Critique of the Valley's Edge Environmental Impact Statement

Press Conference, January 6, 2023

Press Release 2023

Stop Valley's Edge--Editor for a Day,   July 6, 2022

Fundraiser Poster, 2022

SGA's Critique of the Valley's Edge Environmental Impact Statement

 

The Draft EIR said that even though greenhouse gas emissions and aesthetics could not be mitigated, there were "Overriding Considerations" that made it possible for Valley's Edge to go forward. The following is Smart Growth Advocates' response to that position. 

 

The Final Environmental Impact Report for Valley’s Edge found two environmental impacts that cannot be fully mitigated--greenhouse gas emissions and aesthetics. On that basis alone, the Valley’s Edge Specific Plan (VESP) should not go forward.

 

Greenhouse gas emissions and the continued production of CO2 in our atmosphere create an existential threat. Recognizing this threat, Chico’s Climate Action Plan set a goal for reaching net zero emissions by 2045. Chico’s City Council passed the CAP unanimously. The City’s efficiency target is 2.76 MT CO2e per capita per year. However, the GHG emissions for Valley’s Edge are estimated to be 3.13 per capita. The Valley’s Edge Specific Plan is thus inconsistent with the City’s Climate Action Plan.

 

A second impact that cannot be mitigated is aesthetics. With 1446 acres chewed up by 2777 housing units, Chico residents will lose their precious view of our surrounding rangeland and into the foothills to the east of Chico. We are already losing views as housing encroaches on our wild spaces. For our health, wellness, and happiness we need to maintain the natural beauty.

 

In order to approve Valley’s Edge with two environmental impacts that cannot be fully mitigated, the City was required to provide a Statement of Overriding Considerations (SOC). It The SOC provides six reasons the project should move forward; opponents of Valley’s Edge find all six reasons faulty. 

 

1. The City’s staff report claims that Valley’s Edge provides a variety of housing needed by the City. In fact, the “variety” of housing is virtually all middle and low density and virtually all for middle to upper class residents, with only nine acres of multifamily dwellings. Chico needs affordable housing for all income levels. While the developer has declared (at the Planning Commission meeting and at the 1/3/23 City Council meeting) that he will include workforce housing and small cottages, the analysis included in the Housing report in this packet suggests something quite different, based on Chico’s Housing Elements and current market conditions. The houses in Valley’s Edge will be unaffordable for many moderate- and low-income people.

 

2. The staff report touts the 36-acre CARD park as a reason for approving the project. This park represents a small percentage of total acreage of this project. Moreover, the staff report claims that the VESP “also includes neighborhood parks and other usable open space for the Project’s residents,” failing to add that the open space and parks are exclusively for the Homeowners Association (HOA) residents of Valley’s Edge. While the developer has said he wants the HOA to allow use for others who would pay an annual fee, this simply underlines the exclusivity of Valley’s Edge. The loss of this open space to Butte County residents puts this consideration in the loss category, not the gain category.

 

3. The staff report claims that the VESP will help the economy by creating jobs. There are a issues with this claim. While acreage is set aside for a commercial village, there are no specifics about what might go there. At the 1/3/23 City Council Meeting, the developer added an image to his report, showing a small local grocery store, another aspirational element appears to be recently added to placate critics who pointed out that residents would have to travel for goods and services. Moreover, while there is no way to know what might inhabit that space, it is more than likely that the various employees will not be able to afford homes in Valley’s Edge. 

 

4. The staff report claims that VESP will manage the Wildland Urban Interface (WUI), using Land Planning, Fire Fighting Capability, Fire Resistant Materials and Building Standards, Fuel Reduction Management, and Emergency Preparedness. The VESP claims that the HOA of VE will be responsible for maintaining standards and fuel reduction. Those who have lived through recent fires in our region know that these are inadequate measures because of the intensity of the fires, their speed, and their heat. Chico’s official Community Wildfire Protection Plan (CWPP) identifies virtually all parcels on the eastern edge of the existing City limits as areas with the highest risk for wildfire. This area has burned three times in the past 19 years. 

 

5. The staff report claims that the VESP will generate revenue through property taxes and retail sales tax. This statement is true, however, the huge pressure on Chico’s infrastructure through the addition of 6000 new residents and 1000 workers will easily eat up any gains in revenue. According to Environmental Defense: “Our governments subsidize sprawl by building infrastructure that supports low density development such as highways. But studies show that low density development doesn’t pay its way. Municipal councils often think that development charges cover the cost of growth, but they only cover the capital costs. Ongoing maintenance, operations and replacement are left out of the equation."

 

6. The staff report states that the VESP will help implement the City’s 2030 General Plan. While the General Plan established Special Planning Areas for growth in the future, Chico is not growing enough to require development in this SPA. Chico does not require housing sprawl to meet its housing needs. The General Plan also calls for density and infill, for walkable, bikeable neighborhoods. What if Chico and its developers look to up-zone, rezone, and look to all of the places that require urban renewal for any new housing plans?

 

Finally, a couple more important points about the Statement of Overriding Considerations: 

 

While many of the claims about the value to Chico of the VESP are on the surface positive, none of them outweighs the harm to the environment done by increasing greenhouse gas emissions with an enormous sprawl. Our first directive is to stop climate change, and the most important thing we can do is to decrease GHGs. Climate Change is an existential threat. A new park and creating new jobs are good things. But not more important than saving the environment.

 

Many of the claims made in the VESP are aspirational--things that we hope will happen. Too much in the SOC is not substantiated or supported by facts. The primary example of this is the claim that VE will provide a range of housing. VESP does not meet Chico’s housing needs at all income levels with an equitable balance for all of Chico’s citizens.

 

Greenhouse Gas Emissions, Pollution, Traffic, and Congestion: 

Valley’s Edge

Press Conference: Smart Growth Advocates, January 6, 2023

 

Climate change is projected to cause increasingly hazardous conditions for life on earth, including increased heat waves, wildfires, drought, extreme storms, flooding, and sea level rise. Secondary impacts of climate change include adverse changes to biological resources and public health. 

City of Chico, Climate Action Plan Update

 

The Valley’s Edge Specific Plan calls for the construction of 2777 new residences in this 1446-acre development on the rangelands and foothills east of Bruce Road in Chico. This enormous sprawl project will directly conflict with the City of Chico’s Climate Action Plan, approved by the City Council in October, 2021. 

Greenhouse Gas Emissions and Air Pollution

The Chico CAP calls for the reduction of greenhouse gas (GHG) emissions to achieve carbon neutrality by 2045.  Transportation is the biggest producer of greenhouse gases, over 50 percent.  The City’s 2030 efficiency target is 2.76 MT CO2e per capita per year. Valley’s Edge the GHG emissions are estimated to be around 3.13 MG CO2e per capita. Thus, Valley’s Edge would result in GHG emissions that exceed the City’s Efficiency target. Both the  construction of this massive housing development and the dependence on vehicles for this urban sprawl neighborhood will have a significant impact on climate change.

 

Air pollution is a public health crisis in Chico, California, where air quality levels rank among the worst in the United States. The city’s air quality status comes despite its relatively small population and rural location in Northern California’s Butte County. A combination of emission sources as well as meteorological, topographic, and geographic conditions shape the city’s poor air quality status. . . .

IQair.com

 

One of the major causes of bad air quality in Chico has resulted from wildfires. However, Greenhouse Gas Emissions are a major contributing factor that will be exacerbated by an urban sprawl project that requires people to drive for jobs, school, shopping, and appointments. In addition, Valley’s Edge is projecting a 20+ year buildout, with groundbreaking occurring in a year or so. This means that dust--another contributer to bad air quality--will be ongoing for many years. 

 

Increased Traffic and Congestion

 

Traffic congestion isn’t just inconvenient, it creates some real problems.

Those problems include: More Accidents. . . . Increased travel time. .. . Worse air quality. . . .  Trucking impacts means high cost for goods. 

Metropolitan Transportation Commission

 

_{“Prior to the Camp Fire, there were already segments of roadways that were inadequate to handle the traffic volumes and the current impacts have now overwhelmed those locations.”} 

_{2019 Chico Staff report, Chico Enterprise Record, January 16, 2019}

 

Adding a town the size of Gridley on the edge of Chico will increase urbanization of Chico. In addition to the increase in GHGs created by an estimated 23,000 to 28,000 automobile trips of 5,000 to 6,000 residents of Valley’s Edge, there will be an enormous increase in traffic and congestion throughout Chico.

 

While there is a commercial area and an elementary planned as part of the VESP, there is no clarity about when these will be built nor what might be available in the commercial section. There is no question that Valley’s Edge residents will travel for work, shopping, school, appointments, and entertainment, adding to the traffic congestion. The greatest pressure will be felt on East 20^th Street, the Skyway, and Bruce Road, but already congested areas (such as highway 99 with its short on-ramps, East 20th Street,Dr. Martin Luther King Jr. Parkway, Eaton Road, Notre Dame Boulevard, Forest Avenue, 1^st Ave., and Mangrove) will face increased traffic and congestion.

 

The Alternative 

 

We are often asked what is the alternative plan. We need housing. Our answer is infill. There are many infill sites in Chico that can accommodate the need for a great deal more housing, and especially affordable housing. The City needs to become much more creative and proactive in up-zoning, rezoning, and urban renewal. Urban planners have developed beautiful, practical, and necessary housing throughout California, and indeed, around the world through infill. This would make housing development consistent with Chico’s Climate Action Plan.

 

The CAP emphasizes the importance of creating a walkable, bikeable city as one of the chief means of diminishing the use of GHGs. Their vision is consistent with Smart Growth Advocates’ emphasis on infill.

 

“The City will work to provide safe, low stress and convenient biking and pedestrian infrastructure and prioritize active transportation. Infrastructure needs include bikeways, sidewalk improvements, and expansions of both kinds of infrastructure to all areas of the City. . . . (T)he the City is committed to achieving higher levels of bicycle mode share on par with the leading bicycle cities in California.”

City of Chico, Climate Action Plan Update

 

 

 

2023 Press Release

For Immediate Release

Contact: Susan Tchudi 530-781-4122 susantchudi@gmail.com

Kathy Clement Coots, 5308981799 kathy.clements.coots@gmail.com

Grace Marvin, 530-893-514-78, 530-893-1994, g-marvin@comcast.net

 

Smart Growth Advocates opposes the Valley’s Edge Specific Plan, to be considered  at the December 1, Planning Commission

 

Community members are encouraged  to attend the December 1 meeting of the Chico Planning Commission to oppose the Valley’s Edge Specific Plan, an urban sprawl project in the rangelands and foothills east of Bruce Road. 

 

Smart Growth Advocates--with the support of Altacal Audubon, Butte Environmental Council, the Mt. Lassen Chapter of the California Native Plant society, FRiends of Butte Cree ak, nd the Sierra Club--opposes the Valley’s Edge Specific Plan. The development of Valley’s Edge will increase Greenhouse Gas emissions, destroy habitat of endangered and sensitive plants and animals, increase wildfire risk, threaten groundwater, diminish the natural beauty, increase air pollution, and exacerbate traffic and congestion.

 

Susan Tchudi, a spokesperson for Smart Growth Advocates, says, “Chico needs more affordable housing, infill development for the people who live here. Chico’s General Plan calls for greater density, a compact urban form, walkable, bikeable communities with a sense of place. We need to direct development toward existing neighborhoods.” 

 

To learn more, go to smartgrowthchico.org.

Stop Valley’s Edge | Editor For A Day

Chico Enterprise Record

 

By Susan Tchudi

PUBLISHED: July 6, 2022 at 2:27 AM PDT

 

The proposed Valley’s Edge housing development is poised to move ahead after the Chico City Council reversed its previous decision to NOT develop Special Planning Areas until the General Plan of Chico was updated. Smart Growth Advocates, The Butte Environmental Council, and the Sierra Club oppose the project and want to provide housing for those who need it, protect our environment from the increase in greenhouse gasses, and maintain the precious ecosystem of the foothills.

The Valley’s Edge Project is a developer’s dream that would be a disaster for Chico. Proposed are 2,777 luxury housing units on 1,448 acres east of Bruce Road. It is an area of riparian woodland with vernal pools, wetlands, and oak trees where the foothills begin. The territory is home to 38 species of nesting and migratory birds, including burrowing owls, the loggerhead shrike, yellow warblers, and Swainson’s hawks. Also threatened are vernal pool shrimp, a number of bat species, and the Western Pond Turtle. While the developers claim they could mitigate the impact on the land, there is no way to move a vernal pool or re-establish the endangered Butte County Meadowfoam elsewhere. In fact, the draft Environmental Impact Report says ”the plan sets no clear parameters for the Meadowfoam preserves, including timing for establishment or management or monitoring requirements.”

During construction, huge amounts of dirt would be moved; grading by heavy equipment would be required; large machines would roar and vibrate. This constant human presence (during and after construction) and the dust, noise, runoff, and presence of polluting materials gives very little hope that natives of this habitat could survive, much less thrive.  While the project claims that it will restore riparian areas and replant vegetation, these “mitigations” will be too little, too late for the wildlife supported by this ecosystem.

 

Even more damning for this project is the projected emissions of greenhouse gasses. This is an impact that—according to the Draft Environmental Impact Report—cannot be mitigated. According to the dEir, the proposed project would result in GHG emissions of approximately 3.13 metric tons of carbon dioxide per capita. Thus, the proposed project’s estimated emissions would exceed the city’s total 2030 efficiency target of 2.76 metric tons per capita per year.

Chico’s Climate Action Plan (unanimously passed by the Chico City Council) calls for zero net emissions by 2045. However, the proposed Valley’s Edge project, with a projected 5,654 residents would lead to vastly increased traffic and greenhouse gas emissions as people drive to town for work, appointments, shopping, and entertainment. Though the developers suggest that public transit could reduce that load, the notion that people in luxury homes will take the bus to town is unlikely at best. And the lack of density of this project makes it improbable that any sort of convenient transit would serve this neighborhood.

 

In addition, the housing units proposed for Valley’s Edge do not meet the needs of Chico’s residents. According to an article in the Chico Enterprise-Record on Friday, May 13, about the draft of the Housing Element for Chico, Chico greatly under-produced units for low and very low income housing in 2014 to 2022. In its new 2022-2030 draft housing element, the city “will need to allocate 1,101 very-low income, 507 low income, 770 moderate income and 1,110 above-income level units over the next eight years.”  Valley’s Edge’s projected 2777 units vastly exceeds the need for 1880 moderate and above moderate income units. The developer claims that the project meets the General Plan guidelines of having a diversity of housing types, but there would be no housing for low or very low income people. In fact, this project seems designed to attract Bay Area and Southern California residents, looking to cash out of exorbitant housing prices and get comparable housing in Chico – affordable for them, but not for Chico residents.

 

The current General Plan calls for “protecting the environment [by] promoting compact, walkable, infill and mixed-use development”; In addition, the General Plan envisions that by 2030, Chico maintains its “small-town character through sound planning and orderly growth. The urban form is compact, with a clear distinction between the City and its surrounding lands”; Valley’s Edge, this enormous 1,448 acre urban sprawl, would provide the opposite of compact urban form.

The conservative City Council’s decision to bypass the General Plan process means that we need a forceful, fulsome response to STOP Valley’s Edge. Concerned citizens and organizations are leading the fight against this and any urban sprawl projects. Those who want to preserve the quality of life in Chico can join the movement by contacting Smart Growth Advocates: sgachico@gmail.com.

 

Susan Tchudi is a resident of Yankee Hill. She is also a member of Smart Growth Advocates and the Advocacy Committee of the Butte Environmental Council, and convener for the Environmental Coalition of Butte County