WATER AND DROUGHT
HARM TO BUTTE CREEK
RUNOFF FROM VALLEY'S EDGE WOULD CAUSE HARM TO:
NO AFFORDABLE HOUSING
ONLY 1.3% IS DESIGNATED FOR AFFORDABLE HOUSING
THIS IS THE WILDLAND URBAN INTERFACE ZONE (WUI) AND HAS BURNED THREE TIMES IN THE LAST 19 YEARS
VALLEY'S EDGE WOULD DESTROY:
GREENHOUSE GAS EMISSIONS
THE GHG EMISSION IMPACTS ARE CONSIDERED SIGNIFICANT AND UNAVOIDABLE
ADDITIONALLY: THE DEIR (DRAFT ENVIRONMENTAL IMPACT REPORT) STATES THAT EMISSIONS CANNOT BE MITIGATED
THE 6.24 ACRES OF WETLANDS THAT TRAVERSE THE AREA AND 11.183 ACRES OF OTHER WATERS INCLUDING VERNAL POOLS WILL ALL BE PUT AT RISK
SMART GROWTH ADVOCATES (SGA) MAJOR POINTS FOR RESPONDING TO THE VALLEY’S EDGE DEVELOPMENT
Valley’s Edge is a proposed land development project covering approximately 1450 acres being designed for approximately 2800 living units in southeast Chico.
Traffic Impacts – Congestion and Carbon
• The development of Valley’s Edge will increase the greenhouse gas (GHG) emissions for the City of Chico. Both the construction of this housing development (2,777 units) and the dependence on vehicles for this urban sprawl neighborhood will have a significant impact on climate change.
• Transportation is the biggest producer of GHG in Chico, and over 23,000 automobile trips entering and departing from the development each day for the 6,000-7,000 residents of Valley’s Edge.
• In October of 2021 the City of Chico approved the Climate Action Plan, which calls for the reduction of greenhouse gas (GHG) emissions to achieve carbon neutrality by 2045.
• The City’s efficiency target noted in the City’s Climate Action Plan cannot be met if Valley’s Edge is built. The City’s 2030 efficiency target is 2.76 MT CO2e per capita per year. However, the GHG emissions for Valley’s Edge are estimated to be around 3.13 MG CO2e per capita.
• The Valley’s Edge Specific Plan is inconsistent with the City of Chico’s Climate Action Plan, passed unanimously by City Council in 2021.
• The EIR for Valley’s Edge indicates that carbon emissions cannot be mitigated.
• The acreage of Valley’s Edge has caught fire three times in the last nineteen years.
• This acreage has served as a wildfire buffer for Chico.
• 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. The proposed Valley’s Edge development borders these areas.
• Valley’s Edge promises a complex and costly set of conditions that will be difficult to maintain and enforce.
• It is difficult to fit intentions to outcomes when fire behavior and frequency defy most previous fire suppression and mitigation. Fire behavior is increasingly unpredictable, frequent and dangerous.
• Valley’s Edge claims that the building standards and landscaping will exceed California’s requirements. This is not saying much, as what is state of the art today could be woefully inadequate when the next fire happens.
• Fire precautions described in final EIR for Valley’s Edge will rely on the intense use and sequestration of water. • This expectation of a generous water supply leaves little room for the likely worsening of water availability and accompanying restrictions on its use.
Housing Needs of Chico
• The City of Chico and Butte County housing policies call for increased low-income housing. • Over the last eight years of permits granted by the City, only 10% were for “very low” or “low income” housing. For the same time period, 82% of the permits granted were for “above moderate” housing.
• Over half of the housing permits granted in 2021 for the City were for “above moderate” housing.
• The Valley’s Edge development does not address Chico’s most pressing housing needs, that is for affordable housing.
• There is a new law that focuses on using available commercial land for new housing to build affordable housing. • Smart development focuses on “infill” projects in underutilized areas, with affordable multifamily housing, walkable sidewalks, tree canopies, and small electric buses
. • The City’s General Plan aspires to have compact development, public transit, walkability and to minimize the creation of HOAs. • Most of the Valley’s Edge housing will be part of Homeowners’ Associations (HOA).
• Only 162 of the 2,777units within the Valley’s Edge development will be multi-family housing. • The updated Housing Element utilizing data from BGAC’s population forecast for 2020-2040 indicates the City of Chico will have only a minimal increase over the twenty year period, that of just over 3,000 people.
Water Availability and Depletion
• The water for 6,000-7,000 residents and the commercial users within Valley’s Edge will come from Cal Water’s wells.
• These wells tap into the groundwater of the Lower Tuscan Aquifer (Vina Subbasin) that currently is providing for the water needs of the residents of Chico, as well as the Butte County domestic and agricultural well users.
• Even without this new pressure on local groundwater, the Lower Tuscan Aquifer (which includes the Vina Subbasin) already has been determined to be in overdraft.
• A local hydrology scientist who has studied the Lower Tuscan Aquifer extensively believes the acreage within Valley’s Edge to be permeable and the development could contaminate the Lower Tuscan Aquifer. The Project also could interfere with the subsequent recharge of the Aquifer. A risk analysis of the hydrology of the property has been strongly encouraged.
• Given the Project’s water demand will be met exclusively with groundwater, the city should establish a project-specific threshold of significance to address potential drawdown of groundwater within the Vina Subbasin.
• Although identifying the amount of water used is a critical component of a Project's EIR analysis, it is not the full extent of the inquiry. The timing of the extraction that will have environmental consequences must be disclosed, analyzed and mitigated.
• The EIR fails to disclose the cumulative impacts to the use of the groundwater and dependent species.
Loss of Habitat for Plants and Animals
• Developing these homes will mean cutting down approximately 1000 slow-growing blue oaks and likely to interfere with the effective functioning of the resident vernal pools.
• The Project is likely to have potentially significant cumulative impacts though the cumulative impacts expected from the Project have not been analyzed with established, adopted studies.
• The habitat for many existing wild animals, birds and native plants will be destroyed.
• Despite agencies that survey endangered species stating the studies need to be conducted every two years with the last one being undertaken in 2017, the EIR states no additional studies need to be conducted.
• The Valley’s Edge plan lists the responsibility for maintenance of the open space as falling under the responsibility of the HOA. These entities have no experience or expertise in ensuring the biological health of fragile species and ecosystems.
• Visitations by the Environmental Consultants failed to identify numerous species of concern that exist on the subject property; these species have been identified on the U.S. Fish and Wildlife Service Birds of Conservation Concern 2021.
• Criteria used to identify avian species of conservation concern are of limited scope as numerous species found on the property were not included in the EIR; these are as follows: White-Tailed Kite, Lewis' Woodpecker, Evening Grosbeak, Oak Titmouse, Brewer's Blackbird, Horned Lark, Northern Harrier, Burrowing Owl, Loggerhead Shrike and the Yellow-Billed Magpie.
Loss of Open Space and View Shed
• Scientific research has documented that nature provides significant health value for humans. The World Health Organization labels stress as a health epidemic of the 21st Century “…even a small amount of time in nature can have an impact on our health. It can: reduce blood pressure, lower stress, improve cardiovascular and metabolic health, lower blood-sugar levels, improve concentration and memory, lift depression, improve pain thresholds, improve energy, boost the immune system, increase anti-cancer protein production, and help in losing weight.”
• The EIR for Valley’s Edge indicates that the loss of aesthetics cannot be mitigated.
• It has long been known that the maintenance of open space and an unrestricted view shed is necessary in the health of humans. • In the words of Wallace Stegner in his Wilderness Letter penned in 1960, “These are some of the things wilderness can do for us. That is the reason we need to put into effect, for its preservation, some other principle than the principles of exploitation or "usefulness" or even recreation.”
• Precious open space should remain open for our many generations to come and for our wildlife because after land is “developed,” its wildness will be lost forever.
What Would Be Lost?