for all the various uses
projected to affect water users in the county: agricultural, residential, recreational,
transfers out of the region for the profit of a few, and species.
BEC continues to be concerned about the future increase in the privatization of
water resources, including potential water bottling and bulk export of water for water bottlers. The General Plan should address this issue as mass export of drinking water could significantly affect water resources and the environment;
having a strong policy in place before a project is proposed will help save
everyone a lot of time and money.
All impacts on water that could be significant should be addressed in the DEIR.
Certain lands tentatively approved for rezoning for residential uses could result in
significant impacts on the hydrology of the areas. The Tuscan golf course is a
prime example. Already the available groundwater for the golf course grass has been iffy. The additional water demand of housing in that general area should be studied for the DEIR for this and other areas approved for rezoning. The study
should address the significance of the impact on water supply and quality for the
environment and for residents who live in those watersheds where the rezoning is
to take place.
Section D.1.b. – states that ‘some’ urban development and agricultural uses would
use groundwater. To be able to accurately assess needs and source it needs to be clearly identified that urban development in certain tentatively approved growth areas will be dependent on groundwater. Butte County does not have infrastructure
to move existing surface supplies. If stated action items are not concretized, the
impacts will be significant.
Though the DEIR states that maximum theoretical buildout is not expected, the
DEIR should nevertheless analyze impacts on water resources for probable buildout. Further, building housing in open space areas of the county promotes sprawl, which goes against all current best practices and the Butte County General
COMMENT LETTER #12
12-1
12-2
12-3
12-4
12-5
12-6
12-7
5-43
-2-
Plan 2030 guiding principles. Instead of studying the impacts on the environment for such areas
to be rezoned, such areas should be eliminated from the plan. Growth should be in the existing
cities, and there is plenty of land within those cities to supply the projected housing needs of the county to 2030 and beyond. (Before the Draft General Plan returns to the Supervisors, the county should recommend doing an economic analysis to see what the economic effect of probable
buildout in the approved growth areas would likely have on the county’s budget.) The DEIR
should make this analysis because the impacts of sprawl will have very significant impacts on
the environment, not the least being water resources.
A recent sewage spill into the headwaters of Dry Creek, an important agricultural water supply, leaves the environmental community questioning how the General Plan policies will prevent
similar situations. Though the spill happened from a poorly located wastewater system in
Paradise, which has fairly rigorous water treatment standards, would the county allow the same
mistakes? (The project was also built within about 100 feet of a residential area, and smells emitted from the system have plagued its operation.)
The proposed general plan and DEIR fails to address the impacts of additional water supply requirements for land use decisions and development per existing area plans.
The Durham-Dayton-Nelson Plan is another example that needs study in the DEIR. Current
details of the plans should be made available as part of the record for the general plan, as they will be grandfathered-in under the 2030 Master EIR. Policy 2.9 and supporting Action 2.2 must address existing area plans.
Chapter 33 refers to safe yield, however, we have not been able to assess safe yield or determine
conditions of overdraft since this ordinance was codified in 1996. We must have an action item
in the General Plan that ensures we can meet this legal obligation, and safe yield and the effect on the environment of going beyond safe yield should be at least mentioned in the DEIR.
The General Plan addresses land use, development, and conservation policy specifically geared
toward population growth whether in urban centers or rural. It is negligent to not indicate in the
DEIR how this growth would be served and that it could be served by groundwater. In a state
where water rights currently exceed developed water supply by 8.5 times, the sources of water
and the sustainability of those sources should be addressed in the DEIR. In addition, most of our surface water supplies are not near our urban centers. These facts must be included everywhere
they are relevant, including the section on agriculture.
The primary water source in Butte County is surface water, which serves 69
percent of the county’s water needs, followed by groundwater, serving 31 percent of the water needs.1
The DEIR fails to identify Dry Creek—Cherokee Canal in the section on Flood Hazards.
Cherokee Canal poses a serious flood concern to the Richvale area and the rice research grounds,
rice storage, and chemical storage facilities and all future growth or industrial development in the
area.
1 Draft General Plan 2030, last paragraph, p. 128
12-10
12-11
12-12
12-13
12-14
12-15
12-16
12-17
12-18
12-19
12-9
12-8
5-44
-3-
BEC has noted some concerns and suggestions regarding water resources and the DEIR in this
letter, and we look forward to working with you as the process moves forward.
Sincerely,
Carol Perkins
Water Resource Advocate
Copy furnished: Butte County Water and Resource Conservation
12-20
5-45
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-46
Letter 12: Carol Perkins, Water Resource Advocate, Butte Environmental
Council. May 14, 2010.
12-1: This comment provides recommendations regarding the General
Plan 2030 Water Element. This is not a comment on the adequacy of the
Draft EIR, and no response is required.
12-2: This comment states that land proposed for residential uses may re-
sult in significant hydrology impacts from increased water demands, noting
the Tuscan Ridge golf course as an example. The Draft EIR addresses poten-
tial impacts from increased water demands resulting from implementation of
General Plan 2030 in Chapters 4.8 and 4.14:
♦ Section D.1.b of Chapter 4.8 on pages 4.8-23 and 4.8-24 provides a quali-
tative assessment of groundwater supply impacts.
♦ Section A.4.a.i of Chapter 4.14 on pages 4.14-15 through 4.14-21 provides
a quantitative assessment of surface water supply impacts for each water
service provider district.
Both of these sections conclude that the proposed project would have a less-
than-significant impact on water supplies due to the numerous policies and
actions in General Plan 2030 that address water supplies, in conjunction with
the Butte County Integrated Water Resource Plan, Butte County Groundwa-
ter Management Plan, and other State and federal regulations. For example,
Water Resources Element Policy W-P2.9 requires that applicants for new ma-
jor development projects demonstrate adequate water supply to meet the
needs of the project, including an evaluation of potential cumulative impacts
to surrounding groundwater users and the environment, and Policy W-P3.1
directs the County to ensure the sustainability of groundwater resources
through a basin management objective program that relies on management at
the local level, utilizes sound scientific data, and assures compliance.
The Draft EIR analyses cited above do not call out specific Planned Unit De-
velopment (PUD) areas, such as the Tuscan Ridge PUD, nor other specific
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-47
areas that are proposed for residential development. Instead, the Draft EIR
provides a programmatic analysis for the entire county. Subsequent project-
level analyses for individual development projects will be required to include
a water supply assessment for new major projects.
In addition, as indicated in the response to Comment 7-6, the discussion of
groundwater supply impacts on page 4.8-23 in Section D.1.b of Chapter 4.8
has been augmented to further explain potential groundwater impacts from
development in the Tuscan Ridge areas. This expanded discussion is provided
in Chapter 3 of this Final EIR.
12-3: This comment states that the Draft EIR should address water supply
and water quality impacts within the watersheds of areas proposed for resi-
dential uses. See the response to Comment 12-2 for a discussion of the Draft
EIR’s water supply analyses. The Draft EIR also provides an assessment of
water quality impacts resulting from implementation of General Plan 2030 in
Chapter 4.8, Sections D.1.a (pages 4.8-22 and 4.8-23), D.1.c (pages 4.8-25 and
4.8-26), and D.1.e (page 4.8-27). In these sections, the Draft EIR finds less-
than-significant water quality impacts due to the numerous policies and ac-
tions proposed in the Water Resources and Health and Safety Elements, as
well as the Butte County Stormwater Management Program, Butte County
Stormwater Management and Discharge Control Ordinance, and other State
and federal regulations.
12-4: This comment states that the Draft EIR should clearly identify
which areas designated for urban development will be dependent on ground-
water. As indicated in the response to Comment 12-2, Water Resources Ele-
ment Policy W-P2.9 requires that applicants for new major development pro-
jects demonstrate adequate water supply to meet the needs of the project.
The sources of water for future development projects cannot be determined at
this time, since they will depend on a number of factors, including the avail-
ability of groundwater supply to meet the demands of the development pro-
ject. Although the locations of some areas proposed for urban development
are not currently within the district boundary of a surface water service pro-
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-48
vider, such areas may need to find surface water sources in order to demon-
strate adequate water supply. Therefore, at this programmatic level, the Draft
EIR cannot accurately identify those areas where urban development may
occur in the future that would be dependent on groundwater.
12-5: This comment states that Butte County does not have infrastructure
to distribute surface water supplies, which could lead to significant impacts.
As indicated in the response to Comments 12-2 and 12-4, the source of water
for future development projects cannot be determined at this time, but if the
water source is groundwater, the Draft EIR has evaluated the potential im-
pacts, and found them to be less than significant. The Draft EIR also evalu-
ates the potential impacts from expanding water infrastructure. Section
A.4.a.ii of Chapter 4.14 on pages 4.14-21 through 4.14-24 considers potential
environmental impacts caused by the construction or expansion of water fa-
cilities. This section finds the potential impacts to be less than significant due
to proposed General Plan 2030 policies and actions and the fact that addi-
tional project-specific environmental analysis for water system improvements
would be completed pursuant to CEQA.
12-6: This comment states that the Draft EIR should evaluate impacts on
water resources from probable buildout. Throughout the document, the
Draft EIR does evaluate impacts from the probable buildout of General Plan
2030 (i.e. the “reasonably foreseeable” outcome of General Plan 2030). The
probable buildout is termed “projected 2030 buildout” in the Draft EIR, and
it is explained further in Chapter 3, Section F, on pages 3-39 to 3-55. In addi-
tion, as described in Section G of Chapter 3 (pages 3-55 and 3-56), the Draft
EIR also estimates the “maximum theoretical buildout” of General Plan 2030,
and each evaluation chapter in the Draft EIR includes a qualitative assessment
of the potential impacts under maximum theoretical buildout.
12-7: This comment states that building housing in open space areas pro-
motes sprawl, which is counter to the General Plan 2030 Guiding Principles
and best planning practices. This is not a comment on the adequacy of the
Draft EIR. However, General Plan 2030 includes a number of policies that
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
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direct growth to existing urbanized areas. Specifically, Policy LU-P15.2 re-
quires that new urban development be primarily located in or immediately
adjoining already urbanized areas. In addition, Policies LU-P8.3, LU-P8.4,
LU-P8.5, and LU-P15.3 promote efficient infill development near public fa-
cilities.
12-8: This comment states that growth should be focused to existing ur-
banized areas and avoid open spaces, noting that there could be potential fis-
cal impacts to the County if development occurs in outlying areas. This is
not a comment on the adequacy of the Draft EIR, and no response is re-
quired. In addition, see response 12-7.
12-9: This comment states that the Draft EIR should evaluate the impacts
of sprawl on the environment, and in particular water resources. The Draft
EIR evaluates the potential impacts from implementation of General Plan
2030. As explained in Chapter 3 of the Draft EIR, implementation of Gen-
eral Plan 2030 is based on the distribution and pattern of land uses included in
the General Plan 2030 land use map (Figure 3-3, page 3-21) and the develop-
ment allowed by that land use map (Section F of Chapter 3, pages 3-39 to 3-
55). The pattern and amount of development allowed by General Plan 2030
is evaluated throughout the Draft EIR, including the water resources and
supplies analyses in Chapters 4.8 and 4.14.
12-10: This comment notes that a recent sewage spill into the headwaters of
Dry Creek occurred, and asks how General Plan 2030 policies would prevent
a similar situation. As indicated in Section B.4.a.i in Chapter 4.14 (page 4.14-
40), municipal and community wastewater facilities are regulated by the Cen-
tral Valley Regional Water Quality Control Board (RWQCB) and its waste-
water treatment requirements. Furthermore, this is not a comment on the
adequacy of the Draft EIR, and no further response is required.
12-11: This comment states that the Draft EIR fails to address the impacts
of the additional water demands of the land uses and development allowed by
the existing Area Plans. As indicated on pages 3-31 and 3-32 of the Draft EIR,
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
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an Area Plan, Neighborhood Plan or Specific Plan has already been developed
and adopted for the following areas:
♦ North Chico
♦ Chapman-Mulberry
♦ Durham-Dayton-Nelson
♦ Stringtown Mountain
The General Plan 2030 land use designations within these areas are generally
consistent with the applicable Area, Neighborhood, or Specific Plan. Where
they are not consistent, the proposed project also includes conforming
amendments to Area and Specific Plans in order to make them consistent
with General Plan 2030.
As indicated in the response to Comment 12-9, the pattern and amount of
development allowed by General Plan 2030, including development within
Area Plan boundaries, consistent with adopted Area Plans, is evaluated
throughout the Draft EIR, including the water resources and supplies analyses
in Chapters 4.8 and 4.14. Therefore, the Draft EIR did evaluate the impacts
associated with development under the existing Area Plans. The response to
Comment 12-2 describes the water supply impact analyses in the Draft EIR.
12-12: This comment states that the Durham-Dayton-Nelson Area Plan is
an example of an Area Plan that requires study in the Draft EIR. The re-
sponses to Comments 12-2 and 12-11 address this comment.
12-13: This comment states that the details of existing Area Plans be made
available as part of the record for the General Plan and EIR. The existing
Area Plans are public documents available for review at the County Devel-
opment Services office, as they have been since their adoption.
12-14: This comment suggests that General Plan 2030 include an action to
ensure that the County meets its safe yield legal obligation under Chapter 33
of the Butte County Municipal Code. General Plan 2030 does not include
actions related to the implementation of existing programs. However, Gen-
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-51
eral Plan 2030 does include a number of policies and actions that further pro-
tect the sustainability of water resources, including the policies supporting
Goal W-3 to sustain groundwater resources, and Policy W-P2.9 and Action
W-A2.2, which address the consideration of water resource sustainability and
water supply in land use decisions. In addition, page 4.8-6 of the Draft EIR
describes Chapter 33 of the Butte County Municipal Code. This is not a
comment on the adequacy of the Draft EIR, and no further response is re-
quired.
12-15: This comment states that the safe yield and the potential impacts of
going beyond safe yield be mentioned in the Draft EIR. Safe yield is defined
in Chapter 33 of the Butte County Municipal Code as “the maximum quan-
tity of water which can be withdrawn annually from an aquifer under a given
set of conditions without causing overdraft or adverse water quality condi-
tions.” While the thresholds of significance under CEQA do not specifically
call out safe yield, the following thresholds address potential overdraft and
related water quality impacts:
♦ “Would the project substantially deplete groundwater supplies or inter-
fere substantially with groundwater recharge such that there would be a
net deficit in aquifer volume or a significant lowering of the local ground-
water table level?” This threshold is evaluated in pages 4.8-23 and 4.8-24
of the Draft EIR.
♦ “Would the project violate any water quality standards or waste discharge
requirements?” This threshold is evaluated in pages 4.8-22 and 4.8-23 of
the Draft EIR.
♦ “Would the project provide substantial additional sources of polluted
runoff, or otherwise substantially degrade water quality?” This threshold
is evaluated in page 4.8-27 of the Draft EIR.
12-16: This comment states that the Draft EIR should indicate what water
sources will serve development allowed by General Plan 2030. The responses
to Comments 12-2, 12-4, and 12-5 provide a response to this comment.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-52
12-17: This comment states that the Draft EIR should address water sources
and the sustainability of those water sources. The response to Comment 12-2
responds to this comment.
12-18: This comment notes that most of the surface water supplies in Butte
County are not near urban centers, and suggests that the Draft EIR recognize
this situation where relevant, including in the section on agriculture. The
Draft EIR provides a map of the district boundaries of existing water service
providers in Figure 4.14-1 on page 4.14-8. In addition, Table 4.14-1 on page
4.14-7 of the Draft EIR identifies the water sources for each water service pro-
vider that is shown in the figure. Therefore, the Draft EIR maps the bounda-
ries of surface water supplier districts; these water suppliers include agricul-
tural water providers. Furthermore, the Draft EIR analyzes the potential
environmental impacts from constructing new or expanding existing water
infrastructure, as explained in the response to Comment 12-5.
12-19: This comment suggests that the Draft EIR recognize Dry Creek-
Cherokee Canal as a flood hazard. The existing conditions section on page
4.8-18 of the Draft EIR has been revised to reflect this suggestion, as shown in
Chapter 3 of this Final EIR.
12-20: This comment provides concluding remarks for the letter, and no
response is needed.
June 2, 2010
Dan Breedon, Principal Planner Butte County Department of Development Services 7 County Center Drive Oroville, CA 95965 Supplemental BEC Comments to Water Commission on Draft General Plan 2030 DEIR BEC comments were submitted to the county and Water Commission on May 14, 2010 for consideration. The following are supplemental comments from BEC for the Water Commission’s consideration at today’s meeting. Comprehensive comments with so many errors in the DEIR and Draft General Plan make definitive comments difficult. Some details and questions have been submitted in recent e-mails, and we await the county’s reply. Some policies referenced in the DEIR, for example, cannot be found in the updated draft GP. Water tables and maps in the Setting and Trends report remain incomplete and inconsistent; yet, these are referenced in the DEIR and draft GP. Fix the inconsistencies and publish an updated DEIR, draft General Plan, Setting and Trends report, Policy Alternatives document, and General Plan Land Use map.
Overall, the DEIR is difficult to follow. The General Plan is to a large extent a plan for urban
expansion, with specific growth areas studied for change. The DEIR fails to make impacts to the
environment from certain areas, those given a nod for a change in land use and zoning in the draft
general plan, understandable for each of these change areas. Restated, the way the DEIR is
organized makes it very difficult to understand the impact on the environment for each such area.
In particular, for this comment letter to the Water Commission, the general source of sufficient
water for each individual change area is not clearly indicated or studied for potential impacts to the
associated environment. Clearly show each growth area and analyze the environmental
impacts for each individually.
Overall, the need for each of the growth areas is not clearly delineated. The general plan update process is largely, to date, land owner and developer driven rather than driven by policy. This is not a new critique; we have been reassured along the way that policies would guide the process after the consideration of what land owners and developers propose; however, we do not see in the DEIR that the growth areas are called for. The DEIR fails to show that the existing residential zoning within municipalities and reasonable spheres of influence, which are not easily decipherable in the DEIR, are insufficient for population growth to 2030 and beyond. Clearly show each SOI as it exists and each SOI as proposed and why urban growth beyond those areas is needed.
The DEIR fails to clearly estimate the probable types of jobs available, income levels, and types of residential units that justifiably should be built to accommodate that need. Moreover, the type of housing proposed does not appear to be the type of housing that is most needed for growth. Lower income housing is needed; however, the residential uses proposed are largely for single family units that tend to be expensive and classic sprawl. This is status quo growth, not sustainable growth and not in any way relating to current best practices for sustainable uses of land, air, and water. Clearly show in the DEIR that the areas proposed for urban expansion will meet the needs of the majority of people for the projected population growth.
Respectfully submitted,
Robin Huffman Advocacy Director Copy furnished: Butte County Water and Resource Conservation
COMMENT LETTER #13
13-5
13-6
13-7
13-8
13-9
13-10
13-1
13-2
13-3
13-4
5-53
13-11
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BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-55
Letter 13: Robin Huffman, Advocacy Director, Butte Environmental
Council. June 2, 2010.
13-1: This comment references Letter 12, noting that the comments in this
letter are supplemental. The comment also notes that the Draft EIR and
General Plan 2030 include errors, which makes a definitive list of comments
difficult. This comment does not provide any specific instances of errors in
the Draft EIR. The Draft EIR was reviewed by County staff for accuracy.
Chapter 3 of this Final EIR notes changes and corrections in the Draft EIR in
response to specific comments from other commentors. Without specific
errors listed, additional response is not feasible.
13-2: This comment states that policies referenced in the Draft EIR are not
found in General Plan 2030, and that questions have been submitted to
County staff. As noted in the response to Comment 13-1, the Draft EIR was
reviewed for accuracy, and without specific errors provided, it is difficult to
respond to these comments. Comment 7-5 noted one instance in which a
policy number was incorrectly cited in the Draft EIR, and this has been cor-
rected in Chapter 3 of this Final EIR. In addition, Development Services staff
received the noted emails from the Butte Environmental Council (BEC) on
June 2, 2010, and responded via email to BEC on June 2, 2010 and met with
BEC Advocacy Director Robin Huffman on this same date to address the
emails and further questions.
13-3: This comment states that the Draft EIR references incomplete and
inconsistent water tables and maps from the Setting and Trends Report. The
water resources information included in the Draft EIR and Setting and
Trends Report is based on best available data. See the response to Comments
13-1 and 13-2. Since the comment does not provide any specific comments on
the adequacy of the Draft EIR, no further response is necessary.
13-4: This comment directs the County to fix inconsistencies and publish
updated versions of the following documents: Draft EIR, General Plan 2030,
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-56
Setting and Trends Report, Policy Alternative, and General Plan 2030 land
use map. As indicated in the response to Comments 13-1 through 13-3, the
commentor does not list any specific errors or inconsistencies in the Draft
EIR. Any specific errors or inconsistencies in the Draft EIR that have been
identified are corrected in Chapter 3 of this Final EIR. As described in Sec-
tions 15088 and 15088.5 of the CEQA Guidelines, in response to comments
on the Draft EIR, the lead agency may revise the content of the Draft EIR
during the Final EIR phase. Recirculation of the Draft EIR is only required
when significant new information is provided, such as a new significant envi-
ronmental impact, a substantial increase in the severity of an impact, or a new
feasible project alternative or mitigation measure, or if the Draft EIR was
fundamentally inadequate and conclusory in nature. The corrections to the
Draft EIR provided in Chapter 3 of this Final EIR do not provide significant
new information, and the findings in the Draft EIR were based on substantial
evidence and not conclusory in nature, which allowed meaningful public re-
view and comment. Therefore, recirculation of the Draft EIR is not neces-
sary.
13-5: This comment states that General Plan 2030 is a plan for urban ex-
pansion, with specific “growth areas” studied for change, and directs that the
Draft EIR analyze the environmental impacts for each “growth area.” This
comment also implies that the analyses for the “growth areas” should be more
focused than the analyses provided in the Draft EIR.
Neither General Plan 2030 nor the Draft EIR identifies “growth areas.” Gen-
eral Plan 2030 is a countywide plan that provides land use designations and
related policies for all unincorporated areas under the County’s jurisdiction.
The Draft EIR evaluates this countywide plan, not just specific areas of the
county.
In Section F.2 of Chapter 3 (pages 3-43 to 3-53), the Draft EIR describes how
the development allowed by General Plan 2030 was assumed to be distributed
throughout the county for the EIR analyses that are based on a geographic
distribution of projected 2030 buildout. These are not areas that are targeted
BUTTE COUNTY GENERAL PLAN 2030
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COMMENTS AND RESPONSES
5-57
for growth; rather, these are the areas where General Plan 2030 would allow
for some type of development. As shown in Table 3-5 and Figure 3-5 on
pages 3-44 to 3-47 of the Draft EIR, these areas cover most areas of the
county, since even the Timber Resources and Agriculture General Plan land
use designations allow some development. Although some development
would be permitted, in order to allow landowners economic use of their
property, the amount and type of development outside of urbanized areas is
limited by the land use designations and related policies of General Plan 2030,
as discussed in response 12-7.
Therefore, the countywide approach to evaluating potential impacts resulting
from implementation of General Plan 2030 is appropriate.
In addition, the programmatic approach of the Draft EIR is appropriate. As
indicated in Section B of Chapter 1 of the Draft EIR (pages 1-6 to 1-3), pro-
gram EIRs are not project-specific and do not evaluate the impacts of specific
development ‘projects’ that may be proposed under General Plan 2030. Such
projects will require separate environmental review to secure the necessary
development entitlement. This EIR is intended, where appropriate, to be
used as a first-tier environmental document for future projects, but it is not
intended to address impacts of individual development projects. Tiering sub-
sequent development projects from this EIR will be guided by CEQA Guide-
lines Section 15183.
13-6: This comment states that the need for “growth areas” is not deline-
ated, and that General Plan 2030 is landowner- and developer-driven rather
than policy-driven. This is not a comment on the adequacy of the Draft EIR,
and no response is needed.
13-7: This comment directs the Draft EIR to demonstrate why urban
growth beyond the municipalities and the Spheres of Influence (SOI) of those
municipalities is needed to accommodate future population growth. The
comment also directs the Draft EIR to show each SOI as it exists and as it is
proposed. The Draft EIR maps the current boundaries of each SOI in a
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number of figures, including Figure 3-2 on page 3-6 of the Draft EIR. General
Plan 2030 does not propose to change the boundaries of any of the SOIs, nor
is it within the jurisdiction of Butte County to determine changes to the SOI
of any incorporated municipality. In addition, the Draft EIR provides a map
of the existing County General Plan land use designations within the SOIs in
Figure 4.9-3 on page 4.9-13, as well as a map of the proposed General Plan
land use designations within the SOIs in Figure 3-3 on page 3-21. This com-
ment is not a comment on the adequacy of the Draft EIR, so no further re-
sponse is required.
13-8: This comment states that the Drat EIR does not estimate the prob-
able types of jobs available or income levels and the types of residential units
that would be needed to accommodate such employment opportunities. As
indicated in the response to Comment 12-6, the Draft EIR evaluates impacts
from the projected 2030 buildout of General Plan 2030 (i.e. the “reasonably
foreseeable” outcome of General Plan 2030). The projected 2030 buildout is
based on the General Plan 2030 land use map, as well as assumptions about
how much of the maximum theoretical buildout allowed by the land use des-
ignations would occur by 2030; these assumptions are documented in Section
F of Chapter 3 of the Draft EIR. The process to determine projected 2030
buildout is reasonable, adequate, and based directly on the proposed project.
13-9: This comment states that the type of housing proposed in General
Plan 2030 is not the type of housing needed in Butte County; instead of sin-
gle-family housing, lower income housing is needed. The County has
adopted a Housing Element that provides for housing at all levels. Further-
more, this is not a comment on the adequacy of the Draft EIR, and no addi-
tional response is required.
13-10: This comment directs the Draft EIR to demonstrate that the areas
proposed for urban expansion will meet the needs of the majority of the fu-
ture population. The response to Comment 13-9 responds to this comment.
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13-11: This comment is an attachment letter that supports the comments
included in Letter 13. See the responses to Comments 13-1 through 13-10.
June 4, 2010
Dan Breedon, Principal Planner Butte County Department of Development Services 7 County Center Drive Oroville, CA 95965 Subject: Website, Maps, Follow-up, and New Comments on the Draft General Plan 2030 DEIR BEC comments were submitted to the county and Water Commission on May 14, 2010 and June 2, 2010 for consideration. The following are supplemental comments on the DEIR for the Draft General Plan 2030, and another longer letter will follow shortly focusing on other issues. (I’ve seen both June 4 and June 7 given as deadlines.) Due to a number of factors, including errors in the DEIR and Draft General Plan, I had asked for an extension to the comment period. While you were unable to grant the extension, I understand that you will continue to take comments throughout the next step of the process.
I encourage you to provide a corrected and updated DEIR in July to the Planning Commission and
the Board of Supervisors, even if that means another comment period would be required, so that
the draft that goes to the Board of Supervisors in the fall will be a more perfect document, more
understandable and in need of fewer corrections.
Thank you for meeting with me and Carol Perkins, BEC’s Water Resources Advocate, after the Water Commission meeting on June 2 and for providing written feedback and discussion about previously e-mailed questions and letters submitted. You indicated at that meeting that you will soon provide all the related documents to the Draft General Plan 2030 and DEIR in one section, or link, on the www.buttegeneralplan.net homepage, and that you will include in that section or link a document that is a running tally, periodically updated with the changes that you plan to recommend for the DEIR and related documents. These measures will be very much appreciated. Surely other members of the public will also appreciate these measures and this level of transparency. We appreciate this very much as we continue to follow the process for getting the best General Plan 2030 as achievable in as short a time as possible.
The documents needed to be in one place online, all up-to-date, are the DEIR, the draft General Plan, the Setting and Trends Report, the Policy Alternatives document, the Guiding Principles (not previously mentioned, but it would be a good place for them to be), the running tally of recommended changes, the upcoming zoning documents, and at least one key map or set of maps.
Such access to a map or maps, separate from the documents, would be helpful. One candidate is in
the General Plan, Fig. LU-3, General Plan Land Use Designations. Another is in the DEIR, Fig. 3-
5, Projected 2030 Residential Buildout, which is what we mainly used in our discussion with you
on June 2, though it doesn’t show areas for other types of development, such as industry.
The rest of this letter will mainly be about maps. As you know, layering is an essential tool in planning. If you have the technical ability to layer maps electronically, please provide that capability to the public to see the layers. If not, please find an alternative way for the public to see the layers needed. Such maps are needed in the DEIR to see how the environment may be impacted.
Especially in Butte County, maps should not be flat, they should be topographical to show where the property lines are in relationship to the fingers, canyon rims, and canyons of the Buttes. Property lines and elevation lines are two kinds of mapping that need to be overlayed to show the environmental context on which properties are found for a proper environmental review, and this is a major deficiency with the DEIR.
The DEIR fails to include a map showing important hydrologic areas overlaid with a map of areas
to be available for urbanization or other development. That’s another layer that is necessary to
understand the potential impacts of General Plan 2030 on the environment. The county should
COMMENT LETTER #14
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include a tentative map of the probable recharge zones, even while the county’s firm knowledge of hydrologic zones remains incomplete.
If the upcoming Tuscan Study will be used in any way in support of the changes in land use or zoning for the General Plan 2030, this potential needs to at least be mentioned with a map to show if any areas to be studied are the same as the areas to be available for urbanization or other development. In an article “Tuscan Aquifer project may take next step” in the Paradise Post on June 3, Butte County Senior Planner Chris Thomas is reported to have said, “The information [from monitoring data] will help, but not totally identify, a sustainable amount of water use from the underground reserves,” and “Such information will help assess sustainable use for [water] inside the county and outside requests for water transfers.” The map of the study areas for the Tuscan Study, since it is purportedly designed to “help assess sustainable use for inside the county”, should be included in the DEIR and should be layered with a map showing areas available for urbanization or other development. Many of the areas being opened for development in the General Plan 2030 are in the very areas that are potential recharge zones, in the east side of the county. The potential impacts on the hydrology need to be identified in the DEIR and before rezoning takes place. Once rezoned, it is much easier for individual projects to occur on the land, and they can, one project at a time according to the zoning. In that scenario the DEIR fails to identify cumulative impacts to the environment.
For the record I will note here, particularly since the Water Commission has not been producing minutes that have detail as to who from the public spoke or generally what was said by anyone, that the Water Commission did consider BEC’s June 2 letter on June 2; however, they did not feel they had time to adequately consider including suggestions in their recommendations, just as they did not have adequate time to consider BEC’s comments in their recommendations to the Board of Supervisors for the draft General Plan 2030. This is unfortunate and partly because I did not get BEC’s comments to the Commission until the same day that they were discussing their recommendations. My intention was to provide comments sooner. Still, the fact remains that the Water Commission felt they did not have enough time in both cases to consider incorporating any of our input into their recommendations to the Board.
Respectfully submitted,
Robin Huffman
Advocacy Director
Copy furnished: Butte County Water and Resource Conservation
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Letter 14: Robin Huffman, Advocacy Director, Butte Environmental
Council. June 4, 2010.
14-1: This comment contains introductory language for the letter. No
response is required.
14-2: This comment encourages the County to prepare a corrected and
updated Draft EIR to make it more perfect, more understandable, and in need
of fewer corrections. The response to Comment 13-4 responds to this com-
ment.
14-3: This comment expresses appreciation for County staff’s response to
the commentor’s concerns about the availability of information on the pro-
ject website. The comment also includes requests regarding the organization
and contents of this information on the website. This is not a comment on
the adequacy of the Draft EIR, and no response is required.
14-4: This comment requests that map layers be made available to the pub-
lic. The Draft EIR presents maps describing existing conditions and the Gen-
eral Plan land use designations proposed for General Plan 2030 and the pro-
ject alternatives. This information has been presented in the Draft EIR in a
standard map format that is typical and acceptable in EIRs. The County does
not have the resources to provide electronic, layered maps to the public.
However, the County has provided a website service for the public to look
up the General Plan 2030 land use designation for individual parcels at the
following website: http://gp_butte_county.chicomapworks.com/.
14-5: This comment states that the maps in the Draft EIR should show
topographical information and parcel boundaries. The maps presented in the
Draft EIR show existing conditions information in a format that is clear and
readable. It is difficult to show many different types of information on a sin-
gle map while maintaining clarity. Each map contains the information that is
the focus of the map (e.g. land use, agricultural lands, and fault lines) without
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extraneous information in order to clearly display the map’s intent. On some
figures, such as the General Plan land use map, parcel boundaries are shown
because they directly relate to the focus of the map. However, topography is
not shown in any of the maps in the Draft EIR; in most cases, topographic
information would make the maps less clear. Chapter 3 of this Final EIR
includes a revised Figure 3-2, Planning Area, which shows topographic in-
formation. Other maps can be compared to this figure in order to relate
them to topography.
14-6: This comment states that the Draft EIR should show a map of im-
portant hydrologic areas overlaid with a map of areas proposed for develop-
ment. The comment also states that the Draft EIR should include a map of
the probable groundwater recharge zones. The Draft EIR contains maps
showing hydrologic areas and other water resources, and explains how Gen-
eral Plan 2030 adequately addresses the protection of water resources and re-
charge areas. Surface water features are displayed in Figure 4.8-1 on page 4.8-
11 and groundwater basins and subbasins are displayed in Figure 4.8-2 on page
4.8-16 of the Draft EIR. These hydrologic features can be compared to the
General Plan land use designations shown in Figure 3-3 on page 3-21 of the
Draft EIR to compare the location of the features to the General Plan land
use designations.
The Setting and Trends Report, the background document for General Plan
2030, contains the tentative maps showing potential recharge areas. Essen-
tially, a substantial portion of the foothill area and the entire valley portion of
the county have some recharge capacity. However, those maps are not yet
finalized, and the County does not consider the data to be a reliable basis for
analysis and conclusions under CEQA, so the Draft EIR does not display
them. As explained in Section D.1.b of Chapter 4.8 of the Draft EIR (page
4.8-24), General Plan 2030 includes a number of policies and actions that pro-
tect groundwater recharge areas. Policy W-P3.3 and Actions W-A3.1 and W-
A3.2 recognize the need to protect recharge areas with the understanding that
different areas have specific capacities to contribute to recharge.
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14-7: This comment references an upcoming County study called the Tus-
can Aquifer Project, and states that if the study will be used to support
changes in land use for General Plan 2030, it should be described in the Draft
EIR. The Tuscan Aquifer Project is a discrete research project and is not di-
rectly related to General Plan 2030 or the Draft EIR. It comprises a scientific
data gathering effort that is intended to improve upon existing data and analy-
ses. It would be too early to draw any conclusions from the Tuscan Project
that would have any meaningful significance to the Draft EIR.
The data from the study are not directly applicable to General Plan 2030.
However, future discretionary approvals will need to be consistent with both
General Plan 2030 and any applicable chapter and section of the Butte
County Code. Specific projects, whether developments or actions, pursued
through General Plan 2030 will have to undergo project-specific environ-
mental reviews, including analysis of potential impacts to groundwater. Data
developed through the Tuscan Aquifer Project will thus be incorporated as
applicable into environmental review for specific projects pursuant to the
General Plan 2030 Water Resources Element.
14-8: This comment states that many areas in which General Plan 2030
allows development are also potential recharge zones, and that potential im-
pacts on hydrology need to be identified before the land use designations for
these areas are changed. The comment also states that the Draft EIR does not
identify cumulative hydrology impacts. As indicated in the response to
Comment 14-6, the Draft EIR evaluates potential impacts related to recharge
areas in Section D.1.b of Chapter 4.8 on page 4.8-24. In addition, cumulative
hydrology impacts are discussed in Section D.2 on page 4.8-34 of the Draft
EIR. This section finds a less-than-significant cumulative hydrology impact
due to General Plan 2030 policies and actions, Best Management Practices,
and other RWQCB regulations in the region.
14-9: This comment notes that the comments provided in Letter 13 were
reviewed by the Water Commission, but that the Water Commission did not
have adequate time to review the letter in advance of its meeting. This is not
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a comment on the Draft EIR, and no response is required. Comments on the
Draft EIR from the Butte County Water Commission are included as Letter 7
in this Final EIR.
June 5, 2010
Dan Breedon, Principal Planner Butte County Department of Development Services 7 County Center Drive Oroville, CA 95965 Subject: New Comments on the Draft General Plan 2030 and DEIR The following are additional BEC comments on the DEIR for the Draft General Plan 2030 in time for the June 7 deadline. As you know I have been following the process from the very first session several years ago, attending many meetings and participating in many discussions in my formal role as Paradise Town Councilwoman, as a citizen of the county, and now for Butte Environmental Council. I admit at the outset that I have not read the DEIR cover-to-cover word-for-word. I will make these new comments as specific as possible and try not to repeat what I have previously submitted by e-mail or letter for the DEIR, anticipating that those comments will receive adequate attention.
This first section organizes my comments by areas accepted for development, which is how I have
suggested that the DEIR be organized to make it more understandable. After that I will go through
the DEIR as it is currently organized. The presentations to the Planning Commission and to the
Board of Supervisors should look at the impacts on the environment by proposed growth area.
But first, let me say that the county should have a goal to change the way that the Butte County Association of Governments (BCAG) distributes the State’s annual allocation to the county for accommodating the projected population growth. Currently, as you know, the methodology is to distribute the population growth equally among the municipalities and county by current population. There is another way that would have less impact on the environment. The current method induces sprawl throughout the county. Directing the majority of the population growth to Oroville should be adopted as a means of the population growth having less impact on the environment. Oroville has a large area accepted for growth, and it could be planned to have the least impact on the environment while being appreciated to improve the economies of scale in Oroville for increased business opportunities, public transit, and other public services. Oroville is also closer for commuters to the Sacramento area and to the Bay Area, and growth at the southern end of Butte County to the east of the best soils for agriculture and within a generally urbanized area makes a lot of sense for sustainable development. Why this has not already been part of the planning scenario discussion could be because this idea didn’t fit the meeting agendas somehow.
Overall, because of the Oroville option, there is no justifiable reason to prematurely rezone land that has the potential to have “significant and unavoidable” detriments to the environment in areas that have significant environmental constraints and sensitivities.
Comments on Specific Growth Areas
Magalia: Though the plan for Magalia is to zone for fewer residential units than are currently allowed, the area nevertheless is a growth area in the draft General Plan 2030. The topography of the area has constraints, more or less identified in the DEIR and associated documents. The cumulative effect of the lot-by-lot development that is the probable scenario for most all of the growth will make Magalia a more unsafe place to live. Given the current population and the lack of a reasonable circulation route, Magalia is effectively on a dead end and will remain on a dead end even should FH171 be paved to Butte Meadows. Any additional residential units means more lives at stake because Magalia is in forests surrounded by canyons with no evacuation route except a one lane road over Magalia dam, which is not the direction to go if the big fire occurs below Magalia. Magalia, specifically, currently needs a real fire evacuation route more than any other area in the county. The county should state a goal with action items, such as asking legislators for assistance, that Clark Road, SR191, be made a through route to SR32, much as BCAG’s May 9, 1994 Feasibility Study of State Route 191 Extension in Butte County proposed. The alternative for a tall bridge would have the least environmental impact, coupled with strong support for the
COMMENT LETTER #15
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protection of the very sensitive Forks of Butte Creek area. The county is seeking to widen the road
over the Magalia dam; however, not as aggressively as possible given its lower priority to projects in the valley. There are also alternatives that should be considered again more seriously, such as
using Bader Mine Road and Coutolenc Road and finding ways to achieve the goal of better circulation in and through Magalia. In fact, Figure 3-5 does not even show the name Magalia,
which seems really odd. Magalia is not part of Paradise, though it is in their sphere of influence, except for those properties that go beyond the sphere. The second big constraint and safety issue is
water for fighting fires as well as for safe yield, which the area is at the brink of breaching even in normal hydrologic years. The impact on the environment of allowing more homes to be built in
Magalia before the circulation and water constraints are solved would be the source of increased environmental disaster for Magalia. Magalia really needs a specific plan and more infrastructure
and safety personnel and facilities, police and fire, before any more development occurs, and this needs to be emphasized in the DEIR more than it is now.
Paradise: The southeast area of Paradise has two big areas projected for residential buildout that also have serious environmental constraints and significant impacts on air quality, biological
resources, hazards and safety, hydrology and water quality, land use, and just about every other area of environmental evaluation that could, in fact, be avoided by Paradise simply choosing infill
and compact growth as a strategy and/or by the County choosing the Oroville option. Paradise still has some unique farmland not identified on Figure 4.2-1, perhaps because it is within a sphere of
influence; yet, some unique farmland within the Oroville sphere of influence appears in that map.
Skyway: Do not approve any more rezones on the Skyway between Paradise and Chico that will
be sprawl inducing, such as residential units. The hazards and safety that development along the Skyway induce are significant and avoidable by not developing there. There is no proof that
recreational uses would suffer by not approving additional housing, only testimonials. There will be proof that watering Blue Oaks like watering to keep grass green will lead to environmental
degradation.
Butte Creek Canyon: Include a special planning area to preserve the historic and rural nature of the
area as well as to increase the safety of recreational uses so that the environment is not harmed.
Chico: There is much concern about the growth in the north between the airport and SR99. This
area should have a unique agricultural overlay zone such as in an area of Oroville. At the other end of Chico at 99 and Honey Run road, the tentatively approved sprawl is too close to Butte Creek
Canyon. In the Doe Mill area along Hwy 32 to the canyon rim overlooking Butte Creek Canyon, this is also unnecessary sprawl that will have environmental impacts that are avoidable. None of
these should be part of any general plan. The environmental impacts are significant and avoidable as stated above.
Butte Valley: A special planning area is called for in this most special part of the county where lot-by-lot splits and ranchettes are becoming all too common and threatening the agricultural uses and
the environmental sustainability of the area.
Yankee Hill: The deep brick color on the map of dwelling units estimated for buildout without
accompanying jobs and businesses really seems unwise, especially given the topography and generally arid environment, subject to periodic fires going through.
In short, the county has little business providing extensive growth areas. This is what the municipalities should provide, cities whose growth would not impact agricultural soils, some of
the most prime in the world. Growth should especially be targeted for concentrated growth in the City of Oroville, which has indicated growth would be appreciated where it would be appropriate.
Other higher density buildout proposed east of Oroville, east of SR162 by Forbestown, I defer to people more familiar with the area. The best alternative to the proposed project is concentrating
most growth in Oroville.
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DEIR 4.1-4.15
4.1 – Aesthetics
Seek to include the Skyway as a California Scenic Highway. This has been proposed but has been
deferred to future consideration. County Scenic Highways and Scenic Highway Zoning should be expanded and enhanced. There are many scenic vistas along the Skyway and along other roads of
the county that should be preserved that the draft General Plan 2030 does not adequately protect.
4.2 – Agriculture
This section, like the previous section is very general, so it is difficult to make specific comments. Agricultural lands within spheres of municipalities needs to be better indicated. The Figure 4.2-1
map is very general, a summary that could use more detail and comparison with other available and well regarded soil mapping.
4.3 – Air Quality
Since the Butte County Air Quality is currently and periodically out of compliance with state and
federal standards for health and safety, more needs to be done to come into compliance. Compact urban development incorporating more non-motorized forms of transportation along with more
availability of public transportation will help bring Butte County into compliance and provide healthier air for its citizens. Sprawl of urbanization into rural areas decreases air quality, and this is
an avoidable impact by directing development towards higher density zoning in existing incorporated areas and unincorporated pockets within those areas. Public transit and “complete
streets” transportation systems are more feasible when development is compact.
4.4 – Biological Resources
More needs to be included in this section about the Butte Regional Conservation Plan and the significance of this plan to the conservation of biological resources in Butte County. Certain areas
should be singled out as priorities for conservation, particularly areas which have been consistently threatened by development, such as, but not exclusive to, Butte Creek Canyon, Butte
Valley, and their canyon rims.
It is odd that Paradise and Magalia reservoirs are not identified in the Reservoirs section, since
they are of major significance to the second most highly urbanized areas in the county. Indeed, the water use is of more urban significance to water users in Butte County than the water from the
Oroville Reservoir which mostly goes out of county.
The restoration of Butte Creek, as a primary example of protection of waterways, should be
supported by the county more so than by recognizing the “Anadromous Fish Restoration Program (AFRP) and other organizations”. The county should instead take a lead in establishing the goal
and associated policies and action items to restore Butte Creek and its natural flows throughout Butte County.
The migratory deer herd areas map has been questioned by a number of people, and it appears to Butte Environmental Council that the number of deer has been underestimated. To exclude all of
the Paradise Ridge and Magalia from the Deer Herd mapping and simply give the area over to urbanization is wrong, an unnecessary “unavoidable” impact. Instead, there should be a way for
the deer to be accommodated even within and near Paradise and Magalia and Butte Creek Canyon and Butte Valley, instead of being killed by cars in mass numbers. There should be wildlife
corridors provided through these areas after a study of where these corridors could safely and most readily be provided through these and other urbanized and semi-rural areas.
4.5 – Cultural Resources
This section is entirely too general. Specific areas of the county having certain or concentrated
cultural resources should be mapped. Certainly Butte Creek Canyon is one such concentrated area
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in need of more organized county protection of cultural resources. Magalia Depot is as of yet
unprotected. The Historic Sawmill Trail and the rest of the old railroad grade from Chico to Stirling City and beyond is also largely available for preservation and continued public use. Many
significant cultural resources could be preserved and conserved with an increased transit occupancy tax supporting a county tourism department and with more related stated goals and
associated policies and action items in the draft General Plan 2030.
4.6 – Geology, Soils, and Mineral Resources
Environmental priorities should be indicated in this section, such as clean-up of existing dredge mining before premature loss of prime agricultural lands for aggregate mining. The types of
known mineral resources left in Butte County are not specified or mapped, which is puzzling, though some particular mines are mentioned as having “mineral resources” and mapped. Existing
mining operations are not mapped, and should be, along with an overlay of elevations and hydrologic layers, and perhaps property lines.
4.7 – Hazards and Safety
Already mentioned are circulation concerns and fire hazards, especially for Paradise and Magalia.
Magalia is not identified on the map, again in Figure 4.7-1, and the priority for roads and a moratorium on building is not indicated as significant and avoidable. There is only a description of
the hazards, not a description of the significance of the buildout expected or possible given the land use on the Ridge in the proposed General Plan 2030.
Land use designations and zoning in and around existing airports could be better allocated away from airports to avoid the noise impacts and increase safety for people. “Downzoning” in areas
that are inappropriately designated residential would be appropriate and worth pursuing near airports, wherever this is still possible.
4.8 – Hydrology and Water Quality
The well spacing requirements should be related to the actual geology of the area, which varies
considerably in different areas of the county. The well spacing in the mountains, foothills, canyons, and valley should not be a “one size fits all” requirement. Likewise with wastewater
requirements, which are under review and critical to preserving water quality since large urbanized areas of the county are on septic systems, many near reservoirs, rivers, creeks, and steams and in
recharge zones.
The County could play a role in regulating the purchase and subsequent use of pollutants of
various urban types, and increase their advocacy for curtailing agricultural pollutants and converting to a truly green, organic devolution.
Development in known flood zones, and in areas with the potential for flooding, should be accompanied with special building standards to avoid environmental impacts in a flood event.
We question the statement that “approximately 75 percent of the County’s residential water supply is extracted from groundwater.” What is the significance of this statement? Shouldn’t particular
municipalities be identified as to their use of ground and surface water? Section 3 is a particularly general section. Figure 4.8-2 is also very general. What is the significance of a “basin”, such as the
East Side Basin? Are these not recharge zones for the basins? The DEIR should at least speculate what will happen when massive development occurs in the East Side Basin, as is arguably
probable given the draft General Plan 2030, that is, probable - versus maximum - theoretical buildout. The DEIR fails to analyze the probable theoretical buildout adequately.
4.9 – Land Use
Note in the DEIR that FH171 is mostly not in Lassen National Forest, but through private land,
and that the paving of FH171 from Stirling City to Butte Meadows could be sprawl inducing
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without specific general plan goals, policies, and action items to discourage this scenario, either
from lot-by-lot development or larger projects or both.
The land use maps Figures 4.9-2 and 4.9-3 are not easily understood by their titles. What does
“existing” mean? Are these “existing” in the old general plan or in the draft General Plan 2030? Clarify this in the titles. Same with the “existing” zoning map, figure 4.9-4. If “existing” means
the old general plan, then indicate (in any case) what these maps have to do with the impact on the environment of the draft General Plan 2030 by overlaying the old and the new land use maps and
zoning maps so the differences become visible. The significance of these visuals to the DEIR is not easily apparent, though it may be clear in the text.
4.10 – Noise
The comparison charts of existing and future traffic noise levels shows significant noise impacts
along many sections of state routes and major corridors. These could be avoided by not sprawling into some of these areas, instead increasing the densities in existing urban areas, providing for
more public transit, and providing for more non-motorized vehicle corridors.
4.11 – Population and Housing
The statement on page 4.11-10 that there are no significant impacts related to population and housing as a result of General Plan 2030 is counterintuitive for people like me who live here. Page
4.11-6 makes a blanket statement that “the majority of the new residential units are projected to develop within the Spheres of Influence (SOIs) of the incorporated municipalities and in existing
unincorporated communities.” There is no analysis community by community as to the need of the sprawl into SOIs and other county areas. There is an assertion that 33,800 new residents would be
added to county areas, but there is no indication of the total new residents to the county or whether those 33,800 could also fit within the incorporated municipalities instead of within the SOIs or
unincorporated communities. The point is that large areas of county lands are poised to be unnecessarily rezoned to potentially accommodate 33,800 new residents sprawled through
environmentally sensitive areas of the county, contributing to air pollution and unsustainable type development, and there is no indication in the DEIR that this is at all called for. On the contrary to
the closing statement on page 4.11-10, mitigation measures are surely required for the loss of habitat of the sensitive species that live in the areas to be rezoned, the loss of water to recharge
zones, among other environmental concerns from noise to lighting to circulation to health and safety, not to mention the economic effect of spreading 33,800 new residents throughout the
unincorporated areas of the county, people who will need public services of many types.
4.12 – Public Services and Recreation
The finding that the fire protection service impacts would be “less than significant” is from the county’s perspective in that they have a policy of not providing services to rural areas to the
standard of urban areas; however, this policy has been less than satisfactory to rural residents. Magalia, with a density as high or higher than Oroville, is considered to be rural by county
standards and is notably underserved by sheriff and fire personnel. They have been underserved recreationally as well. Isolated subdivisions in newly urbanized areas that are not large enough to
pay for their own safety personnel will be underserved as well; this should be considered instead “significant” and such development should certainly not be part of a general plan. At the least,
significant mitigation measures should be put in place for the developers and new residents to pay for the public services and recreation that people moving into the new developments will surely
expect, including reasonable access to public education for K-12 students that does not adversely impact the already stressed economics of the current residents of the county.
4.13 – Transportation and Circulation
Besides the issues already mentioned above, there are many deficiencies in transportation and
circulation. Paradise, for example, does not have a budget to improve or to maintain roads much
15-38
15-39
15-40
15-41
15-42
15-43
15-44
15-45
15-37
cont.
5-70
6
New Comments on the County’s Draft General Plan 2030 and DEIR Butte Environmental Council
June 5, 2010
beyond fixing major potholes. In the fire of 2008 it was very apparent that Pentz road in Paradise
needs to be widened to accommodate two lanes downhill and one lane uphill in the event of an emergency evaucation. Other improvements are needed, but there is no money. The “existing
deficient roadway segments” map, figure 4.13-2 is very generous in its showing only one or two short segment of road each in Chico, Paradise and Oroville. Public transit discusses only the bus
system; what is missing is improvements to rail systems, or identifying and planning to retain corridors for future rail systems. The bicycle system should include a future class 1 along the
Durham Pentz Road from the class 1 on the Midway to Butte College, and there should be class 1 routes planned in Butte Valley. Horse trails should also be planned in places like Butte Valley.
Complete Streets development should be considered feasible for all areas of the county and implemented in conjunction with development everywhere development occurs and planned for in
existing communities of all densities.
4.14 – Utilities
It is interesting that given changes to the way energy is expected to be used with new State regulations, according to the DEIR, that the new development is considered not significant relating
to future energy consumption. If energy transmission lines, for example, are not needed to new developments between municipalities, that would be a less than significant impact regarding
electricity; however, that will not likely be the case. This example is curiously not cited.
4.15 – Greenhouse Gas Emissions
The impact is considered cumulatively significant and unavoidable. Could the impacts be avoidable with compact urban growth within existing municipalities instead of the sprawl
proposed in the General Plan 2030? This scenario does not appear to be adequately addressed throughout the DEIR; however, it is noted in the alternatives section in general as the
Concentrated Growth Alternative. The maps provided, however, include study areas that were rejected for development. The maps were based on proposed study areas, and three alternatives for
those given areas, not on guiding principles for the county as a whole. A map that shows concentrated growth according to principles of smart growth would best show a true concentrated
growth alternative for the county, which best matches the county’s guiding principles.
The product to date, the draft General Plan 2030 and the accompanying DEIR is an imperfect
document based on an imperfect process. How can we make these documents and the next steps in the process more perfect from here? In addition to the suggestions above, I urge you to compare
the products to date to the guiding principles, and slowing down with the introduction of the rezone documents.
Respectfully submitted,
Robin Huffman
Advocacy Director
15-49
15-50
15-51
15-45
cont.
15-46
15-47
15-48
5-71
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-72
Letter 15: Robin Huffman, Advocacy Director, Butte Environmental
Council. June 5, 2010.
15-1: This comment contains introductory language for the letter. No
response is required.
15-2: This comment suggests that the Draft EIR should be organized by
“areas accepted for development” or “proposed growth area.” Draft General
Plan 2030 presents land use designations for the entire County, but does not
target specific areas for development, nor guarantee that any development
will occur. Therefore the term “proposed growth area” is inaccurate and mis-
leading. The Draft EIR considers the allowed development that would be
reasonably foreseeable Countywide under the land use designations and poli-
cies in Draft General Plan 2030, consistent with CEQA requirements. It is
organized according to the topics in the CEQA Appendix G Environmental
Checklist form, consistent with widely accepted industry standards. The
Draft EIR covers the complete set of topics required by CEQA and is consis-
tent with the findings of the scoping period and Initial Study. It is not neces-
sary to reorganize the Draft EIR in response to a single request to do so.
15-3: This comment states that the County should change the way BCAG
allocates growth projections to jurisdictions in the county and should direct
population growth to Oroville. This is not a comment on the adequacy of
the EIR, so no response is required. It should be noted that, while it is out-
side of the County’s jurisdiction to direct growth to any incorporated city,
Draft General Plan 2030 does include policies to support coordinated plan-
ning with BCAG, LAFCO, and incorporated cities. For example, Policy LU-
P12.3 says “The County shall work closely with the Local Agency Formation
Commission to ensure that spheres of influence and land use plans in all areas
of the county are supported by the County,” and Action LU-A12.1 is to “De-
velop a coordinated countywide growth and annexation strategy in close co-
ordination with LAFCO.”
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-73
In addition, as noted in response 12-7 above, General Plan 2030 includes a
number of policies that direct growth to existing urbanized areas. Specifi-
cally, Policy LU-P15.2 requires that new urban development be primarily
located in or immediately adjoining already urbanized areas. In addition,
Policies LU-P8.3, LU-P8.4, LU-P8.5, and LU-P15.3 promote efficient infill
development near public facilities.
15-4: This comment discusses constraints to growth in the Magalia area,
specifically relating to fire hazards and adequate evacuation routes. The
comment acknowledges that the Draft EIR identifies these constraints. Wild-
land fire hazards are analyzed in Chapter 4.7, Section D.1.h on pages 4.7-30
through 4.7-33 of the Draft EIR. Potential impacts to evacuation plans are
analyzed on in Chapter 4.7, Section D.1.g on page 4.7-30. This comment does
not question the adequacy or conclusions of these sections. Instead, it sug-
gests specific actions that the County should take to improve evacuation
routes in the Magalia area. Since this is not a comment on the EIR, no addi-
tional response is required.
15-5: The commentor mentions that Figure 3-5 of the Draft EIR lacks a
place name for the community of Magalia. In response to this comment, this
figure has been revised to add the name Magalia, as shown in Chapter 3 of
this Final EIR.
15-6: This comment states that the Draft EIR should emphasize the public
safety impacts of allowing additional residential development in Magalia due
to high wildland fire hazards in the area. In response to this comment, the
discussion of wildland fire hazards on pages 4.7-30 and 4.7-31 has been revised
as shown in Chapter 3 of this Final EIR to provide additional information
more specific to the Magalia area.
However, the addition of this information does not change the conclusion of
the Draft EIR that the extensive policies in General Plan 2030 to protect new
development from fire hazards would reduce potential impacts to a less-than-
significant level. Specifically, as cited on pages 4.7-31 to 4.7-32 of the Draft
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-74
EIR, Policy HS-P11.4 requires that new development meet current fire safe
ordinance standards for adequate emergency water flow, emergency vehicle
access, signage, evacuation routes, fuel management, defensible space, fire safe
building construction, and wildfire preparedness, and Policy HS-P12.4 re-
quires all developments in wildland urban interface areas in High or Very
High Fire Hazard Severity Zones to provide, at a minimum, small-scale water
systems for fire protection.
15-7: This comment states that the Town of Paradise should “choose infill
and compact growth” and that the County should direct growth to Oroville.
See response to Comment 15-3, above.
15-8: This comment states that there is unique farmland within the Para-
dise Sphere of Influence (SOI) not identified on Figure 4.2-1. The types of
farmland identified on Figure 4.2-1 are based on the categories established by
the State of California Department of Conservation Farmland Mapping and
Mitigation Program (FMMP). The FMMP defines “Unique Farmland” as
“[f]armland of lesser quality soils used for the production of the state's leading
agricultural crops. This land is usually irrigated, but may include non-
irrigated orchards or vineyards as found in some climatic zones in California.
Land must have been cropped at some time during the four years prior to the
mapping date.” This definition does not include other land that may be culti-
vated in a unique manner and/or used for unique crops, and land that does
not meet the FMMP definition for Unique Farmland.
The types of farmland identified on Figure 4.2-1 are based on data collected in
2006 and published on June 24, 2008, which was the best available data from
the FMMP at the time the Notice of Preparation (NOP) for the Draft EIR
was issued. In response to this comment, the EIR consultant team reviewed
more recent FMMP data for Butte County, collected in 2008 and published
on February 26, 2010. This more recent data does not identify any additional
agricultural land in any category within the Paradise SOI beyond that already
shown on Figure 4.2-1. Therefore, no revisions to Figure 4.2-1 are needed.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-75
15-9: This comment states that the County should not rezone land along
the Skyway to allow more residential units in order to avoid impacts to pub-
lic safety. This is a comment on the appropriate zoning for this area and not
on the analysis in the Draft EIR, so no response is required.
15-10: This comments states that the County should establish a special
planning area for Butte Creek Canyon. It is not a comment on the EIR, so
no response is required. However, it should be noted that on July 27, 2010,
the Board of Supervisors acted to include a new action item under Goal COS-
6: “Work with Butte Creek Canyon residents and local groups toward adopt-
ing a planning strategy for a Butte Creek Canyon overlay. The purpose of
the planning strategy is to facilitate the protection and preservation of the
historical and ecological foundation of Butte Creek Canyon, including the
survival of salmon, steelhead and other sensitive plants and animals such as
the East Tehama Deer Herd, preservation of historical sites, ecological pre-
serves, and the optimum balance of recreation and residential use.”
15-11: This comment supports the application of the Unique Agriculture
Overlay designation to the area north of Chico. It also states that General
Plan 2030 should not allow “unnecessary sprawl” south of Chico or in the
Doe Mill area due to unspecified environmental impacts. The Draft EIR ana-
lyzes the potential environmental impacts of reasonably foreseeable develop-
ment allowed under General Plan 2030, including some additional residential
development in the area both north and south of Chico. Comments about
the type and amount of development that should be allowed are comments
on the land use designations and policies of General Plan 2030 and not on the
Draft EIR. Therefore, no further response is required.
15-12: This comments states that the County should establish a special
planning area for Butte Valley. It is not a comment on the EIR, so no re-
sponse is required.
15-13: This comment refers to the depiction of Yankee Hill on Figure 3-5 of
the Draft EIR, Projected 2030 Buildout. As explained in the accompanying
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-76
Table 3-5, on page 3-46 of the Draft EIR, the 2030 buildout estimates devel-
oped for the Draft EIR assume that 150 additional units would be developed
in Yankee Hill by 2030, equivalent to 10 percent of the total residential de-
velopment that would be allowed under General Plan 2030 designations and
policies. As explained in the text in Draft EIR Chapter 3, Section F.2.b, on
page 3-52, Yankee Hill is considered an established, unincorporated commu-
nity. Although development pressure in most of these communities is rela-
tively low, they are the types of already urbanized locations to which General
Plan 2030 directs future growth. Therefore, established unincorporated
communities that include potential for development based on the General
Plan 2030 land use map are considered 2030 development areas for the pur-
poses of the 2030 buildout projections used for the Draft EIR.
However, as explained in Chapter 3, Section F.1 on page 3-42 of the Draft
EIR, “The projected 2030 buildout estimate is used as a basis for the environ-
mental assessment, but it does not restrict or specify the actual physical loca-
tion of future development that will be permitted under General Plan 2030....
[G]eographic areas or potential development projects for which development
is assumed in this EIR are not in any way “pre-cleared” for development or
privileged for special consideration by County staff or the Board of Supervi-
sors; development in those areas still requires normal review under regular
County policies that are spelled out in General Plan 2030, the Butte County
Zoning Ordinance, and other County regulations.” [Emphasis added.]
This comment is a comment on the amount and type of development that
should be allowed in Yankee Hill, and not a comment on the analysis in the
Draft EIR, so no further response is required.
15-14: This comment states that the County should focus growth in the
City of Oroville. See response 15-2, above.
15-15: This comment states that the best alternative to General Plan 2030 is
“concentrating most growth in Oroville.” The Draft EIR identifies the Con-
centrated Growth Alternative, which would direct development toward exist-
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-77
ing urban areas like Oroville, as the environmentally superior alternative on
page 5-35. Since this comment agrees with the conclusion of the Draft EIR,
no further response is necessary.
15-16: This comment states that the Skyway should be designated a Cali-
fornia Scenic Highway. It is not a comment on the Draft EIR, so no response
is required.
15-17: This comment states that different methodology should be used to
map agricultural lands in the county. The commentor is correct that other
approaches to soil mapping are available. Figure 4.2-1 of the Draft EIR, Agri-
cultural Land, presents 2006 data, the most recent available, from the State of
California FMMP. This figure, and the accompanying analysis in Chapter
4.2, Section D.1.a, on pages 4.2-9 through 4.2-13 of the Draft EIR, directly
correspond to the standard of significance used to evaluate impacts to agricul-
tural land. The standard of significance, presented in Chapter 4.2, Section C,
on page 4.2-8, is whether the proposed project would “[c]onvert Prime Farm-
land, Unique Farmland, or Farmland of Statewide Importance (or “farmlands
of concern under CEQA”), as shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of the California Resources
Agency, to non-agricultural use.” [Emphasis added.] Therefore, it is appro-
priate to use the data from the California FMMP, as opposed to other sources
of soil mapping, as the basis for this analysis.
15-18: This comment states that compact urban development would im-
prove air quality in Butte County. As explained in response 11-2, above, Ta-
ble 4.3-7 of the Draft EIR shows that the proposed General Plan 2030 would
result in net decreases in all nonattainment pollutants from traffic operations
compared to existing conditions. This is partially a result of General Plan
2030 policies that focus development in urbanized areas, such as Policies LU-
P8.3, LU-P8.4, LU-P8.5, LU-P15.2 and LU-P15.3, and support public transit
and alternative transportation, such as Policies CIR-P2.1, CIR-P2.2, CIR-P2.4,
CIR-P3.1, CIR-P3.2, CIR-P3.3, CIR-P3.4, CIR-P3.5, CIR-P3.6, CIR-P3.9,
CIR-P4.1, CIR-P4.2, CIR-P4.3, CIR-P4.6, CIR-P5.1, CIR-P5.2, CIR-P5.3,
BUTTE COUNTY GENERAL PLAN 2030
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5-78
CIR-P5.4, CIR-P5.6, CIR-P5.7, and CIR-P5.8. In particular, it should be
noted that General Plan 2030 Policy CIR-P2.6 directs the County to incorpo-
rate “Complete Streets” policies that are designed and built to be safe for all
users, including bicycles, pedestrians, and transit users, as suggested by the
commentor. This comment is a comment on the policies of General Plan
2030 and not on the analysis in the Draft EIR, so no further response is re-
quired.
15-19: This comment states that the Draft EIR needs more discussion of the
Butte Regional Conservation Plan and its significance to conservation of bio-
logical resources in the county.
The purpose of Chapter 4.4 of the Draft EIR, Biological Resources, is to ana-
lyze the impacts of General Plan 2030 on biological resources in the county.
In this context, the Butte Regional Habitat Conservation Plan and Natural
Community Conservation Plan (HCP/NCCP) is discussed throughout the
chapter, but the basic importance of the HCP/NCCP is assumed and is out-
side of the scope of this discussion. The HCP/NCCP is summarized on page
4.4-6 as part of the regulatory framework section in the Biological Resources
chapter. Proposed covered species in the HCP/NCCP are discussed on pages
4.4-29, 4.4--48, 4.4--61, 4.4--62, and 4.4--70. The General Plan policies that
require coordination of the County in the HCP/NCCP process and of pro-
ject mitigation with the HCP/NCCP are discussed on pages 4.4-77 through
4.4-79. Coordination of General Plan policies with HCP/NCCP require-
ments regarding impacts on wetlands is discussed on pages 4.4-81 and 4.4-82.
Development of the General Plan with input and collaboration from the
Butte Regional HCP/NCCP process is mentioned on page 4.4-84. This ex-
tent of inclusion of the HCP/NCCP in the Draft EIR is considered adequate
for the CEQA analysis.
15-20: This comment states that specific areas should be singled out as prior-
ity conservation areas. Determination of priority conservation areas is a
function of the HCP/NCCP, not the General Plan. It should be noted, how-
ever, that the General Plan includes policies requiring coordination with the
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
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5-79
HCP/NCCP, as mentioned above. In addition, Draft EIR Figure 4.4-3 illus-
trates areas of US Fish and Wildlife Service-designated Critical Habitat (see
also Response 16-24). The General Plan includes policies requiring an assess-
ment of biological resources, impacts, and mitigation in coordination with
the HCP/NCCP for proposed projects in areas where Critical Habitat is des-
ignated. Therefore, the Draft EIR is adequate in its discussion of conservation
areas.
15-21: This comment states that Paradise and Magalia reservoirs should be
discussed in the Reservoirs section of the Biological Resources chapter. As
noted by the commentor, the Paradise and Magalia reservoirs are significant
sources of water for urban water users. In this context, they are included as
parts of the Del Oro Water Company and Paradise Irrigation District, dis-
cussed in the Utilities Chapter on page 4.14-10 and -12 in the Draft EIR.
However, these reservoirs are not included in the Biological Resources chap-
ter of the Draft EIR because they are not as important to wildlife habitat as
they are to the larger Lake Oroville and the Thermolito Forebay and After-
bay Reservoirs.
15-22: This comment states that Butte County should establish a goal, poli-
cies, and action items to restore Butte Creek. It is a comment on General
Plan 2030 and not on the analysis in the Draft EIR, so no response is neces-
sary.
15-23: This comment states that the number of migratory deer in the
county has been underestimated and that the County should accommodate
deer in Paradise, Magalia, and Butte Creek Canyon by creating wildlife corri-
dors. It states that allowing urbanization in the Paradise Ridge and Magalia is
“an unnecessary ‘unavoidable’ impact.” However, the Draft EIR does not
find an unavoidable impact to deer herds. As discussed in Chapter 4.4, Sec-
tion D.1.d, on page 4.4-84 of the Draft EIR:
Several policies and actions of the Conservation and Open Space Element
of General Plan 2030 would… help protect deer and other animal migra-
tion, including protecting habitat corridors (COS-P7.1) and maintaining
BUTTE COUNTY GENERAL PLAN 2030
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buffers along riparian corridors (COS-P7.6). Policy COS-P7.2 would
protect migrating deer herds and other migrating animals by allowing
and encouraging clustered development with remaining areas being con-
served under permanent conservation easements. As trustee agency for
the deer herd, DFG will comment on future development projects rela-
tive to the on-going health of the migratory deer herd. In addition, Ac-
tion COS-A10.1 directs coordination with DFG to monitor effects of de-
velopment on migratory deer herds. Policies of General Plan 2030, to-
gether with other federal and State policies and regulations, would reduce
potential impacts to deer and other migratory species to a less-than-
significant level.
The Draft EIR’s analysis of impacts to deer herds is adequate, and no revi-
sions are needed.
15-24: This comment states that the cultural resources section is too general
and suggests that areas of the county containing specific or concentrated areas
of cultural resources be mapped.
Due to the confidential nature of the locations of archaeological resources,
information regarding locations of cultural resources is not included in public
documents and is not included in this EIR or its appendices. A cultural re-
sources sensitivity map was prepared for the project area during alternatives
analysis and this map was submitted to the County for their records. Maps
showing the locations of historic buildings and structures within the county
would be on so large a scale as to be useless for identifying such buildings and
structures. Additionally, this information changes periodically as structures
reach 50 years of age and are evaluated for listing on various historic registers.
The Northeast Information Center at CSU Chico is the repository for this
information and should be consulted on a project-by-project basis to ensure
the most recent information is considered.
15-25: This comment lists specific locations, including Butte Creek Canyon,
Magalia Depot, and the Historic Sawmill Trail, that the commentor suggests
BUTTE COUNTY GENERAL PLAN 2030
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5-81
should be preserved and conserved using funding generated by an increased
transient occupancy tax. It is not a comment on the Draft EIR, so no re-
sponse is required.
15-26: This comment states that the County should prioritize clean-up of
existing dredge mining. This is a comment on County policy, not a comment
on the analysis in the Draft EIR, so no response is necessary.
15-27: This comment states that the Draft EIR does not map known min-
eral resources in Butte County. As indicated on page 4.6-16 of the Draft EIR,
the State Geologist has not yet mapped the mineral resources in Butte
County. However, public or private entities can petition the State Mining
and Geology Board (SMGB) to classify specific lands that contain significant
mineral deposits and that are threatened by land use incompatibilities. In
1994, the SMGB received a Petition for Mineral Classification for Martin Ma-
rietta Materials Table Mountain Quarry near Oroville. This petition involves
approximately 320 acres of land that is considered an active basalt mine. The
SMGB concluded that part of this mine is classified as a mineral resource of
regional or statewide significance and designated the site as MRZ-2. In addi-
tion, in 2001, the State classified a portion of the M&T Chico Ranch, a previ-
ously-proposed mining site located adjacent to Little Chico Creek 5 miles
southwest of Chico, as a mineral resource of regional or statewide significance
(MRZ-2). However, the M&T Chico Ranch mine proposal was not approved
and is not currently being considered for mining under County permit.
These two identified mineral resource areas are shown in Figure 4.6-5 on page
4.6-17 of the Draft EIR. In addition, in response to this comment, the Draft
EIR has been revised to include a new Figure 4.6-5, which maps active mining
sites in Butte County, as noted in Chapter 3 of this Final EIR.
Although additional mineral resource mapping is not available, the map of
MRZ-2 sites in Butte County provides an adequate level of existing setting
information for the analysis of mineral resource impacts provided on pages
4.6-27 and 4.6-28 of the Draft EIR. That analysis of mineral resource impacts
addresses the following standard of significance: “Result in the loss of avail-
BUTTE COUNTY GENERAL PLAN 2030
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ability of a known mineral resource that would be of value to the region or
the state, or of a locally-important mineral resource recovery site delineated
on a mineral resource plan, local general plan, specific plan or other land use
plan.” The MRZ-2 sites are the only sites that have been mapped as mineral
resources of value to the region or state.
15-28: This comment states that the Draft EIR should map existing mining
operations. A map and table listing existing mining operations was included
in the Setting and Trends Report as Figure 11-1 and Table 11-1 and is not re-
produced in the Draft EIR. The inclusion of this information in the Draft
EIR would not change the conclusion of the analysis on page 4.6-27 of the
Draft EIR that the policies and actions of General Plan 2030 would avoid the
loss of availability of a known or locally important mineral resource that
would be of value to the region or the State, which would be consistent with
CEQA standards of significance.
15-29: This comment states that fire hazards are a concern in Paradise and
Magalia. See responses 15-4 and 15-6, above. In response to this comment,
Figure 4.7-1 has been revised to add the name Magalia, as shown in Chapter 3
of this Final EIR.
15-30: This comment states that the Draft EIR does not describe the signifi-
cance of the expected buildout on the Tuscan Ridge under General Plan 2030.
As explained in Chapter 3, Section F on page 3-41 of the Draft EIR, the
analysis of hazards and safety in the Draft EIR must consider whether Gen-
eral Plan 2030 would allow any development in a geographic area, such as a
fire hazard severity zone, which could trigger potential impacts. For this
analysis, the question is not how much development General Plan 2030 would
allow, but where that development could potentially be located. Therefore,
all potential development allowed by General Plan 2030 was evaluated to as-
sess impacts to hazards and safety.
15-31: This comment states that residential development should not be al-
lowed near airports and that areas near airports should be “down-zoned” to
BUTTE COUNTY GENERAL PLAN 2030
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avoid inappropriate development. This is a comment on County policy, and
not a comment on the analysis in the Draft EIR, so no response is necessary.
In addition, see response 3-1 explaining that General Plan 2030 has been re-
vised to be consistent with the ALUCP, and an ALUCP override is no longer
necessary.
15-32: This comment addresses the development of well spacing require-
ments and pollutant regulations. It is a comment on County policies and not
on the analysis or conclusions of the Draft EIR, so no response is necessary.
15-33: This comment states that special building standards should be applied
to development in known flood zones. This is a comment on County policy,
and not on the analysis or conclusions of the Draft EIR, so no response is
necessary. However, it should be noted that General Plan 2030 includes two
detailed policies regulating new development in flood zones, Policies HS-P2.4
and HS-P2.5, which are considered in the Draft EIR’s analysis of flood haz-
ards.
15-34: This comment questions a statement in Chapter 4.8, Section B.3 on
page 4.8-14 of the Draft EIR regarding groundwater as a source for residential
water supply. As indicated in Chapter 3, citations for this statement have
been provided. The primary source for this statement is a drinking water
quality report for the northern Sacramento Valley. In addition, this state-
ment is supported by a presentation by Dan McManus of the California De-
partment of Water Resources (DWR) to the General Plan 2030 Citizens Advi-
sory Committee on January 17, 2008. In his presentation, Mr. McManus in-
dicated that, based on 2000 data, urban uses in Butte County use approxi-
mately 43 thousand acre feet (TAF) from groundwater sources and 14 TAF
from surface water sources. Therefore, approximately 75 percent of urban
water demands are served by groundwater.
The statement is provided in order to inform readers of the existing condi-
tions regarding water use and groundwater in Butte County.
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Regarding whether the Draft EIR should identify whether municipalities use
groundwater or surface water, the General Plan 2030 Draft EIR does not ana-
lyze growth inside incorporated municipalities. For growth in the unincor-
porated County, see response 12-4.
15-35: This comment asks about the significance of the basins illustrated in
Figure 4.8-2. The text on page 4.8-15 of the Draft EIR has been revised to
include an explanation of these basins, as shown in Chapter 3 of this Final
EIR. These basins are hydrologic basins, as depicted by the California De-
partment of Water Resources, and do not equate to recharge zones. The addi-
tional explanation of the basins does not affect the analysis or conclusions of
the Draft EIR.
15-36: This comment states that the Draft EIR should analyze the water
supply impacts of probable development in the East Side Basin. The Draft
EIR does not analyze water supply impacts based on subbasin boundaries, but
it does analyze the impacts of all reasonably foreseeable development that
would be allowed under General Plan 2030. See responses 12-2, 12-3, and 12-
6, above, for more detailed information on the Draft EIR’s water supply
analysis as it relates to probable development.
15-37: This comment requests that the Draft EIR note that Forest Highway
171 (FH171) is on private land and that paving this roadway could induce
sprawl. The commentor is correct that this roadway is located primarily on
land owned by a private timber company. However, it should be noted that
General Plan 2030 does not call for the paving of FH171. As explained in
Chapter 4.13, Section A.2.a on page 4.13-6 of the Draft EIR, the BCAG 2008-
2035 Regional Transportation Plan (RTP), the blueprint for transportation
improvements in the county, calls for the reconstruction of Forest Highway
171 from Inskip to Butte Meadows. However, this project is not part of
General Plan 2030 and, as noted in the Draft EIR, Butte County does not
have the authority to make final decisions regarding the improvements in-
cluded in the RTP. Therefore the Draft EIR appropriately does not analyze
the potential impacts of this project. It should be noted that General Plan
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-85
2030 designates the entire area surrounding FH171, Stirling City and Butte
Meadows with the Timber Mountain designation, which requires a minimum
160-acre parcel size and limits residential uses to one single-family dwelling
per legal parcel. This restrictive land use designation, along with other Gen-
eral Plan 2030 policies directing development to urbanized areas, would se-
verely limit the potential for sprawling residential development in this remote
corner of the county.
15-38: This comment requests an explanation of Figures 4.9-2 and 4.9-3. As
explained in Chapter 4.9, Section B at the top of page 4.9-7, Figure 4.9-2
shows what land uses exist on the ground today. Figure 4.9-3 appears in Sec-
tion B.2 of Chapter 4.9, which is entitled “Existing Butte County General
Plan” and which explains that “[t]his section describes the land use designa-
tions in the existing Butte County General Plan, which would be updated and
replaced by the proposed General Plan 2030.” Since General Plan 2030 has
not been adopted, it cannot be considered the “existing” General Plan for the
County and is instead referred to throughout the Draft EIR as “proposed Gen-
eral Plan 2030.” The description of existing General Plan land use designa-
tions is provided in the interest of full disclosure for the reader. However,
CEQA Section 15125(a) directs that an EIR should utilize “the physical envi-
ronmental conditions in the vicinity of the project, as they exist at the time
the notice of preparation is published” as “the baseline physical conditions by
which a lead agency determines whether an impact is significant.” Therefore,
the impacts of General Plan 2030 must be based on impacts to the existing
physical environment, not on differences between General Plan 2030 and the
County’s existing General Plan, so a comparison of existing and proposed
maps of General Plan land use designations is not relevant to the environ-
mental analysis required of the Draft EIR.
15-39: This comment states that noise impacts identified in the Draft EIR
could be reduced by increasing densities in urban areas and improving transit
and non-motorized transportation. See response 15-18 regarding policies in
General Plan 2030 that are consistent with this suggestion. Since this com-
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-86
ment does not dispute the EIR’s analysis or conclusions relating to noise im-
pacts, no further response is required.
15-40: This comment states that the 33,800 new residents assumed to be
generated by the projected 2030 buildout for purposes of the quantitative
analyses in the Draft EIR should be housed within incorporated municipali-
ties. See responses 13-7 and 15-3. The role of the Draft EIR is to disclose the
potential environmental impacts of General Plan 2030. Comments regarding
how much growth should be allowed in the county are comments on the
policies and land use designations in General Plan 2030 and not comments on
the analysis in the Draft EIR.
15-41: This comment disagrees with the statement on page 4.11-10 of the
Draft EIR that says “[s]ince there are no significant impacts related to popula-
tion and housing as a result of General Plan 2030, no mitigation measures are
required.” The commentor lists impacts relating to biological resources,
groundwater, noise, lighting, circulation and health and safety that would
result from development allowing 33,800 new residents in unincorporated
Butte County. Chapter 4.11 of the Draft EIR, Population and Housing, is
specifically focused on the standards of significance listed in Section C of that
chapter, on page 4.11-5, consistent with the standards contained in CEQA
Guidelines Appendix G.
15-42: This comment states that the County’s policy of providing a rural
level of fire, sheriff, and recreational service to residents in Magalia is not sat-
isfactory to rural residents. This is a comment on County policy and not on
the analysis in the Draft EIR. It is appropriate and necessary to base the
analysis in the Draft EIR on currently adopted County policies, regardless of
whether all County residents support these policies.
15-43: This comment states that new subdivisions will be underserved by
safety personnel and should not be allowed under General Plan 2030. As dis-
cussed in Chapter 4.12, Sections A.3 (pages 4.12-5 to 4.12-6) and B.3 (pages
4.12-13 to 4.12-15) of the Draft EIR, General Plan 2030 includes a number of
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-87
policies to ensure that adequate sheriff and fire services are provided as or
before new development occurs, including master planned development. For
example, Policy PUB-P2.2 requires that the County’s adopted Standards of
Cover for fire protection be maintained and implemented, and Policy PUB-
P2.3 requires that new fire stations be located on sites that are easily accessi-
ble, close to existing or future development, and/or close to fire hazard areas.
In addition, Land Use Element Policy LU-P9.1 directs the County to work
with municipalities and service providers to ensure that services are available
for new development and consistent with master plans. Therefore, the Draft
EIR concludes that impacts to public safety would be less than significant.
15-44: This comment states that the County should require developers and
new residents to pay for public services, recreation, and K-12 education. This
is a comment on County policy and not a comment on the analysis of the
Draft EIR, so no response is necessary.
15-45: This comment states that the Town of Paradise does not have suffi-
cient funds for needed roadway improvements, and that Pentz Road in Para-
dise needs to be widened. Roadway improvements within the Town of Para-
dise are not under Butte County’s jurisdiction and are not included as part of
General Plan 2030. Roadway deficiencies within the Town are not analyzed
as part of the Draft EIR.
15-46: This comment states that Figure 4.13-2 showing existing deficient
roadway segments is “generous.” It is important to note that not every road-
way in the county and the incorporated municipalities was analyzed in the
Draft EIR. Figure 4.13-2 highlights only deficiencies on roadway facilities
that were selected for analysis. The specific facilities that were selected for
analysis are listed in Table 4.13-4 of the DEIR. These facilities were selected
for analysis either because they were believed to carry relatively high volumes
or because they provide an important connection to populated areas or major
county resources. It is likely that existing deficiencies are present on road-
ways that were not selected for analysis.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-88
For those facilities that were selected for analysis, an existing deficiency was
identified if the roadway segment operates at unacceptable levels during the
PM peak hour according to the level of service threshold criteria set by the
applicable agency (County, City, Caltrans, etc). This level of service was cal-
culated based on each roadway segment’s existing geometry, the PM peak
hour traffic count volumes, and specific volume threshold criteria for each
roadway type, as summarized in Table 4-13.2.
15-47: This comment states that the Draft EIR should discuss improve-
ments to rail systems and retention of corridors for future rail systems. Rail
facilities and services are described on page 5-37 to 5-38 in the Setting &
Trends Report. As noted in the Setting & Trends Report, there are currently
no plans for additional future rail systems in Butte County. However, old
rail corridors that are no longer in service are being preserved as bicycle and
pedestrian trails. Rail transportation is not under the County’s jurisdiction.
However, General Plan 2030 does include a policy and an action to support
rail transit. Policy CIR-P3.1 states that “[t]he County supports improved
connections to other regional transportation services, such as rail and re-
gional/national bus lines, and to connect Butte County communities with
each other.” Action CIR A3.1 states that the County will, “[i]n conjunction
with the Butte County Association of Governments seek funding to develop
a plan to support and promote rail service that would connect Butte County
with other regions and would connect Butte County communities with each
other.”
15-48: This comment provides suggestions for future bicycle and equestrian
trails. This is a comment on County policy and not on the analysis or con-
clusions of the Draft EIR, so no response is necessary. As noted in response
15-18, above, General Plan 2030 Policy CIR-P2.6 directs the County to in-
corporate “Complete Streets” policies that are designed and built to be safe for
all users, including bicycles, pedestrians, and transit users, as suggested by the
commentor.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-89
15-49: This comment states that new energy transmission lines may be
needed to serve new development and that the Draft EIR does not cite the
potential need for new energy transmission lines. The analysis in the Draft
EIR is appropriately focused on the standard of significance contained in
Chapter 4.14, Section E.3, on page 4.14-59, which asks whether the project
would “[r]esult in the wasteful, inefficient and unnecessary consumption of
energy during construction or operation.” Because General Plan 2030 does
not propose any specific type or location of development, it would be specu-
lative and premature for the Draft EIR to contain guesses about the type and
amount of energy that future development in the county may require and
whether or not that energy could be supplied through existing facilities.
Thorough environmental review of new energy transmission lines will be
required if and when those new transmission lines are necessitated by specific
projects.
15-50: This comment states that impacts from greenhouse gas emissions
could be avoided or reduced by considering a different Concentrated Growth
Alternative for the County. The alternatives analysis in the Draft EIR is con-
sistent with Section 15126.6(a) of the CEQA Guidelines by providing “a
range of reasonable alternatives… which would feasibly attain most of the
basic objectives of the project but would avoid or substantially lessen any of
the significant effects of the project.” In particular, the Concentrated Growth
Alternative would have less environmental impacts than the proposed pro-
ject, as shown in Table 5-2 on page 5-11 of the Draft EIR, and is identified as
the environmentally superior alternative on page 5-35. See response 15-3 re-
garding the County’s authority to direct growth to incorporated communi-
ties.
15-51: This comment states that the Draft EIR is imperfect and that the
County should reconsider the General Plan 2030 process overall. This Final
EIR contains responses to all specific comments and criticisms of the Draft
EIR. Based on the written comments received on the Draft EIR, as well as
public input received at workshops and hearings on both the Draft EIR and
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-90
General Plan 2030, the County believes that both documents are complete
and accurate to the best of the County’s ability.
June 7, 2010
Dan Breedon
Butte County Planning
7 County Center Drive
Oroville, CA 95965
Re: Butte County General Plan 2030 Draft Environmental Impact Report
Dear Mr. Breedon:
AquAlliance is submitting the following comments, questions, and suggestions for the Butte
County General Plan 2030 (“General Plan”) Draft Environmental Impact Report (“DEIR”).
Project Description
The DEIR asserts that the “projected 2030 buildout of the unincorporated county includes,
“13,700 additional residential units, 33,800 new residents, as well as the development of 1.8
million square feet of new retail and office space and 1.1 million square feet of new industrial
space by 2030.” However, on page 3-56 in the Project Description (“Project”) chapter for the
General Plan 2030 and the Airport Land Use Plan (“ALUCP”) override, it is revealed that the
General Plan actually could permit:
♦ 61,100 new dwelling units
♦ 150,900 new residents
♦ 19.1 million square feet of new retail/office space
♦ 19.4 million square feet of new industrial space (p. 3-56)
Which depiction is the accurate Project description for the public, policy makers, and for the
purposes of CEQA? Butte County needs to present a definable Project and analyze it under the
California Environmental Quality Act (CEQA). The DEIR states, “However, as discussed in
Chapter 3, it is extremely unlikely that maximum theoretical buildout would ever occur under
General Plan 2030. Therefore, an analysis of maximum theoretical buildout is not required by
CEQA.” (p. 4.8-34) Presenting the Project and then avoiding analysis because an unidentified
actor or actors decided that it really won’t happen at the numbers expected, is confusing at best
and is an attempt to circumvent CEQA requirements. The sine qua non of an environmental
COMMENT LETTER #16
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2
impact report (EIR) is an accurate project description.1 Any evaluation of the General Plan “must
necessarily include a consideration of the larger project, i.e., the future development permitted by
the amendment.” 2 In order to comply with CEQA, the DEIR must therefore describe and
consider the full extent of the growth permitted by the Plan and must quantify the impacts. (Id.)
It is quite simply a CEQA requirement that an EIR must evaluate the project’s potential to affect
the environment, even if the project does not ultimately materialize.3
For the purposes of our comments, the Project definition will be what the DEIR refers to as the
“maximum theoretical buildout,” the 61,100 new dwelling units, 150,900 new residents, 19.1
million square feet of new retail space, and 19.4 million square feet of new industrial space.
General Comments
A) As stated in the General Plan, policies are intended to guide “[d]ecision-making as the County
works to achieve a goal. Such policies, once adopted, represent statements of County regulation.
A policy is on-going and requires no further implementation. The General Plan’s policies set out
the standards that will be used by County staff, the Planning Commission and Board of
Supervisors in their review of land development projects and in decision-making about County
actions.” (p.5) Policy statements viewed as guidance are understandable, but how will they
become regulation? How will this comply with CEQA? Large portions of the DEIR and General
Plan consist of unenforceable statements of goals and objectives, using terms like “support” or
“encourage”,” rather than “require.” For example: “Policies HS-P4.1 and HSP4.2 support the
efforts of public and private entities to study levee stability and design and reconstruct levees
that do not meet flood protection standards.” (DEIR p. 4.8-32); “Policy PUB-P6.5 encourages
permanently protected and maintained open space in new development using mechanisms such
as conservation easements and development agreements.” (DEIR p. 4.12-55); “Carpooling shall
be encouraged by providing additional carpool pickup and park-and-ride locations near transit
centers and at freeway interchanges.” (GP p. 174) These advisory statements do not constrain or
direct growth in an enforceable manner.
There are many “shall” policy statements in the General Plan that are referenced in the DEIR.
1 San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus (1994) 27 Cal.App.4th 713, 730; County of
Inyo v. City of L.A. (1977) 71 Cal.App.3d 185, 199.
2 City of Redlands v. County of San Bernardino (2002) 96 Cal.App.4th 398, 409 (citation omitted).)
3 Bozung v. Local Agency Formation Com. (1975) 13 Cal.3d 263, 279, 282.
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cont.
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3
They are grand statements of intent, but there is no expressed mechanism that will make them
enforceable. These many “shall” policies provide the County with too much discretion and the
public and policy makers with too little direct and clear understanding of the impacts from the
Project. Rather than presenting an exhaustive list of impacts, the County has chosen to obfuscate
the impacts and defer facing mitigation requirements to a future time. The DEIR states on page
2-3 that, “Rather than mitigating impacts from implementation of General Plan 2030 through
mitigation measures in this EIR, the policies and land use map in General Plan 2030 are intended
to prevent the majority of environmental impacts altogether.” (emphasis added) The intentions
behind this path may be honorable, but the DEIR lacks honest disclosure and discussion of the
serious and significant impacts that will arise from the development of the Project. The DEIR
goes on to say that, “As described in Section D, the General Plan 2030 process involved a wide
variety of stakeholders and interests. As a result, this General Plan is intended to meet multiple,
and sometimes competing, policy objectives. Therefore, the County may not be able to adhere to
every policy in every decision that it makes to implement this Plan. The Board of Supervisors
will have discretion over which policy objective it will follow in instances in which there are
competing policy objectives affecting a single decision.” (emphasis added)
While AquAlliance appreciates that the County divulges that there is the potential to have major
policy directives ignored that are relied upon for mitigation in the General Plan and DEIR,
CEQA mandates that public agencies not approve projects unless feasible measures are included
that mitigate the project’s significant environmental effects.4 CEQA therefore requires that
“[e]ach public agency shall mitigate or avoid the significant effects on the environment of
projects that it carries out or approves whenever it is feasible to do so.”5 The mitigation measures
must be enforceable, rather than just vague policy statements.6 The DEIR fails these
requirements.
As mentioned above, the DEIR fails to divulge impacts from the Project and asserts that policies
will form the basis for mitigation even with the Supervisors’, “[m]ay not be able to adhere to
every policy in every decision that it makes to implement this Plan. The Board of Supervisors
4 Pub. Resources Code, § 21002.
5 Pub. Resources Code §§ 21002.1, subd. (b); City of Marina Board of Trustees (2006) 39 Cal.4th 341, 360.
6 See Pub. Resources Code § 21081.6, subd. (b); Federation of Hillside and Canyon Associations v. City of Los
Angeles (2000) 83 Cal.App.4th 1252, 1261 & n.4 (agency must take steps to ensure mitigation measures are fully
enforceable through permit conditions, agreements, or other measures).
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cont.
5-93
4
will have discretion over which policy objective it will follow in instances in which there are
competing policy objectives affecting a single decision.” Expanding the quote from the previous
page, the DEIR contends that, “However, by incorporating policies intended to avoid
environmental impacts and by steering development to existing incorporated and unincorporated
cities and communities, General Plan 2030 is largely self-mitigating. Rather than mitigating
impacts from implementation of General Plan 2030 through mitigation measures in this EIR, the
policies and land use map in General Plan 2030 are intended to prevent the majority of
environmental impacts altogether.” (p.2-3)
With all of the unenforceable policies and actions presented in the DEIR that is theoretically
analyzing the impacts from “[6]1,100 new dwelling units, 150,900 new residents, 19.1 million
square feet of new retail/office space, and 19.4 million square feet of new industrial space,” how
is this possible? The County owes all policy makers, from both incorporated and unincorporated
jurisdictions, and the public a complete answer to that question. It is like BP oil suggesting that
they have contained the worst, documented environmental disaster in the United States merely
because they say they have done so. The County must provide demonstrable proof through
specific avoidance and mitigation measures and present it in a supplemental EIR, so the public
may actually have a substantive document on which to comment.
The General Plan states that, “Some policies in this Plan are also required as means to mitigate
environmental impacts under the California Environmental Quality Act (CEQA). These policies
all use the imperative “shall,” and in all cases are mandatory. These policies will be marked with
an asterisk (*) in the Final General Plan.1” (p. 13) Unfortunately, the footnote informs the reader
that the County is unable to determine which policies will rise to this level of significance: “At
the time of publication of this Public Review Draft General Plan, the list of policies that are
required for environmental impact mitigation under CEQA has not been finalized. This list will
be provided separately for use during the review of the Public Review Draft General Plan, and
incorporated into the Final General Plan document prior to adoption.” (General Plan p. 13)
Additionally, it must be determined and presented to the public and policy makers how the
“shall” policies with asterisks will be enforced. The public and policy makers are again unable to
grasp the significance of the whole of the Project due to a chosen phasing strategy by the County.
A general plan must be more than a statement of broad but unenforceable policies and goals for
the future. The General Plan must state “with reasonable clarity” what the plan is, not just what
is hoped for with yet undetermined environmental impact mitigation under CEQA.7
7 Concerned Citizens of Calaveras County v. Board of Supervisors (1985) 166 Cal.App.3d 90, 97.
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cont.
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5
Section 21081.6 of the California Public Resources Code requires public agencies to “adopt a
reporting and monitoring program for the changes made to the project or conditions of project
approval, adopted in order to mitigate or avoid significant effects on the environment.” A
Mitigation Monitoring and Reporting Program is required for the proposed Project. The DEIR
should have identified significant adverse impacts with avoidance and mitigation measures.
Please present all avoidance and mitigation measures and a summary table in a supplemental EIR
for public review and comment.
B) It is still noted that Butte County has a weak objective regarding the environment. “Address
the protection, enhancement, utilization and management of natural resources and the
environment. “ DEIR p.3-10 How will the County “address” environmental protection when it
has failed to disclose the myriad, potential impacts to the environment and disclose avoidance
and mitigation measures?
C) The Specific Plan areas designated on the Land Use map Figure 3-3 should be removed from
the Butte County General Plan 2030. New residential growth should occur in the incorporated
towns and cities, not the County. Potential growth in areas adjacent to existing, incorporated
communities should be left to the planning of the communities where there is greater potential
for more efficient use of land and the ability to provide services.
Biological Resources
A) Figure 4.4-1 fails to illustrate the important wildlife areas that have been preserved by fee
title, with conservation easements or are mitigation areas from prior development. This should be
corrected as it will assist the understanding of policy makers and the public with the values from
existing protected lands and the potential incompatibilities with activity on adjacent lands.
B) There is a very contradictory paragraph on page 6-4 of the DEIR “Although growth and
development under General Plan 2030 would not result in environmental impacts to biological
resources, development in Butte County and elsewhere in the region would contribute to the on-
going loss of undeveloped natural lands, which could impact special-status species, sensitive
natural communities, federally-protected wetlands, and wildlife and fish movement corridors.
This cumulative impact would be significant and unavoidable.” How will there be no impacts to
biological resources when significant and unavoidable impacts are expected? This lack of clarity
renders the document useless. These contradictory statements are also found elsewhere in the
DEIR.
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6
Hydrology and Water Quality
A) The water quality section (pp.4.8-12 to 4.8-14) discloses the Central and Southwest plumes in
the Chico Urban Area, but neglects to reveal the numerous additional ground water plumes that
have plagued not only the Chico Urban Area, but also Oroville. The DEIR acknowledges that
other “[g]roundwater contaminants of concern in Butte County include arsenic, chromium,
copper, dioxin, and polynuclear aromatic hydrocarbons,” but fails to disclose the locations,
extent of the ground water pollution, and the hazards to human and environmental health. A true
accounting of all past and current ground water contamination and the location must be disclosed
and analyzed. Completely absent from the DEIR is any mention of the gas additive MTBE,
which has affected numerous areas of Butte County. Documentation and a map illustrating the
cumulative contaminated areas must be presented in a supplemental EIR.
B) Where is a water supply analysis for the Project? Ground water supply and recharge is briefly
discussed with an acknowledgment that at least 75% of Butte County’s residents depend on
groundwater. (pp.4.8-14 to 4.8-15) This is a serious omission.
C) What is the original source of the following conclusory statements? “Of the 3.77 MAF of
annual rainfall, less than half is used.7 Therefore, more than 2 MAF are currently available for
recharge or discharge via surface and subsurface outflow, although this amount will not always
be available.” The source is listed as the Butte County General Plan Technical Update
Background Report, page 12-16, but what scientific data produced the information?
Land Use
A) As currently drafted, the General Plan is not a true planning document. It creates a set of
unenforceable preferences and policies for how growth will occur in the County on the available
land. The County can transform the General Plan from an aspirational document to the legally-
required constitution for future development by ensuring that goals and objectives are linked to
specific and enforceable worded policies and implementation measures. Such measures can
include, for example, development phasing so that land is not developed until available infill
(areas in or adjacent to developed areas) has been used to the maximum extent feasible, and
coordination between a County and the cities in its jurisdiction about where future growth will
occur.
B) The DEIR acknowledges that the General Plan would have “significant land use impacts” if
there was a, “Conflict with any applicable plan, policy, or regulation of a government agency
with jurisdiction over land in unincorporated Butte County that has been adopted for the purpose
of avoiding or mitigating an environmental effect.” Id p. 4.9-29 The DEIR acknowledges the
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7
federal Bureau of Land Management and Forest Service plans with which it must be compatible
to avoid significant impacts. Noticeable absent from the federal plans section is any mention of,
let alone coordination with, the Vernal Pool Critical Habitat designation and the Recovery Plan
for Vernal Pool Ecosystems in California and Southern Oregon. This is a very serious omission
that affects over 50,000 acres in Butte County (see attachments).
C) The General Plan and a supplemental EIR must consider down-zoning to more fully comply
with AB 32, the Recovery Plan for Vernal Pool Ecosystems in California and Southern Oregon,
protection of groundwater recharge areas, and the pending Habitat Conservation Plan.
Growth Inducing Impacts
Direct Impacts
Page 6-2 The proposed General Plan 2030 also includes policies that would maintain the rural
character of Butte County and minimize the environmental impacts of anticipated growth.
Placing an additional 150,000 more people in the unincorporated areas of Butte County will not
maintain a healthy rural character nor minimize environmental impacts as expressed above.
There is a greater chance for both urban and rural health found in the Concentrated Growth
Alternative. It would meet all of the Project’s objectives and is the environmentally superior
alternative and would most certainly reduce the severity of most environmental impacts
associated with the project. It is not clear, therefore, why the County failed to fairly evaluate the
alternatives in chapter five.
Page 6-3 As a result, while the proposed General Plan 2030 and ALUCP override would result
in increased local growth, policies included in General Plan 2030 would reduce the potential for
negative impacts associated with direct growth inducement to a less-than-significant level. How
will this be done? As discussed on page two of these comments, the DEIR has failed to describe
and consider the full extent of the growth permitted by the Project. CEQA requires that an EIR
evaluate the project’s potential to affect the environment, even if the project does not ultimately
materialize, but that has not been done in the Project’s DEIR.
Indirect Impacts
The DEIR concludes that, “[t]he proposed General Plan 2030 and ALUCP override would result
in a less-than-significant indirect negative growth inducing impact.” As illustrated for direct
impacts immediately above, the DEIR has failed to describe and consider the full extent of the
growth permitted by the Project. Therefore the Growing Inducing section is out of compliance
with CEQA.
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cont.
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8
Cumulative Impacts
A) CEQA Guidelines Section 15130 requires that an EIR include a discussion of cumulative
impacts “…when the project’s incremental effect is cumulatively considerable, as defined in
[CEQA Guidelines Section 15065(c)].” Cumulatively considerable effects are those
“…incremental effects of an individual project that are significant when viewed in conjunction
with the effects of past projects, the effects of other current projects, and the effects of probable
future projects.” (CEQA Guidelines Section 15065(c)) Unfortunately, not only has the DIER
failed to analyze the Project’s potential impacts and propose avoidance and mitigation measure,
but it has also not adequately incorporated the cumulative effects from past, present, and future
projects in the region to provide a straightforward cumulative impact analysis.
B) The DEIR concludes that the, “majority of impacts associated with General Plan 2030 and the
ALCUP override would be reduced to a less-than-significant level,” but there is
acknowledgement of some significant and unavoidable impacts. They include the conversion of
Prime Farmland, Farmland of Statewide Importance; impacts to special-status species, sensitive
natural communities, federally-protected wetlands, and wildlife and fish movement corridors;
hydrology and water quality impacts at both the project and cumulative level; impacts to airports
that are completely avoidable; a substantial permanent increase in ambient noise levels, traffic
and transportation; and violation of air quality standards conflicting with the State goal of
reducing greenhouse gas emissions in California to 1990 levels by 2020. (DEIR pp. 6-4 to 6-6.)
In light of the fact that the Project is not properly defined, the impacts are not adequately
quantified, enforceable mitigation measures are not imposed, and adequate alternatives are not
considered, these conclusions are unsupported and contravene CEQA.8
C) “Because General Plan 2030 includes residential densities that are not consistent with the
Airport Land Use Compatibility Zones in the ALUCP, adoption of this document requires an
override of the ALCUP.” (p.3-2) The DEIR is inadequate due to its failure to assess impacts
resulting from planning deviations from the State Aeronautics Act Handbook, a requirement of
CEQA Guidelines section 15154(a). The County is subject to all of the SAA and Public
Resources Code section 21670.1. A mentioned above, the impacts to the airports are completely
avoidable.
8 See Berkeley Keep Jets Over the Bay Committee v. Board of Port Commissioners (2001) 91 Cal.App.4th 1344,
1371 (lead agency cannot simply conclude that there are overriding considerations that would justify a significant
and unavoidable effect without fully analyzing the effect.)
16-27
16-28
16-29
5-98
9
Conclusion
AquAlliance looks forward to a supplemental EIR that will contain a more transparent project
description, and full analysis of project and cumulative impacts, and a more impartial assessment
of alternatives. Please keep AquAlliance informed of future opportunities to participate in
meetings, hearings, or comment periods that pertain to the Butte County General Plan 2030 and
its implementation process.
Sincerely,
Barbara Vlamis, Executive Director
AquAlliance
P.O. Box 4024
Chico, CA 95927
16-30
5-99
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Figure III-9b.Vina Plains and Chico core areas within the Northeastern Sacramento Valleyvernal pool region.
Dec. 2005
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TEHAMACOUNTY
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Park
S a c r a m e n t o R i v e r
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0 1 2 30.5 Kilometers
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Core area(s)
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III-47
16-23
5-100
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Doe Mill core area
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Figure III-9c.Doe Mill, Oroville, Richvale, and Palermo core areas within the NortheasternSacramento Valley vernal pool region.
BUTTECOUNTY
1:170,000
Dec. 2005
0 1 2 30.5 Miles
0 1 2 30.5 Kilometers
Northeastern Sacramento Valley vernal pool region
Core area(s)
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III-48
16-23
5-101
Honcut core area
Honcut core area
Honcut
70
1:100,000
Figure III-9d.Honcut core areas within the Northeastern Sacramento Valley vernal pool region.
Dec. 2005
Northeastern Sacramento Valley vernal pool region
Core area(s)
0 0.8 1.6 2.40.4 Miles
0 0.8 1.6 2.40.4 Kilometers
BUTTECOUNTY
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III-49
16-23
5-102
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-103
Letter 16: Barbara Vlamis, Executive Director, AquAlliance. June 7,
2010.
16-1: This comment contains introductory language for the letter. No
response is required.
16-2: This comment cites the description of projected 2030 buildout and
maximum theoretical buildout provided in Chapter 3 of the Draft EIR, and
states that the Draft EIR must have a defined project description. In addition,
the comment states that the Draft EIR must consider the full extent of the
growth permitted by General Plan 2030.
As explained in Section F of Chapter 3 of the Draft EIR (pages 3-39 and 3-40),
the Draft EIR evaluates the projected development that will occur under the
General Plan through the year 2030, or “projected 2030 buildout,” consistent
with CEQA requirements that an EIR evaluate the “reasonably foreseeable”
direct and indirect impacts of a proposed project. While Butte County has
the capacity to accommodate development allowed by General Plan 2030
beyond the year 2030, it is probable that Butte County will have adopted an
update to General Plan 2030 by or before 2030, in keeping with past decisions
in the California courts, which dictate that local jurisdictions should update
General Plans regularly. Therefore, development after 2030 is expected to
take place under a revised General Plan, rather than under General Plan 2030.
Consistent with CEQA statutes, this Draft EIR considers the “reasonably
foreseeable” effects of adopting General Plan 2030, which would result from
development allowed between the adoption of the documents and their hori-
zon year of 2030.
This section also clearly identifies the projected 2030 buildout as follows:
♦ 13,700 new dwelling units
♦ 33,800 new residents
♦ 1.8 million square feet of new retail/office space
♦ 1.1 million square feet of new industrial space
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-104
All of the analyses in the Draft EIR are based on this consistent interpretation
of the General Plan 2030 land use map and policies and the type and amount
of growth that General Plan 2030 would allow.
For the purpose of full disclosure to the public, the Draft EIR also presents
the maximum theoretical buildout of General Plan 2030, which is cited in the
comment. Each analysis section of the Draft EIR provides a separate qualita-
tive assessment of the potential impacts under maximum theoretical buildout,
which addresses the requests contained in this comment. This is not required
by CEQA, but is provided in order to present additional information to the
public.
16-3: This comment cites text from General Plan 2030 indicating that
General Plan 2030 policies represent statements of County regulation, and
asks how policies will become regulation and how policies will comply with
CEQA. As noted in the comment, Butte County considers the policies in
General Plan 2030 to be statements of County regulation. Some of the poli-
cies included in General Plan 2030 should be viewed more as guidance than
regulation, such as those policies that express support for a particular goal.
However, many of the General Plan 2030 policies describe specific require-
ments with which project applicants or the County must comply. The Draft
EIR relies only on enforceable General Plan 2030 policies and other regula-
tions to mitigate project impacts to a less-than-significant level; the Draft EIR
also cites non-enforceable policies, but only to add support to an enforceable
policy. This is consistent with CEQA; Section 15126.4(a)(2) of the CEQA
Guidelines states: “Mitigation measures must be fully enforceable through
permit conditions, agreements, or other legally binding instruments. In the
case of the adoption of a plan, policy, regulation, or other public project,
mitigation measures can be incorporated into the plan, policy, regulation, or
project design.”
16-4: This comment states that the Draft EIR cites many policies that are
not enforceable. As indicated in the response to Comment 16-3, the Draft
EIR relies only on enforceable General Plan 2030 policies and other regula-
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-105
tions to mitigate project impacts to a less-than-significant level, but also cites
non-enforceable policies to add support to an enforceable policy. For exam-
ple, Policies HS-P4.1 and HS-P4.2, which are cited in the comment, support
Policies HS-P4.3 and HS-P5.1, which require that new development in levee
and dam inundation areas consider risks from failure of these levees and dams.
In addition, Policy PUB-P6.5, which is cited in the comment, supports Policy
PUB-P6.1, which directs the County to coordinate the review of development
proposals with other agencies in order to designate sites for new parks and
recreation facilities.
16-5: This comment states that although the Draft EIR cites policies that
use terms such as “shall,” there is no expressed mechanism to make them en-
forceable. As indicated in the response to Comment 16-3, CEQA Guidelines
require that mitigation measures be enforceable through permit conditions,
agreements, or other legally binding instruments. General Plan 2030 policies
that use terms such as “shall” are enforceable through such methods. For ex-
ample, many of these policies provide specific requirements for new devel-
opment that would be enforced through permit conditions on that new de-
velopment. See also the response to Comment 16-3.
16-6: This comment states that the Draft EIR lacks honest disclosure and
discussion of significant environmental impacts from the proposed project,
indicating that the General Plan 2030 policies do not mitigate such impacts.
The comment also cites text in the Draft EIR regarding competing policy
objectives. This comment does not provide specific instances in which the
Draft EIR does not fully disclose potential environmental impacts, making a
response difficult. As indicated in the response to Comments 16-3 and 16-5,
the Draft EIR only relies on policies that are enforceable to mitigate impacts
to a less-than-significant level.
As noted in the comment, the Draft EIR recognizes that competing policy
objectives may require that the County choose one policy objective over an-
other in some instances. This does not mean that the County will ignore
General Plan 2030 policies; this statement merely recognizes that the imple-
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-106
mentation of General Plan 2030 policies will need to be balanced. In addi-
tion, case law supports that not every policy needs to be followed in each
instance. Furthermore, it is not feasible to identify what specific instances
would require such decisions. Consideration of such instances would more
appropriately occur during future project-specific environmental review
processes. As with most planning processes, variances from established regu-
lations may be appropriate in certain situations, but CEQA does not require
that the Draft EIR evaluate the potential for non-compliance with mitigation
measures. Rather, CEQA only requires that such measures are enforceable.
See also the response to Comments 16-3 and 16-5.
16-7: This comment states that the mitigation measures cited in the Draft
EIR must be enforceable, rather than just vague policy statements. The re-
sponse to Comments 16-3, 16-5, and 16-6 responds to this comment.
16-8: This comment states that the Draft EIR does not divulge project im-
pacts and inappropriately relies on policies to mitigate impacts. The response
to Comments 16-3, 16-5, and 16-6 responds to this comment.
16-9: This comment states that the Draft EIR inappropriately relies on
unenforceable policies to mitigate impacts from the proposed project, and
cites the maximum theoretical buildout numbers. The response to Com-
ments 16-2, 16-3, 16-5, and 16-6 responds to this comment.
16-10: This comment cites text from General Plan 2030 describing how
some of the policies are required as a means to mitigate environmental im-
pacts under CEQA, and how that list of policies was not finalized at the time
of publication of the public review draft of General Plan 2030. This list of
policies was not yet finalized at the time of publication of the public review
draft of General Plan 2030 because environmental review was still underway.
However, that list has subsequently been updated, and is now available on the
County’s General Plan website, www.buttegeneralplan.net. All of the poli-
cies that are included on the list are cited in Chapter 4 of the Draft EIR.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-107
16-11: This comment states that the County must present to the public how
policies that use terms such as “shall” will be enforced. The response to
Comments 16-3, 16-5, and 16-6 respond to this comment.
16-12: This comment states that the project is not well-defined because of a
“phasing strategy” and unenforceable policies and goals for the future. The
responses to Comments 16-2, 16-3, 16-5, and 16-6 respond to this comment.
16-13: This comment states that a mitigation monitoring and reporting
program is required for the project. Chapter 6 of this Final EIR provides the
mitigation monitoring and reporting program.
16-14: This comment states that the Draft EIR should have identified sig-
nificant adverse impacts with mitigation measures, and requests that a sup-
plemental EIR be published with a summary table. The Draft EIR does iden-
tify significant adverse impacts and mitigation measures in summary table
form in Table 2-1 on pages 2-7 through 2-14 of the Draft EIR. A supplemen-
tal EIR is not required under CEQA.
16-15: The commentor states that the project’s objectives, which are based
on the General Plan 2030 Guiding Principles, include a weak objective regard-
ing the environment and that the Draft EIR fails to disclose impacts on the
environment and mitigation measures. The statements regarding the Guiding
Principles are not commenting on the adequacy of the Draft EIR. The re-
sponse to Comments 16-6 and 16-14 respond to the statements regarding the
disclosure of impacts and mitigation measures.
16-16: This comment states that the specific plan areas on the General Plan
2030 land use map should be eliminated, and that new growth should occur in
and adjacent to the incorporated communities. This is not a comment on the
adequacy of the Draft EIR, and no response is necessary.
16-17: This comment states that Figure 4.4-1 from the Draft EIR does not
include important wildlife areas that have been preserved by fee title through
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-108
conservation easements or mitigation. The County recognizes that conserva-
tion easements exist between private landowners and other entities. These
transactions are generally handled in a private manner in a way that does not
require governmental approval or record keeping. It is difficult, therefore, to
determine which properties are subject to conservation easements on individ-
ual private landholdings. Figure 4.4-1’s primary use as referenced in the Draft
EIR pertains to a discussion and representation of the ten biological commu-
nities present in Butte County. The inclusion of important wildlife areas
shown is a secondary point of reference, and not the main purpose of the fig-
ure. The inclusion of the larger wildlife areas shown is appropriate at the
countywide scale represented by the figure. Smaller easements or landhold-
ings would not only be inappropriate at the scale provided, but are not di-
rectly related to the purpose of Figure 4.4-1.
In addition, there are a number of individual parcels designated Resource
Conservation on the General Plan 2030 land use map that reflect holdings
that are for conservation purposes.
16-18: This comment cites text describing a significant and unavoidable cu-
mulative biological resources impact, and states that the text conflicts with
text elsewhere indicating that General Plan 2030 would not have a significant
impact on biological resources. These statements are not contradictory. Sec-
tion D.1 of Chapter 4.4 of the Draft EIR evaluates biological resources im-
pacts from the proposed project, and finds them to be less than significant due
to the extensive goals, policies and actions in General Plan 2030 that mitigate
impacts to undeveloped lands that support sensitive biological resources and
that minimize the effects of development on biological resources in general.
Section D.2 of Chapter 4.4 of the Draft EIR evaluates the cumulative impacts
from General Plan 2030, and finds them to be significant because regional
development could impact biological resources. Specifically, as indicated on
page 4.4-86 of the Draft EIR, the cumulative loss of habitat and sensitive natu-
ral communities in Butte County, while deemed less than significant when
considered in isolation, could potentially contribute to a general decline for
the region, and might result in the loss or displacement of wildlife that would
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-109
have to compete for suitable habitats with existing adjacent populations.
Since this potential change would occur as an intrinsic part of the land use
changes allowed under General Plan 2030 to accommodate the expected con-
tinued growth of population and economic activity in Butte County over the
next 20 years, and since development outside Butte County is beyond the
County’s ability to regulate or control, the cumulative change may rise to a
level of significance and is therefore being treated as a significant and un-
avoidable impact.
In the comment, the cited text from Chapter 6 of the Draft EIR is a summary
of Section D.2 from Chapter 4.4.
16-19: This comment states that the Draft EIR is missing information about
groundwater plumes, the locations and extent of groundwater pollution, and
hazards to human and environmental health. Section B.2 of Chapter 4.8 of
the Draft EIR describes existing conditions related to water quality. This
section includes a description of the two large groundwater plumes, and iden-
tifies groundwater contaminants of concern in Butte County. This informa-
tion is included in order to provide a description of the existing water quality
setting in Butte County so that potential impacts of the proposed project on
water quality can be understood.
Section 15125(a) of the CEQA Guidelines states: “An EIR must include a de-
scription of the physical environmental conditions in the vicinity of the pro-
ject… The description of the environmental setting shall be no longer than is
necessary to an understanding of the significant effects of the proposed pro-
ject and its alternatives.” The level of detail requested in the comment is
more than what is necessary for readers to understand the potential water
quality impacts from the proposed project. However, the text in the Draft
EIR regarding water quality has been revised in Chapter 3 for clarity.
16-20: This comment states that the Draft EIR is lacking a water supply
analysis. The response to Comments 12-2 and 12-4 describes the water supply
analyses in the Draft EIR.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-110
16-21: This comment asks for the original source of the following statement
from the Draft EIR (page 4.8-15): “Of the 3.77 MAF of annual rainfall, less
than half is used. Therefore, more than 2 MAF are currently available for
recharge or discharge via surface and subsurface outflow, although this
amount will not always be available.” This text was cited from the 2005 Butte
County General Plan Technical Update Background Report, as noted in the
comment. The original source for the statement in the General Plan Techni-
cal Update Background Report is unknown. Therefore, this statement has
been deleted, as reflected in Chapter 3 of this Final EIR. The deletion of this
statement does not affect the analysis or conclusions of the Draft EIR.
16-22: This comment states that General Plan 2030 is not a true planning
document because it includes a set of unenforceable preferences and policies.
This is not a comment on the adequacy of the Draft EIR, and no response is
required. See response 16-3 regarding the enforceability of policies in General
Plan 2030.
16-23: This comment states that the Draft EIR Land Use chapter should
describe and evaluate potential conflicts with the Recovery Plan for Vernal
Pool Ecosystems in California and Southern Oregon (Recovery Plan) and the
Vernal Pool Critical Habitat designation of lands in Butte County. Because
the Recovery Plan and Critical Habitat designation relate to biological re-
sources, this discussion more appropriately belongs in Chapter 4.4, Biological
Resources, of the Draft EIR. The Draft EIR does not discuss the Recovery
Plan, which covers a large geographic area, but rather discusses the more lo-
cally specific Butte Regional Habitat Conservation Plan (HCP) and Natural
Community Conservation Plan (NCCP), which must be in agreement with
requirements of the Recovery Plan. The connection between the Recovery
Plan and the Butte Regional HCP/NCCP has been added to Chapter 4.4, as
shown in Chapter 3 of this Final EIR.
Vernal Pool Critical Habitat is discussed on pages 4.4-52, 4.4-63, and 4.4-72 in
Chapter 4.4 of the Draft EIR, and is shown on Figure 4.4-3. The critical habi-
tat areas described and shown in the Draft EIR include portions of the areas
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-111
that the commentor shows on the maps provided as attachments to Comment
16-23. The “core areas” on the attachments are taken from the 2005 Recovery
Plan; however, the entirety of the core areas was not designated as the final
critical habitat in 2006. The Draft EIR analysis focuses on the final critical
habitat areas because these are the lands that are federally regulated for the
recovery of the vernal pool species.
16-24: This comment states that the General Plan and a supplemental EIR
must consider down-zoning in order to comply with Assembly Bill (AB) 32,
the Recovery Plan, protection of groundwater recharge areas, and the Butte
Regional HCP/NCCP. This is not a comment on the adequacy of the analy-
sis in the Draft EIR, and no response is required. However, it should be
noted that the Draft EIR did not find significant impacts with respect to the
Recovery Plan, groundwater recharge areas, and the Butte Regional
HCP/NCCP, so mitigation through down-zoning or other means is not re-
quired. As indicated on page 4.15-66 of the Draft EIR, as part of the General
Plan 2030 process, the County considered a wide range of policies and actions
to reduce GHG emissions and comply with AB 32, and all feasible measures
are included. Since down-zoning could have the effect of simply spreading
the same amount of development over a larger land area at a lower density,
resulting in increased vehicle miles traveled as Butte County residents drive
farther for jobs and services, it is not necessarily the case that down-zoning
alone would help the County reduce its GHG emissions and achieve compli-
ance with AB 32.
16-25: This comment disagrees with the Draft EIR’s finding that General
Plan 2030 policies would maintain the rural character of Butte County and
minimize environmental impacts of anticipated growth, citing the maximum
theoretical buildout population. The comment also states that the Concen-
trated Growth Alternative is environmentally superior, meets the project’s
objectives, and was not fairly evaluated in the Draft EIR.
As indicated in the response to Comment 16-2, the Draft EIR evaluated po-
tential impacts from projected 2030 buildout of General Plan 2030, which
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-112
includes 33,800 new residents. As indicated on pages 6-2 and 6-3 of the Draft
EIR, the following General Plan 2030 policies would maintain the rural char-
acter of Butte County:
♦ Policy LU-P4.1 requires that the integrity and stability of existing resi-
dential neighborhoods be promoted and preserved.
♦ Policy LU-P2.3 supports planning efforts in unincorporated communities
by providing knowledge, time, and materials to community efforts.
♦ Policy LU-P2.4 engages unincorporated communities in community
planning processes to set a community vision, develop Area Plans and
potentially urban growth boundaries, community boundaries, and SOIs.
The Draft EIR identifies the Concentrated Growth Alternative as the envi-
ronmentally superior alternative on page 5-35, as noted by the commentor.
The analysis of the Concentrated Growth Alternative is consistent with Sec-
tion 15126.6(d) of the CEQA Guidelines by providing “sufficient informa-
tion… to allow meaningful evaluation, analysis, and comparison with the
proposed project;” including matrices that compare the alternatives and their
impacts to the proposed project; and discussing potential impacts of the alter-
natives in less detail than those of the proposed project.
16-26: This comment states that the Draft EIR does not describe the project
or consider the full extent of the growth allowed by General Plan 2030. The
response to Comment 16-2 responds to this comment.
16-27: This comment states that the Draft EIR does not adequately evaluate
cumulative impacts from past, present, and future projects in the region. This
comment does not indicate how the Draft EIR’s cumulative analysis is inade-
quate. The cumulative analysis in the Draft EIR is consistent with Section
15130(b) of the CEQA Guidelines. As described in Section D of Chapter 6 of
the Draft EIR (pages 6-8 and 6-9), the cumulative analysis considers potential
effects from a combination of the project in the unincorporated county with
development in other portions of the region, including the incorporated mu-
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-113
nicipalities and the surrounding counties. The cumulative analysis considers
the anticipated levels of growth and development within those jurisdictions.
16-28: This comment states that the Draft EIR does not adequately define
the project, adequately quantify the impacts, provide enforceable mitigation
measures, or consider adequate alternatives. The response to Comments 16-2,
16-3, 16-5, 16-6, and 16-14 respond to the portions of this comment that per-
tain to the project description, impacts, and mitigation measures. The com-
ment does not indicate how the alternatives are not adequate. The alterna-
tives analysis in the Draft EIR is consistent with Section 15126.6(a) of the
CEQA Guidelines by providing “a range of reasonable alternatives… which
would feasibly attain most of the basic objectives of the project but would
avoid or substantially lessen any of the significant effects of the project.” In
particular, the Concentrated Growth Alternative would have less environ-
mental impacts than the proposed project, as shown in Table 5-2 on page 5-11
of the Draft EIR.
16-29: See response 3-1.
16-30: This comment provides concluding remarks, and asks that AquAlli-
ance be kept informed of future opportunities to provide input. This is not a
comment on the adequacy of the Draft EIR, and no response is required.
-----Original Message-----
From: Burr, Carol (Retired) [mailto:CBurr@csuchico.edu]
Sent: Wednesday, April 21, 2010 5:26 PM
To: DSGeneralPlan Subject: Weaknesses in the DEIR and EIR
According to the state Attorney General there are issues around water that
the DEIR and EIR do not adequately address. Quoting the AG, these
inadequacies include the following:
·The document ³fails to apprise the decision makers and the public of the
full range and intensity of the adverse effects on the environment that may
reasonably be expected if the Plan is adopted and carried out.²
·³. . . the DEIR fails to discuss the impacts of climate change, and reduced
snowpack, on the City¹s water resources . . . .²
·³The DEIR . . . needs to address the likelihood of reduced snowmelt affecting the availability of surface water, and should also discuss
potential impacts of greater reliance on groundwater due to reduced surface
water supplies . . . .²
·³Before the impacts of a project can be assessed and mitigation measures
considered, an EIR must describe the existing environment. It is only
against this baseline that any significant environmental effects can be
determined. . . .³
·³An EIR must inform decision-makers and the public of the intended sources
of water for [a] project, and the environmental impacts of exploiting those
sources. Such analysis cannot be deferred . . . .²
·³An EIR evaluating a planned land use project must assume that all phases
of the project will eventually be built and will need water, and must
analyze, to the extent reasonably possible, the impacts of providing water
to the entire proposed project.²
·³An EIR that neglects to explain the likely sources of water and analyze
their impacts, but leaves long-term water supply considerations to later
stages of the project, does not serve the purpose of sounding an
Oenvironmental alarm bell¹ before the project has taken on overwhelming
COMMENT LETTER #17
17-1
17-2
17-3
17-4
5-114
Obureaucratic and financial momentum.²
·³Even if [the development] can secure this water supply, which is
uncertain, the EIR fails to discuss any impacts from using the groundwater.
There are indications that the well field is hydraulically connected to [a]
[r]iver. If the two are connected, pumping groundwater will draw down the river . . . . The California Supreme Court has specifically forbidden EIR¹s
from deferring this type of analysis.²
Until these concerns are addressed, the draft General Plan is incomplete and
may lead to further reduction in water supplies for the entire state.
We have worked hard to have a General Plan that protects Butte County and
offers it fiscal and environmental sustainability. Let us build into the
document answers to the problems raised in the Attorney General's review.
Thank you.
Carol Burr
17-5
17-4
cont.
5-115
Author: Tony St. Amant
tsainta@hotmail.com
April 16, 2010
Extracts of
Attorney General Comment Letters
Filed under the California Environmental Quality Act
(Available at http:/www.ag.ca.gov/globalwarming/ceqa/comments.php)
This paper extracts comments from published Attorney General (AG) CEQA reviews of DEIRs and EIRs. The
purpose of this effort is to gain some conceptual insight into the Attorney General’s view of DEIR/EIR
insufficiency as it might relate to the Butte County General Plan 2030 DEIR, especially with regard to the
author’s primary area of interest, water resources.
My hope is that local DEIR comments with the same perspective as the AG has expressed on other CEQA
reviews will have a greater impact on the local process and a greater chance of AG support in the long run.
AG case law and statute citations have been omitted for readability. They are available at the online
location, above, on the pages indicated, below.
_________________________________
One Valley One Vision Draft Area Plan and Draft Environmental Impact Report, 12/1/09
Our review to date indicates that the DEIR fails as an informational document, in that it fails to
apprise the decision makers and the public of the full range and intensity of the adverse effects on the
environment that may reasonably be expected if the Plan is adopted and carried out. (p.2) (Emphasis
added)
City of Sacramento General Plan 2030 Draft Environmental Impact Report SCH # 2007072024, 8/29/08
Impact of Climate Change on Water Supply (p.3)
The DEIR discusses generally the impact of climate change on water resources. The DEIR fails,
however, to address several important issues. First, the DEIR discusses the impacts of reduced
snowpack that are expected to occur between 2070 and 2099, but fails to address the potential
impacts during the years covered by the General Plan, from 2008 until 2030. Second, the DEIR fails to
discuss the impacts of climate change, and reduced snowpack, on the City’s water resources
specifically. This is significant because the City primarily depends on the Sacramento and American
Rivers for its water, and flows in the American River depend on operations at Folsom Reservoir.
(Emphasis added)
With a reduced snowpack, it becomes increasingly difficult to refill reservoirs in the late spring and
early summer, reducing reservoir yields. The DEIR thus needs to address the likelihood of reduced
snowmelt affecting the availability of surface water, and should also discuss potential impacts of
greater reliance on groundwater due to reduced surface water supplies. In California’s changing
climate, the DEIR cannot assume that the region’s hydrology will not change. (Emphasis added)
17-6
17-7
17-8
5-116
Author: Tony St. Amant
tsainta@hotmail.com
April 16, 2010
Baseline Used to Evaluate the Impacts of the Plan (p. 4)
In both the Climate Change and Water Quality sections, the DEIR uses the hypothetical full build‐out
under the 1988 General Plan as the baseline for calculating CO2 emissions, water demand, and
accompanying environmental impacts. Both CEQA and case law are clear, however, that a planning
document must describe the existing physical conditions in the environment, not only what could
have been built under a previous plan. “Before the impacts of a project can be assessed and
mitigation measures considered, an EIR must describe the existing environment. It is only against this
baseline that any significant environmental effects can be determined.” Thus, the City should
recalculate all projections and evaluate impacts using the correct baseline. (Emphasis added)
Solano County General Plan Draft Environmental Impact Report SCH# 2007122069, 6/16/08
The DEIR fails to adequately analyze the impacts of the project to water supplies. (p.10)
An EIR must inform decision‐makers and the public of the intended sources of water for the project,
and the environmental impacts of exploiting those sources. Such analysis cannot be deferred. “An
EIR evaluating a planned land use project must assume that all phases of the project will eventually
be built and will need water, and must analyze, to the extent reasonably possible, the impacts of
providing water to the entire proposed project.” (Emphasis added)
* * * * *
The DEIR attempts to mitigate the impacts by requiring verification of sufficient water supply before
new development subdivisions are approved, and by monitoring groundwater. These mitigation
efforts are insufficient. “An EIR that neglects to explain the likely sources of water and analyze their
impacts, but leaves long‐term water supply considerations to later stages of the project, does not
serve the purpose of sounding an ‘environmental alarm bell’ before the project has taken on
overwhelming ‘bureaucratic and financial momentum.’ Thus, the water supply analysis fails to
comport with CEQA. (Emphasis added)
Yuba Highlands [development] Environmental Impact Report, 5/11/07
The EIR fails to adequately analyze and mitigate impacts from supplying water to the project (p.6)
The EIR maintains that the project is entitled to groundwater from the Yuba Goldfields well field, near
the Yuba River. Even if Yuba Highlands can secure this water supply, which is uncertain, the EIR fails to
discuss any impacts from using the groundwater. There are indications that the well field is
hydraulically connected to the Yuba River. If the two are connected, pumping groundwater will draw
down the river. The EIR acknowledges that it is unknown whether using groundwater will affect the
Yuba River but assures the Board and the public that those impacts will be studied later, in an EIR on
the well field. The California Supreme Court has specifically forbidden EIR’s from deferring this type of
analysis. It recently held that an EIR must address the reasonably foreseeable impacts of supplying
water to a project and cannot put off the analysis to a future EIR, which is exactly what the EIR
proposes to do here. (Emphasis added)
17-9
17-10
17-11
5-117
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-118
Letter 17: Carol Burr, CBurr@csuchico.edu. April 21, 2010.
17-1: This comment states that the Draft EIR does not disclose the full
range and intensity of the environmental impacts from General Plan 2030.
The response to Comment 16-6 responds to this comment.
17-2: This comment states that the Draft EIR does not discuss the impacts
of climate change and reduced snowpack on water resources. Section D.2.b
of Chapter 4.15 of the Draft EIR (pages 4.15-57 to 4.15-65) discusses the po-
tential climate change impacts resulting from General Plan 2030, including
impacts on water resources from reduced snow pack (see pages 4.15-60 and
4.15-61). In addition, as indicated in the response to Comment 7-13, potential
related impacts to groundwater are also described, as shown in Chapter 3 of
this Final EIR. While reduced snowpack from climate change may reduce
surface water supplies and increase groundwater demands, General Plan 2030
Action COS-A1.1 directs the County to prepare a Climate Action Plan
within one year of adoption of General Plan 2030, and requires that the Cli-
mate Action Plan include a Climate Change Preparedness Plan that will pre-
pare for the impacts of climate change on the county’s economic and natural
ecosystems and promote a climate-resilient community. In addition, General
Plan 2030 includes numerous policies that promote a sustainable water sup-
ply.
17-3: This comment states that the Draft EIR must describe the existing
environment. The context for this comment is also provided in Comment
17-9, which states that the baseline environmental conditions in the Draft EIR
should be the existing physical conditions in the environment, rather than
what could have been built under a previous plan. Each section of Chapter 4
in the Draft EIR includes a subsection describing the existing physical condi-
tions related to the environmental topic. The impact analyses consider the
conditions under the proposed project in relation to this baseline, and do not
compare the proposed project to the existing General Plan. The alternatives
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-119
analysis appropriately includes a comparison of General Plan 2030 to the ex-
isting General Plan, or the “No Project” Alternative.
17-4: This comment states that the Draft EIR must disclose the sources of
water for the project and the environmental impacts of exploiting those
sources. The response to Comments 12-2, 12-3, and 19-1 respond to this
comment. In addition, as indicated in the response to Comment 17-10, the
majority of this comment is an extract of a comment from the California At-
torney General’s Office on the Solano County General Plan Draft EIR. In
the Solano County Draft EIR, a significant water supply impact was found,
and mitigation measures were proposed. The Attorney General commented
that the proposed mitigation measures failed to mitigate the impact. The
Butte County General Plan 2030 Draft EIR did not find a significant water
supply impact, as noted in the response to Comment 12-2. Therefore, the
comment from the Attorney General’s Office on the Solano County General
Plan Draft EIR does not directly relate to the Butte County General Plan
2030 Draft EIR.
17-5: This comment states that the General Plan is incomplete and may
lead to a reduction in water supplies for the State. The response to Comment
12-2 addresses the water supply analysis that was conducted in the Draft EIR.
Furthermore, this is not a comment on the adequacy of the Draft EIR, so no
further response is required.
17-6: This comment explains that the comments in this letter are extracts
from the State Attorney General comment letters on other EIRs. It should
be noted that the Attorney General did not comment on the Butte County
General Plan 2030 Draft EIR and that comments on other EIRs for other
jurisdictions are not comments on the General Plan 2030 EIR. Since this is
not a comment on the adequacy of the Draft EIR, no response is needed.
17-7: This comment is an extract of an Attorney General comment letter
on the One Valley Vision Draft Area Plan and Draft EIR regarding full dis-
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-120
closure of impacts. The response to Comment 17-1 responds to this com-
ment.
17-8: This comment is an extract of an Attorney General comment letter
on the City of Sacramento General Plan 2030 Draft EIR regarding the im-
pacts of climate change on water supply. The response to Comment 17-2
responds to this comment.
17-9: This comment is an extract of an Attorney General comment letter
on the City of Sacramento General Plan 2030 Draft EIR regarding baseline
conditions. The response to Comment 17-3 responds to this comment.
17-10: This comment is an extract of an Attorney General comment letter
on the Solano County General Plan Draft EIR regarding water supply analy-
ses. The response to Comment 17-4 responds to this comment.
17-11: This comment is an extract of an Attorney General comment letter
on the Yuba Highlands EIR regarding water supply analyses. The response
to Comment 17-4 responds to this comment.
COMMENT LETTER #18
18-1
5-121
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-122
Letter 18: Tony St. Amant. 27 Garden Park Drive, Chico, CA 95973.
May 11, 2010.
18-1: See response 3-1.
COMMENT LETTER #19
19-2
19-1
5-123
COMMENT LETTER #19
19-3
19-4
19-2
cont.
5-124
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-125
Letter 19: Tony St. Amant, 27 Garden Park Drive, Chico, CA 95973.
May 11, 2010.
19-1: This comment states that the Draft EIR does not adequately analyze
the project’s impacts on water supplies or the effects of increased water con-
sumption on groundwater levels, agricultural activities, stream flows, native
vegetation, and land subsidence. This comment also cites the maximum theo-
retical buildout of General Plan 2030. The response to Comments 12-2, 12-3,
and 12-4 describes the surface and groundwater supply and quality analyses
included in the Draft EIR. These analyses consider potential impacts that
could affect all water users in Butte County, including agricultural users. Fur-
thermore, Section A.4.a.ii of Chapter 4.14 of the Draft EIR (pages 4.14-21
through 4.14-24) evaluates potential impacts resulting from the construction
or expansion of water facilities, including surface water hydrology, wetlands
and riparian habitat, agriculture, and socioeconomic resources. In addition,
Section D.1.f of Chapter 4.6 of the Draft EIR (pages 4.6-23 and 4.6-24) pro-
vides an analysis of potential hazards from land subsidence.
Also, the responses to Comments 12-6 and 16-2 address General Plan 2030
buildout.
19-2: This comment states that the Draft EIR does not fully disclose the
intended sources of water for General Plan 2030 or the environmental im-
pacts from exploiting those sources. The responses to Comments 12-2, 12-3,
and 19-1 respond to this comment.
19-3: This comment states that the County’s Groundwater Management
Ordinance is not enforceable, and that General Plan 2030 Policy W-P3.1,
which is related to that Ordinance, cannot be implemented. This is not a
comment on the adequacy of the Draft EIR, and no response is required.
19-4: This comment directs the County to perform an analysis to deter-
mine whether development allowed by General Plan 2030 would deplete
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-126
groundwater supplies or interfere with groundwater recharge. The responses
to Comments 12-2 and 14-6 respond to this comment.
COMMENT LETTER #20
20-1
20-2
20-3
20-4
5-127
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-128
Letter 20: Tony St. Amant, 27 Garden Park Drive, Chico, CA 95973.
June 3, 2010.
20-1: This comment references the Butte County Water Commission’s
comment on the Draft EIR that is documented in Comment 7-2. The re-
sponse to Comment 7-2 responds to this comment.
20-2: This comment references the Butte County Water Commission’s
comment on the Draft EIR that is documented in Comment 7-6. The re-
sponse to Comment 7-6 responds to this comment.
20-3: This comment references the Butte County Water Commission’s
comment on the Draft EIR that is documented in Comment 7-13. The re-
sponse to Comment 7-13 responds to this comment.
20-4: This comment indicates that the Draft EIR must include an analysis
to determine whether development allowed by General Plan 2030 would de-
plete groundwater supplies or interfere with groundwater recharge. The re-
sponses to Comments 12-2 and 14-6 respond to this comment.
Butte County General Plan 2030
Draft Program Environmental Impact Report
Summary of Public Comment Received
4/22/10 1:00 pm
No written comments were submitted at the meeting.
Oral Public Comment:
1) Robin Huffman – Butte Environmental Council
-Suggested a second follow-up meeting during the review period with the
Planning Commission.
–Inquired on whether a financial assessment for the study areas and the
preferred land use alternatives would be prepared.
–Inquired as to whether General Plan 2030 will contain goals, polices, or
actions pertaining to setbacks on ridgelines.
2) Gene Willet –Bangor Resident
-Expressed concern about impact of General Plan 2030 on the Bangor
community, specifically truck traffic, noise, road damage from trucks, response
times for emergency vehicles, and notification of discretionary land use
applications for businesses negatively affecting the local area.
–Inquired as to whether General Plan 2030 would redirect waterways, drying
up local water supplies.
COMMENT LETTER #21
21-2
21-3
21-4
21-5
21-1
5-129
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-130
Letter 21: Oral Comments Made during the Public Hearing on Thurs-
day, April 22, 2010.
21-1: This comment requests an additional Planning Commission meeting
on the Draft EIR during the public review period. Butte County believes
that the General Plan 2030 process has included extensive public meetings and
opportunities for public involvement, including an extended review period
for the Draft EIR. Therefore, no additional meetings are necessary.
21-2: This comment inquires about a financial assessment of study areas
and the preferred land use alternative. Such a financial assessment would be
outside of the scope of CEQA. This comment is not a comment on the Draft
EIR. However, it should be noted that the March 2008 Alternatives Evalua-
tion Report did include a comparative evaluation of the market viability, fis-
cal impacts, and jobs/housing balance of each alternative in each study area.
21-3: This comment inquires whether General Plan 2030 will include
goals, policies, or actions regarding development along ridgelines. It is not a
comment on the Draft EIR. However, it should be noted that General Plan
2030 Conservation and Open Space Goal COS-17 and its supporting policies
work to maintain and enhance the quality of Butte County’s scenic and visual
resources. This goal is supported by Policy COS-P17.1, which limits ridge-
line development near scenic resources via the adoption of specific develop-
ment guidelines in order to minimize visual impacts. In addition, Conserva-
tion and Open Space Element Goal COS-18 would protect and enhance sce-
nic areas adjacent to and visible from highways for enjoyment by residents
and visitors. This goal is supported by Policy COS-P18.1 and Action COS-
A18.1, which instruct the County to review its scenic highways program and
consider designating new scenic corridors based on a consideration of factors
such as an area’s scenic characteristics, including vista points, geologic re-
sources, native plant and animal species, waterways, historic resources, agri-
cultural, timber, and recreation uses.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-131
21-4: This comment expresses concerns about impacts from traffic, noise,
emergency vehicle response times, and new businesses in Bangor. The Draft
EIR analyzes each of these potential impacts Countywide at a programmatic
level. Traffic impacts are analyzed in Chapter 4.13, noise impacts are ana-
lyzed in Chapter 4.10, and emergency vehicle access is analyzed in Chapter
4.7. The commentor does not specify which types of impacts from new busi-
nesses are of concern, but the Draft EIR covers a wide range of potential im-
pacts from all types of new development.
21-5: This comment expresses concern about impacts from redirecting
waterways. General Plan 2030 does not include any policies or actions to
redirect waterways, and does include a number of policies and actions to pro-
tect and enhance the County’s water resources. The potential impacts of
General Plan 2030 policies and actions on water resources, including water-
ways, are analyzed in Chapter 4.8, Hydrology, of the Draft EIR.
BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
COMMENTS AND RESPONSES
5-132
6 MITIGATION MONITORING AND REPORTING PROGRAM
6-1
This chapter provides a Mitigation Monitoring and Reporting Program
(MMRP) for the Butte County General Plan 2030. The purpose of the
MMRP is to ensure the implementation of mitigation measures identified as
part of the environmental review for the project. The MMRP includes the
following information:
♦ A list of mitigation measures;
♦ The party responsible for implementing the mitigation measures;
♦ The timing for implementation of the mitigation measure;
♦ The agency responsible for monitoring the implementation; and
♦ The monitoring action and frequency.
Butte County must adopt this MMRP, or an equally effective program, if it
approves the Butte County General Plan 2030 with the mitigation measures
that were adopted or made conditions of project approval.
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BUTTE COUNTY GENERAL PLAN 2030
FINAL EIR
MITIGATION MONITORING AND REPORTING PROGRAM
6-4