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.