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HomeMy WebLinkAboutBUTTE CO. PLANNING DEPT. 79-11 6U , rid „ stem ptsnsa�ceopilsn one orvery litleofthearea would "ify for systems slopes, onles s than 5 arses. Therefore, no zoning for.less than 5 acre minimums should be approved. To do otherwise would waste staff time and create unreasonable owner expectations. On steeper 'sl'6pes,.it is Q acknowledged that, a -much larger leach area would .be required and zoning Minimum shouldrbe much larger. � c Terkdih Restricts 6h Development: nt. again, specific slope and soil information as no's\ y'et —available and 'same should be obtained ' before"approval of,any zoning which would permit further residential. use. Based upon..the. U.S. Soil conservation Services recommended , limitation of 12% maximum slope for development on r'rar tic soilso ; all lands in excess of that slope ;,ghou:! d be zoned fd,' very large miri,imum pareei:',s so as to 'permit adequate house ,and ie" ach f1 el f Resid6ntial thA entire re - 9 11 parcentage o this area�.has ground naturally, flat enough +o afford development without alteration of the existing topography, -wherefore nearly all develop-� mgnt in the area would require land alteration, leading erosi q g to' on' arid, rs_ atteindant problems. Drainage: `brainage of contaminated storm water and percolated wastes into �LOJM Ot&Ville and Ponderosa Res:irvoir wiill, add to the significant erosion and}>sed. mbntatiori potential. The coMbination w,"11 severely, damage recreational, water, and fishery, use fez` resi- t,; dents of Orbville and Butte County. r Summary f the Project t ,ConsY`de ations : - " To the listed "fa,cw tors should,,be added thethe basic impact's We have suggested under Section 151404 - E. SECTION :151.42 DESCR.IPTTON _OV ENVIRONMENTAL SETTI;N(3 w Soils: The indicated unpublished soil, surveys` and the6so l vegetation ;survey OUX,rently underway „by the Forest S�rvi.ce should be obtained before any z)�n�.ng /to approve resiarzintxal Or Commercial U00- in se in talks area, unless it is to be asoumed that the soils are extremely unstab.,Ip, erodible, and generally too shallow for septic percolation. The on page 9 that the soil in thho. rezone area is pre- domina t� 2 to feet deep is cnhtradicted by accnowledgments of shallower soil, over most of the area on pages 8 and 13. Area resi- deYats are also aware tLtat the soil, is much less than 2 to 3 feet, ' deep over much or any large portion of this area Whereas Local health officialb are ge'hdrally-"L concerned with soil only aS to il"s capacity' for septid percol,atk-.. j `hist r,a titin soil, ercol"ates so well than i.'t would readil � trans art, west p r �'�� p� Labe Oroville and, hderosa Reye. oir.. These,ampa; strums , 1 'J' sha'w7,d be thoroughly studied and input obt'Ained from the,":ity of Orov�.Tc\, OWTD, recreationists, and water quality persoirnel. How much more 'r,pidly would hake ,Oroville,be sedimented? Who,.;would pay for dredg r.n�it and how much? What individual site"'studies would be made to assure stability and ability to safely handle' sewage? Hydrolog,: The statement that. 1 can be expected to supply 5 to 20 gallons per minute' 'is :not true, as per above infor- mation from Tom Kruse`; local indicating an-average ` ot_. ,3 ,!gallons per minute, Most r�Ysidents must ration water during' t.",- AGntlis of August through October, Thus, the EIR`'s indication 15 that only limited de%elopment of the ,water source could, c'c'ur is true and an understatement. Air Shed Character: With increased population and traffic, dust, from most of thy,° xistinq roads would ,increase partlqulate matter very substan.tia',l,lyr unless paved. Visu tet: The visual ualit is reserr„J a1 Char�ar " � ' .. -quality p �` ' �y high except the view over the Sacramento Valley, which :is coni tbnly ob- " scored by smog, except after clearing winds. The local visual quality would change markedly with substantially increased vehicle usage in the area. Vegetation: It is true/ that oak toodiand-chaparral.-grass- .and-fo othill pine vegetation (_'lovers much of the area. The dense tart oak indicated, however, largely to the easy" of this re— Zone Zone area, near Feather Fal1.s, This land has cons"Iderably more coniferous species than is suggested in the tIR. Most of these, however, are we7'A away from the main roads and, nat readily visible.Porestry is the primary industry in tr?,s area and the source for many local jobs. Major forested acreage, privately.'and publicly owned, is unite- eluded but surrounded by and adjacent to the prezone, area, The climate and soils are sufficient for ti"fiber production oyer even more of the landi if not., first develop8', aid if reseeded.' This is income potential for residents and the County and a superal r.,,-use of the land. There are many unique _ ung. ue micro-climates, p 1 ar+�,�,cularly on the north and northeasterly facing slopes; general=y'Fabove 1,50x'fest in elevation; which resemble the climate of the paci is Northwest! cooler temperatures, more moisture, and. some plant types not fou-nd,.on the `:..ouch and southwesterly facing slopes. They ate generally fragile eco--systems, ane would be jeopardized by the impacts of increased population d nsity and more intense land use, ,,unless specificall protected ;from encroachment and despoliation. Wildlife: This area lies"between the colder high elevations and the more heavily populated -Talley lands.,, Accordingly, `it is essential winter range habitat for deer, which must migrate down from,,the =higher� eleva"'ions. The popu�;:,itio s of wildlife are not as reduced as mtay be caggested by -the EIR, in 'that more coniferou's p present than indicated (be, ter :habitat) species and tarp �ak�ae See apperdik C per development reducticn,,of this hero by 80% or more. ,y Sucker. Run Creek was overlooked by the EIR as a perennial stream, hosting a substantial trout fishery. Local residents depend upon fishing for an-important part of,,,,their food supply and recreation. Streams and headwaters of Lake Oroville are 'fed by this watershed and erosion siltation would damage brown and rainbow trout feeding areas.,and kokanee salmon spawning areas.,' Rare and Endangered Fish and Wildlife; Whereas page 21 of the EIR inaidates the rare and endangered-Southern Fuld Eagle is not known in this area,$ appendix C acknowledges at least two nesting pairs in thy+ area, Which would be deplaced or eliminated by major development in this area or even minor development in critical " locations. Many residents have observed eagles in the areas of the Feather River south fork and Ponderosa Reservoir; indicating there may, be more than the two pai.7s stated. historical Background :arid _Archaeological Resources The rieh.archaeologidal potential of the area has not been sufficiently inventoried. As major Oittive American .sites often occur on land beet-suited for modern development; a professional archaeological survey,should be conducted prior to approval of this rezone pro- posal., Residential use of any sort will increase vandalism of sites in the area, on developed lots and nearby. As indicated, in the written comments of Archaeologist Keith Johnson, very large parcel sizes are required in critical areae in order to give maXi MUM possibility for house location without,disturbance of these valuable resources. Local. native Americans still use much of the area for their traditional�-*ocial,, cultural; and religious activities. The secon- dary impacts-6f increased population on these practices would be R,!%Iturally destructive, Local native Amer=ic;ans should be consulted to determine the enact nature and Oxtent of archaeological sites within the project area so that they nay be properly located and identified for apptopriate zoning. XJtil: ties .and Public .Services f, Fire Prateoti6h: As �.ri ica.ted+ Chaparral. has a high fire hazard. Furthermore, the peaks of fire activity grIherafly' g driest 'months of July, August, and 5'eptember, ,., occurs during the , { r �,� � , C`.✓' � (%�, x'41. 1 16oi;ncidental witYt periods of highest,- usage of the zon i,x.'g ,area fob ' (,recreational and second home purposes. Thus, increase :residential .use i n the area will peak at the worst possible time.,,,,i'�� ftarther �6 mportant fire hazard factor is slope; hea't' tends to r�,ae and fires muchfa8ter4 ,. , x �r-4;;'vectionvcurrents combined withsstee tslopesrand nar;`cswgcanyar�`Can- ,swan create an ettremel dangerous suata an for s I �,<( _y g r homes a xd rural � � areas. Residential development on the relatively leve Q`areas above these timber lands will be subject to extreme danger. ;,dous;:ing near forest lands and chaparralwill increase,Idli E � zk to Jr F timber land and watershed holding eapa -ity. This must '";' Loon sidered' with the great distance from :tra;7or fire i 1 glib ng equip f't ;'' The" �<4 equipment in Feather Falls,;`, is vet,ry old and insu£ficients and manned r„ by volunteers only. ; Tj';` poor roads to the area further 6 l.' tensify the problem, andthis is still greater for the majority, Lif poteai- tial parcels which are isolated from any paved roads, `n Ito, Gill' pay f or tysthe lacknaf�ased taxfire ratepfor�fi.rensevices and the *�l��bab�ee availability ► :'�>articularl ivt� J' BL,,tt i. County's un_. ` :? labila ty of state funds to compensate for the proper, ,y tax loss l{ of Proposition 13? Can any development`be permitted without pro- yiding adequate fire protection.? , Is this reasonable fob 'Vresent ie9tdents, new, purchasers, or owners of forest lands? ,1 Police Protection: Based on`t;he requirement of i deputy for each 1, 000 ;people, and this rezones potential,"-xlene~� r t * to 91000 new residents, B to 9 more deputies would be } i` who will pay fcVX the5j- o particulael.y given the impact o „Qpositi.ori 137 L Ac .sP,� Butte County has no plan to upgrade Lues ;1, ,n Read.. for 11 year (1995); yet the rezoning would allow and eri.,ourage greatly ,increased traffic well before then. who will, 'pay°'for ��this cost:2 nigh grade access is needed to avoid accidents, <<a�,?4;aIV, fire `5 truck ,access, minimize dust, etc. The VIR anticipates ,{Y yt �rivate 1 development should bear the of such improvement, yep pa,ecemeal j development is the primary phttern in the foothill, « TYA�-�ub'la,c bears the t;ost for such development, amen(, yet .present: road fit .A's are c;> ;, insufficient and the t rend is for less available twx each will improvements to Lumpki.n Road actually ,cost'+'?" S;creased development, the State is expected Lo turn over the CrA'' �'c�ss road to the County, at still greater improvement and ma qhs ea�� ince cost to us. Reads ser`=i ng most 6i ­the present and potenew parcels are -unpaved and there will be demands for court ' i} �rrivel= ment after gradual, piecemeal devel.opindht4 Mote � r�fox:nat ori � s hecessary before the area is committed by this 'rezonetf �r s 19, SFCTIObI 1514 3' _Fi V3:R0NMFNT.AL IMP;AC'1' �' • i Increased <Developmerit and Popu anon Growth 5v't',1,.1 the es-� tabl:ishmor't of the many cpmmercial parcels permitted by', t:�e 6-1 0,. tp..�tudeaoiyd� hehmerchar�ts aboutOthisle merchants? (abet is;`,.t`he at- A r 7 C, r II r, Drainage: Drainage patterns within the -;project area already are being iigerith as a result`gf human activity. Numerous ground_ water,: flows have already been a�tered by the construction of rows tY. oughout the area. Field observ;-Ations by W, Ra. -+I -i"12 Muenzberg revealed many instances of ponding of surface water runga f and blockage of natural drainage patterns by roads or other human activity:, in addition to interfering with''the natural drainaget,patterns, some of these fonds are potential health hazards because 6 ':.heir tendency, to stagnate and act as breeding grounds for mosqui;.,a. Also, par- ticularly given the absence of waste d0posal services, some resi- dents of the area have used some of these sites for solid waste disposal' purposes. These pro�l.,ems(already requ roe county attention and expense, but will be aggravated substantially With any f=ther development. 1 _. l; T_opogranhic Alteration and,Gensration of Erosion, -and sed ` ment tions. up a n , oR from even the existing, ,roads already causes Seda.rnentation • EroS� on f e y p Oroville. As the EIR states, new roads will reatl add to the robleA.', Not mentioned is the fact that virtually none�of the rezone area can be built upon without some alteration.; Given the Very acreage required for leach field: !{ on this shallow soil, disrupti.afi for .leach fields",may be one of the greatest land alterations. very little of the area has adequate road ;=kdcess, so roads will be multiplied many fold. The extent of will. be even worse: land altera,si.on is actually understated in the MR, so the erosion Increased.k\edimentation of Lake Oroville is expected, but. to teat degree? We expect the useful.life of bake Or«ville Would be s1hortened many years by the potential development under this zoni'Ag. What will be the dredging cosi and who will pay it? What Will! be the loss of power, recreation use, etc6 before clean up?., if the rate and amount of surface tater runoff is altered by human activity, as expected, how will this alter the amount of surface water Water iMPbt and in Lake Oroville, Ponderdiga lteserVoi.r, and other'',bode Water Ouali y Tmpadt8t The Environmental Health "Departm,ent, has a��prcvea septa tanks in the area 'With insufficient soil depth; �Ior safe percolation. Sewage effluent from development in the Veather Falls area has been transported rapidly through the shallow 'soils and flowed out over '.he surface for many years, posing, a�� health kind contamination tEispot, which has not been corrected. ,,Phe Health ,;e' artment undoubted! iso `, nderstaEfed already p � � � �i ``�;'�hich Wi�.�' be intensified by the limits r,t Proposition 18'. This rezone will. require much more time from the bepartmont, though staff avallabil.it� is l.ikelly to be less: This will endanger the rezoning area and spread r�sources for she rest of the county dangerously thin. it o „ "14.. if is daubtfu a`taff is`T adequate for "the potential development on even .existing parcels. "They 5.hol ld%not be saddled with- theF=°burden of any of the development' potential under the proposed,z6ning if roads throughout the project area ;are paved to prevent severe erosion and dust, the subsequent runoff will bR coritamix�ated „with chemical residues,from th,s road surface, in addition to,:,, chemicals used by new res,identri, etc. The,,Forest ,Service has used- IC chemical defoliants � in the area, c� (or permitted their use') , which already, may endanger ground water andt,rviioft water quality. The r scarce grc_und water must be protected from further threats,' r Water A vailabi.lity.' Water scarcity will be aggravated Eby development of many of the parcels already existing and substantial new development will crea4e acritical shortago owraers'should not be given the false assurance of water suZficiency suggested ,by any zoning which permits further rezidential,'jdevelopment An added thr6at to water a:vaila'J'Alit y 15 that cuts and excavation; made in conjunction with road btild;ing or realignment expose shallow springs and divert them into drainages ditches us ult Impact \ surface water runoff : Thi:r`typ e of im act can be seen. as a �.�. es of existing roads, 0 �} t y.,ail,op�. „ ment Oquid o6;cur • Slue to the .pound Walter risuft�r..enc Only, d arse ,dev� y If additional development diminishes ground water, the �. ;total amount available for nozi-domestl,7",, uses will also diminish, :f This supply is dep6nded upon,, by the fd.,.4sts and forestry business and the vegetation which holds the unstable granitic soiI in plane. mhis would greatly increase etistinq erosion potential and fire dancer: ti are �,ossof Wild !fe� end PlarYt Rabaaai.; �T'his a is critical�y doetwinter range. ' James SP,ot%den, W� l.dliie S3`� olog�,�.t from the California bepartme,# ox F�.sh and Matte indica�gs 20 acre,-parcels are -the iiiihiMUrA parcel size and a human�tol eraric e t�:�reshtfld levee; ` for deer, and s0aller parcels Mould cause starvatiori� and distuzb ;4 y y q/ A ti i �reaeized or. tn:.quiF� anima,rs, including �heYuhe yf or endangered, matin Snowden also indit, tes the area is h� .. � �pottbO_ Opal and "Aii,14 !fail Cat:. These species are antold', kn � ,to an ant�xease in human activity. Tht can be expected tc abandl6n tic, area if there is muo-h n6W abvelopment in the vicinity, Richard tk�lint., Fi °'her .eS Biologist for Laky, Oraville� bias expressed concern r thr.: rish in T ayCe c?raville foak�r;.,`sucker Ar:n Creek. Xokaziee Salmon, small mouth bass, and btowtf and rainbow troiA inhabit thr take and. the Greek; and the Sal.�tcin Spawn in the preek in tho fall Thal-ceased sedimabitation from d�ivelopment will prevent salmon and other eggs froni hatching, inc,reiased turbiditi may cauw.s temperati're's to . rise to ar, intolerable l;ve. 4nd destroy the food chain» s l 'increased!;F"ire Potential: This was discussed above. The r, problemwould be aggravated by diminished water supply. l . Noise: Present traffic noise fromr logging trucks is only evident during the week. Weekend noises would be ibstantially aggravated by new development. Nois�partcularly�for�be a major factor the5��,uthr�rnBald�aglesz-ecltxci.ng wildlife habitat., Jt Land Use; Although this proposal ,is for zoning more restrictive than the present A=-2,;:,,/`,his zoniing would be a signal, particularly to non-residents unf JEAliar with, the land, that :the allowed USetp have County approval and are reasonably assured, unlike the A-2 zoning. This would be a si.e'nal and e?encouragemeint for subdividing, s e '- g p culation and exploitaUQn of the land. Zoning z should be consistent wi,t h: the carrying capacity of the land,{but '1ehis proposal is not atd is internally inconsistento ResidentLj.al and commercial development is not possible here without great damage to the land; suixounding acreage:, the Feather River, take Orovil.l.e, and the water supply from the Ponderosa Reservoir: �. `? If the land realistically will n -3t be developed to this detrimental degree, what is the need for the propped zoning? `will it, encourage partially completed subdivisions, without adequate i.,nprovements or erasion controls, unsuccessful home industries, or abandoned business ,.ass has occurred in the past? lncreased°'Traffic and Circulation, Traffic Hatards, Abad t ptoye4aentss The estimated 2, 000 to over 10, 000 vehicle trips per day at maximumbuild out appears unrealistically loft, especially given the:- li.mitod local. employment ,tppportunities Regardless the number ofdaily 11tri ,j distances i.nt;l.ved are relatively very high and total Milea.!b 7;:sr residence may be much greater than i.h urban ''` g „ increase energy consumpt'',on and traffic- a:�ea5 . Th�.s , t�z„u1d rPatly '^t related polluuxon l � r; is 'questionable whether Lu,Mpki.n Load can handle an ribte ;bra-fic. �nfoj�mation is iribomplohe. Any increase, -even vithoat large subdi.viions t w,,Ill require majbt road improvement. -r. r� at County. IoXpense. 1�hat world be the cost? Given financial limits, it apertrs the County cannot afford,(( this cost and, as with the lower . 9kyvray, many deaths seem likely befl re such ,improvement would.. be possible 1i All v The State Department of Parks arj recreation apparently n will deoed the Craig access road to the County to improve and main" tain, '"if traffic increases on it. This should be dcterihined_, and, costs e-stimated. Most of the dirt roads.may be impa±6sable in winter for police and fire protection, without'substantial improve- ment. since most of the z.oads service ziniltple parcels, the County is unlikely, to require individual o:mers to make sufficient .improve meats for minor, piecemeal parcel splits. Demr,.nds for County funds ;>> can be expected. How will"`thh"cost be pakO When? What will happen if such improvements cannot be financed? Increased Public ,Services: What will be� t1 41)co`s.L and:. Who �I nay for even mih r 'n�i creases in fire ani(' poi i.ce protection? Pressure is mounting for increases,,,%oven without .aw arcels et �-, . w_ W ��- p r y funds are diminishing'. Anil new development proposals will cause similar problems with Environmental Health Department, Public Works Department, and other department staffing. The remoteness from urban services -'makes the time and expense even greater. This is disproportionate and unfair to residents of urban areas, where development should occur, Mobile homes are making up an ever increasing percentage of Butte County's permanent hoizsing inventory. A Bank of America study "Vocu{a on..Bttte County" (1974) projected they would maks up 15% of the,total by 1980. This trend may go higher because of inflation in'building costs and loan rates-. Mobile homes are especial,y popular in this and other rural. areas. 8inoe Mobile homes are not subject:,to property taxes, this may intensify the shortage of .funds for'the disproportionate cost of "services to this area: How and by whom Can the deficit be compensated? Is the County able to continue to ,provide even the present levels of service? The, Feathl.t AFalls ccordz.nio x'oschool is the only primary school i .. l..'' r i w `.1\� i g pupils, i i :o ri the redone area. iotrict's TrUstee Marilyn Mowdy.,- the primary school has 70 pupils, 42 of whom are. from the ` rezone area. The present school site can accommodate 120 pupils maximum. Hnr_ llmont is now increasing slightly: With over 500 existing, undeveloped parcels in:.the area, the school, may be filled. Any permitted new growth clearly will require a new school.. What will be the coni and how can it be ;paid' The need for larger facilities `i1 ne6,#y »orry Creek hat necessitated two d- bonmeasurep , bothof which have failed, y�tii)ue to the geographical position of the school, increasing scho6i._�)bpulatioh in this area would require substantial bussing. The 'presoftt school bus miake8 two .runs per day to the Enterprise Boat ramp and back and i.s�nearl.y filed, with a capacity of 55 17 1. r>' Pupils. What would be the cost and bus runs and/or another bus? who would acPPs the Pxisting CouriaY for additional s road would require extensive improvement to road addtianal t.raffxc and safe bis stops, Y road and Cragg well',aWay from the main safe b. op , particularl riunodate, y for areas Given Present funding levels w Proposition 13 hich may there are ph solid waste facilitiiesrwx h fter district for disposal of school trash. by the BU":te Count H Despite annual iris the tha school throw Y ealth bepartment raw s pections:; Years.-... 9h a brushy area was o sewage flowing out behnu`> y This Baas been corrected though to ground water o; g` the shallow soil mayl0 rollmQn s may Pollution. Funding shortages for, So least` lea y create a health threat. mage,, and increased n. `1 d A)�aitional inquiries and comments on are submif6ted se t; „ Public expense/revenues Parately and should be considered, Increased Water Demands e Sind and most prob ..�-1Y wally be dep tea_,�romground water sig and a fea;.ible alternative sources are known supplies Ma elude all""n increased consumption, """new parcels until , zoning should pre:. any limited locations where suf'E'ini ens ess a is developed to define Water exi.sss.. Increased Enerav:Demands and Unlit Extensions Gas & Blectric indzcates`�� khat all new lines in thesarea.willcbeac placed overhead and will be This Would be a visual blighlenddaucontrasunfronl sparse development. Yin subdivisions. from the present t' There are no public water or se the present time and novo are considered efeasblesdue toin ethecta at. mum lot sizes allowed. extensive and More intense develo meat mini- graphy. ,.,expensive pumpingstations P Would�'toquire �.dud to the uneven tcpo- $Voss of _Poten r more Camber' s tial Timber Production Area, rl exidts does exa.st fY;ri t e area than the EIR suSJestQ°nsa'derably r� more, unless the water table is lesthe fire danger ane"eases The Potential resource Would rs With further population. r, lowered and/or anurease , , .duce the magi co Damage 'to this features eroUaon cause loss of nuneroial enterprise in the and aderel county revenues area, by this rezone. affect timber land ad�acentctoaandaesthetic considered. T'he'se impacts 'should bend surrounded :potenta.al air ;.-.. y determa3xod grid '� pollution damage must be determined also Utter and So�,a.�, Wast, funds to Daft° C11 nuht -funds t for present oall.ectio;n needs in sheYareauld accept respoh.. do soy and who will What will be the cost o,t , ,r blit may.ladk the pal? To what extent Will this decrease facilities of the oxistir g Land fill site and U111at costs Would a esu'tt of it life ,.a Human Health- increased fire danger, traffic, unstable wafer` supply, potential Water pollutiow-i valley fever from disturbance of archaeological sites, and other potential human health problems may result from any further development. An additional local hazard,is„ rabies, for which Butte County is an endemic area., This danger is � compounded by the atfracti.o'n of small rrarnivores to residential developments. As w,iJ "I habitat is destroyed apd contact with humans increases, so also �s the danger. Recreation: . Jo-Qlevelopea" recreational facilities suc • has basketball courts, tbal,l fields, or childrens t playgrounds exist in the rezone area. The '"natural" recreational facilities such as the trail and observation platform at Feather Falls are routinely crowded to capacity. The trail head parking area was expanded in recent years and is`i'enarally filled on weekends. Increased human activity,'vould place' additional demands `on existing ,recreatioinal'.-;+' facilities and threaten damage -by overuse. Further development :of the . g a may be imp gssii�l:e' due to the lack of. funds« Crax Recreation Are The access road, Oregon Gulch Road, is unpaved and funds for paving tato limit erosion and dust) may not,, be available. This may lead to deterioration of this resource. Historical and Archaeolo ical Recources.:.7'he rich archaeological tential of the area, has not',Ibeen sufficl`erit y illventoried. A pxofes sxonal archaeological survey should be conducte,'prior to approval of Il any zoning which permits flirthep development the area. Residential use of any sort will increase vandalism of known and unknown sites: For example, field observations of a Large archaeolog,cal site, des cribed as a burning §round, revealed extensive vandalism.' The site, is located in an area proposed for residential development. No action should be taken which would Jeopardize such resources, without a comprehensive survey. The entire area should be retained as a virtually untouched historical: and archaeological time capsule, otherwi.se,,this priceless resource will be jeopardized. G. AOVERSE ENVIRONt1EVTAL EFEIt S WHICH CANNOT )Bt AVOZbRU' IF THE PROPOSAL IS IMPLEMENTED To the 13 items listed should be added- 14. Loss of timber production land within and adjacent td,the rezone area. 15. increased danger to human health. M. Loss of a remota-_ and independent lifestyle area, 17 Intensification of"msny other impacts if funds: are not available to provide and mitigation,. 18. Increased ehergy use. 154 Gro+ath inducing impact and/or other impacts on ad- j anent ands . q C7 4J H. 1r MITIGATON M.EASU f! ��� 'EES PROPO'S'ED TO MINIMIZE THE IMPACT Priiary mitigation must be. in the form of- a�,ternative zoning. Thies County has,no conditional zoning permitting other " forms, o niltigation in this rezoning content,. Environmental impact of parcel maps traditiolial,ly is hot intensively reviewed by thi:,s county, even if the meed _is shown in preceding rezonang proceedi.rig6. Health and Public Works"Depart , ment staff wi3.1 become ;i.ncteasingly overworked and their pest practices in`dic,ate they' cannot be relied upon to sufficiently mitigate imp,-_ts'potential with this zoning. Adoption of a dit ordinance, revision of lection services, im rovE.l R ,p gra, g p � weste coli ,, ` g �ment of roado - _sand expanded, services,,all would minimize= some of the impacts ��but paquire furidn; 'Which art,,' probably unavailable and%or _poliz:�"al..__.a+�itudes by public officials which have not been demonstrated. lr- I. ALTERNATIVES TO THE PROPOSED ACTION We agree, that ,the "nes project"' alternaLive iw� unacceptnble. A combination of alternatives 3 and 4 would best mitig'ate these ; impacts., Boundaries should be modified to place all lands with mslopes �mexceedin 12�v timber lands and watershed in Very large Parcel sizes, to minimize or prevent further residential l development. Most car all of tll proposed 4`,.th � parcel sizes � . he ro oac�d minimum g / p '`�� y _ x�.st�.n 2 sho,'u1d be sncreased su�astantxa ' acre parcels should be zoned to a 5 or 10 acre minimum size, peg. mittiny development of existing I,o�s, but encouraging cona6lida,Ei.on of lots -Ito rectify the origi.nAl mistake of stitch small land divisi ons: by the U.S. oovernmprit. only :the relatively "level" lands on the µ ridg.a top, excluding those in the easterly portion of the rezone p area, shc,.'-wZd be ermi�i.t:�:d in .got sizes as small as 5 di� 10 acres. Foothill �ura�:"residential classification fox',.,,any steep, timbero or watershed lands appears questionable. The same is true for sands adjacent to public recreation area. A resource conse"rvation none should be considered. The�a.vesno the 'maximum orotectionr any zoning other than that which will p and restrict development for this fragile- area: ; Butte County should initiate rezoning for all nearby Lands in -the A. Z classificationo so .as to minimize the danger to suck lands and further protect the land Within this proposal. Respectful ly stamitted; r�1 PETERS y VULLPRR, ,, RUSH 0 SCHOOLING & AAS x. t� �:� � , A.,e�r�eys :dor Loca esiderts X Environmental Review Director's response to I,he letter from John, Luvaas of peters, Fuller, Rush;' Sr,hooling and Luvaas Attorneys at Law. 1. It is true that no study has 'been co7y,rtuutod sub- stantiating a need for extensive foothiIJ housing in: the area (or anywhere -in the county), 110w ver, future` development patterns are Moo sp'eculative to evaluate. The development potential,, is a theor(Aic{„p potential. It does not indicate a need for nox�,•,the 1. i.kolihood of achieving such a use fevel. .Appro Lately '1 300 new parcels are potential. ' Ruwever, ac (,nal 1rind., division proposals must meet specific r. equirtiiraitj of the county before approval: adequate sewage dispo,,:al capability on specific sites; provision of °travex ble r r;cess to all created parcels, proof of water on pari eltl smaller than five acres in area, proper configuiat:,oxi of created parcels, as well as further site-specific °env:i roxaxriontal review. 2. The compromise alternative proposal me.p herewith submitted is acknowledged. Tlill-r-1alt ornatai,ve proposes zones of larger :minimum aacrgagear(�Ills ! primarily TM -10; TM -201 and Fly. --5. 3. The six pages of quo'tatiore?-O�ow cm analysis of the Butte County General Flan, ,particulwvl.y the Conservation Fl ement ) the Op ein S� ac e Element, and. the Saf e'ty Element, are acl'c.owledged. The conclusions are noted; a. No commercial zoning is permitted based on the .Land Use Map of the General Paan. b 40 -acre minimum parcel zoning, is, sugges-ted fox Timber, -Mountain designated rareas (the eastern portion of the subject. land area) c. No urbanization or urban amonities of the project area 'is allowable. -use accommodate or inluce urban residential The proposed rezoning will no in the areae Two and five acre parcels cannot be considered urban de nsities. Man -7 of the General Phan quotations refer to »rban growth and develop- ment ratheL than the rural residential and re. creational nature of the subject proposal 4. Additional '.impacts resulting from this rezone project which ape addressed in the letter are listed. a4 ln.sufficibnt water for potential development. E.i'1 . ori page impact was address -4 in the draft This ii Oil ppage 32.; The further emphasis of v., potoal loss or Siminishment of present resi- dents, water ,upplies upon additihnal develop- t� �' ment is noted. b. Potential health problems suyc;;h as Malley Fever from disruption_ of. archaeological sites. Most If not all yells tap groundwater at greater depths then sewage effluent would reach. The Butte County t.�iviromental'Health Department e, believes effluent waters do not pe,roolate very far through the soil structure and are used, by local vegetation (transpiration). C. 4►he Wildlife impact was addressed on page 34 of he la.x.P;. Increased, use of the area would in-- rease the likelihood of wildfires with resultant otential: lose of homes, 'timber, wildlife habitat, sand wat#bhed'�;,, u. Pb sibil0 lack of funding- tc, provide necessary p� lid Services if development of the land en- tails substantiol incre4 ses in public seg va ce demands e. Loss of 'timber production is addressed on pao.r, 37 �{ of -the draft E.I.R. .Associated county revenues til on the portions of the rezone area where,timber production ocburs (eastern portion) is possible. Because of land divisions, potential erosion and wildfire increases, and conflict with adjacent residential uses, existing timber lands would be less viable economic units. y, • l'he fourteen ages of comments and statements ve-� garding all tie various sections of the draft H.I.R. are noted and are hereby included as part of the Environmental Impact Report. =lacy of t1';�' comments in 'the letter have either been , l adequately addressed in the revised draft Bil:.R., or in previous responses contained in this A.ppendi: E. Some of the information sought is more detailed than is necessary for tHis type of project. The California 2nvixonmental. Quality Act indicates that projects of a more general nature (such as rezonings) need not be analyzed in as much detail as would be necessary formore sitespecific development projects Such, as 3 -"Ad diVi8i ns, since the specific impacts are -too speculative for detailed evalua- -Lion. The level of sped 'Icily of a particular protect should determine what level of analysis is necessary in the environmental review of the project. Some of ' the specific data and information sought would be good to have, but is either unavailable at this ti: e nr11too speculative to evaluate oil 8=11 a large scalp. s , u Those'comments addressed in the letter requiring are listed below, a. COMMENT:: aThe proposed. zoning will�,'signal the area fol." develo ment. Response: It is,, true that while the,general unolassif Ned A-2 zoning of the area that currently exists is much less restrictive thanthe proposed zoning districts, the two-acre minimum parcel zoniiig ' that is proposed may label this area as a rural resdent*ial area, thereby encouraging growth and development. `1S b. COMMENT: Zoning must be limited to very ls.rge pwcel sizes. f1 Response Zoning should be compatible with the carryinv,-,, . capacity o4'/ the land f or residential develr-piv.ei�t (and for t1' e other various uses allowed 'n each F+ specific zone). In the subject area, very large parcels probably are necessary on the steepex'- sloping terrain (areas in excess of P6/07�slope) such as in the northeastern and sdutheast,ern portions of the area.} However, the carrying capar l.ty of the land is Area er on the ridge-top lands � °: 6�` s7.d..:;v_,' ing the Various environmental limitations"involved. Very large minimum parcel. zoning may I t be r(-- qu fed on, thesef;more gentle, 10-15916 slop,7)ng Oreas. c. CO {, 'f Thex4_ is no need for small lot zoning ir; `;his area. Response: Because of the unknown or tuloortain future resi- esi--dential dentialuse patterns or personal desires and • preferences, it cannot be assumed that 'two-acre or five-acre parcels will not be needed, gar „de- sired in the Future. The two acre zoni�ig wJ''ll maintain futuvo land use options while providing S-tk4ater restriction on land use +han cui{ren-tl:y exists. It is true that larger-than--two-acre- minimum-parcels are necessary in arms of more rugged terrain ('those areas off 'the'.ridge-,top, where slopes exceed 15%) to protect the land surf 6L6o r, r;egardl elss of demand. d. C,CM1 ,XT c + Soil: i�, ve��y �.imit;ing to development � � the Response: Soil is generl41y dar,,pw than 'was originally 6,tatod in tho' d aft 2.I.Soil depth generally is to S 60 Feet. Soil for wv '' $Ledisposal 1 V ose, �� )V`%fined !,as the p pj weathered' ae`x�omposed grafi articTm. not the. � durface `U;ap-soil l.oatri. bre, Ift)-1 18notl I ri t 01 `,, a serious limitation for septic-l: each Meld systems. Effluent treatment,; occurs in the top several feet and generally does not enter the groundwater supply, which lies at 50 to 200 feet deep. Soil erodibil.ity and leach. dela layou problems are greater lihiiting factors of the land on resi= dential development than is soil. ',depth. Soil s; ;f depth of the decomposed granite generally Ws limiting only on moderate to steep slopes and where rock outcroppings occur. Further discussion ,>-of this factor can be found in the revised odraft e. COMMENT: Vater^is a limiting; factor. Response; W,,ter availability may be the greatest limiti:o:g factor in the rezone area since water sources are ver-.).uncertain, until a, community water. supply is posy; blo and. feasible. Water pro- the is low. U�ells duction from ells in area W generally are 100 to 200 feet deep, below the assimilation regain "of the soy 1. sewage effluent Creation of new parcels undf r f�,ve acres in lyy supply area must have proof or, _-�d44uate water pp (3 beforo the land divisi6A can. be approved gallons per .minute minimum, I i 5 gallons during rt the dry season) . parcels over five acres o not require proof of water.:.... Existing parcels of c of less than five ares mu;:c prove a source water supply (existing webs) but are not required to prove adequate quanlities of water. if extensiv e development of the area ever community water s,Tstem wil'. eventually occurs, a be necessary. f. COMMENT: Terrain restrictions -yin development. , Response; The Soil Conservation Servico_ recommends that be limited to areas of less than development 150 slope if specific soil.stability is a own. Since most of the proposal has , 10-'1% slopes (the ridge-top lands of t1:ye ral:Ooretown Ridge t. ar d the Craig Area), this criterion. would ;1< permit de�relopment on these areas. All other lands in. the re ons. arep, Which have moderate 'to, steep slop of Creator than � �%d slopes o, e , �r,'r�-'S large minim=-p 5rcel zoning °to pro- •tec't the land part' culArl,y since specif 106 soil l ` at'ld telra.i.n stability data : s unava a�,i` �. COMMENT: Erosion and sedimentation will. increase. Response: It is clearly pointed out in t1to ETR ),,)hat the ." theoretical development potential of `:"this rezone pY'oposal, if fully' devoloped may result,,:in serious erosion and 6edim.entation problems. The actual degree o: the problem is dependent on a number of factiors, such as road locations, quantities and. locations of vegetation retained, season of theyear in which earthmoving activitie-s occur, etc. The degree of intensity of tho problem is therefore too speculative for evaluation' (� h. COMMENT: Access problems and other road -related impacts. Response: Access roads to created parcels viould be st:ructed by private individuals as needed to, provide thex:�equired traversable access as per /✓„ Subdivision. Ordinance. Awing of these priv4te roads is unlikely and therefore dust problems from residential use of the roars will be generated. Rda"a could become impassible in printer for police and fire protection. Eow-- ever, ; new land div siono require two -tray trave�sible access from a count --maintained ty road in order to be approved. !:his requires' yearrolmd access capability except in snow country. Such local access roads to more than one residence are ,maintained by the land owners vic, road maiziten,,�.ice agreements among the rospective owners along the access: Lmid divisions may have conditions applied by the Butte County Public Works Department which would ,r) , event the developer„ from .buil ing roads ac`j�O' ss drainage patternii-I whithout adequate culvert construction capable of passing drainage. waters: There is no drainage ordinance covering d 7 opment of existing parcels. J Road construction, par°L cularly on -steeper terrain. and irk' their alignment does not follow the contour of the terrain, is tho primary source of erosion problems in tevraixi over 15% al.ope, since these cleared areas of bared soil and rock: channel runoff. <, 161' COriq1]EN�. ,, , .I Wildlife imp acts tvill Occur''. t lZespons e . Wildlif e ,f6����oncernc and impacts t ,ave been: previouslf'Y discussed in the draft E.I.R: and in this Appeiidix E. Sucker RLm Creek is a perennial stream with a yearround, fishery6 Also, streams and headwaters of Lake Oroville ;� r I are fed by this watershed. ThJ[�s creek lies in. COMMENT io the , eri her , of the ve.,!`o e area and. on p p y: �' n the the probability of erosion sill,!ation of 1 creek or of any waterbody as a Iresult of the proposal is speculative. and vooty-zonea generally do.not extend very deep. J, COMMENT; More coniferous species exist aJh, the rezone area w then t�ie draftoEZR indicates. P' Response: Coniferousti.mbe,w-producing (.trees ,do exict in - the eastarn and nd: t.heastern [portions of the Response: 1 rezone area in relative abune�a ee. However, == elsewhere in the project ares, conifer species i( make up a small ..:percentage ot:'the total vegeta- tion and are rather lispersG. The dense taxi oak growth mentioned occurs ,largely east of '�, this rezone area., near �eatki,er Falls. 1 k: COMt`=T: Fire .Prote6tion adequacy. Response: It is true that 'peak recreational use and summer home use oT the area will coincide with, the peak fire season. Adequate Fire pro- Lection at ultimate development potential may ly be questiona..be at present service levels and with potential acces Ycirculation problems. 1. COMME'N'T: Potential for topogrtaplic Alteration. Response; The majority of the area hao SIO - 1591 slope generally (xldge-top. lands) where roan construction cal be undertaken without signi- ficant, surface alteration. The steeper areas of terrait (havin},a grcater than I%,slope) is where potential land alteration and soil disturbance would occur and could be signi- igni -ficant ficantit extensive road systems were to be constructed and more ea.so residential use were to bteur (on less th,-di five or ton acre ;� parcels) in. COMMENT io Reduction hn groundwater quantiti es'used by ve&. tation may occuv,) Responset. Vegetation uses the top several feet of soil for water uptake of inil trating precipitation and vooty-zonea generally do.not extend very deep. dells, in the area generally tap ground water �r sources at deeper levels, 50 to 200 feet depths» Ti. CCJI"ISNT The development induced, by this proposal could generate potential human health problems Response: lr.Creased likelihoo4, of wildfires ,'�tvgffi . acc 5onts, ax+baurei�d'f people to a'raba es endtsn;.c area , and. t�,e possibility of, vailpy fever roblessi t fto `disturbance of archaeological p sites may result 21.1 development and use -0:. Otho i '�, ,rarea ,3.nGeases' i•. r. .` o C. The list of adverse impacts contained on page 19 of the letter are hereby added to section 15143(b),,, Adverse Environmental £fects It should be noted: that these :impacts are potential and may not occur,: CThe most reasonable proposal for rezoning 0 o the area which is the -most ennv`iro:r�mexitally sound while allowing ou taable lands uses of the propertios; could well be a combination of the various alternatives under consideration If \ \1 ,I 0 ,i a ,x SOCIETY FOR, CALIFORNIA ARCHAEOLOGY ,t District 2 Clea rirtghottse c/o Department of Anthropology California State University Chico, CA 95929, June 26 1918 Mr. Earl Nelson, Director , yV� Environmental Review Department 7 County center Drive Orovill.e, CA 95955 Re: Craig-Mooretown Rezone Dear Mt4 Nelson 1 have reviewed the draft BIR for the above referenced rezone andi'\'ould add the following remarks regarding the arclYaeological. potential of the area finder consideration- Although the sub- ject property has not been systematically surveyed by archae6- logisknowntto exist, historicrded and there. ostculturallys gni ficant lonare e prehistoric ali.ties within the rezone area represent the villages, camp sites, and task areas of the Maidu Indian people and their prodeces- sort who ;held the property for 4000 or mono years prior to the coming of the white man. tither sites include those with great religious and social significance to the lndiah people living in the region today and the areas or mining activities which `ti\ contain important information pertaifting to the Gold Rush era ' in 8utte Countyi All of these sites are important in. their \, own right as they represent a segment o,i California's cultural heritage and are finite, nonrenewable ;sources_. They take on added 'signi.f;i.cance because the,,','waters of Lake Urovi.l.l.e already have destroyed a major pa,�t�df the rogion's historic and prehistoric 'values,' Unless proper mitigation measufoL.;'are in§bituted the cultural resources within the rezone area All be irreparably damaged or de5tro ed by land development projects ects aria the increased aessto jwhich �andh'settlementyo��camnewl.ys increased population. vandalism 1 / • opened region i The first 'step toward proper mitigation should be a complete i.rnv(-.ntory of the cultural resources on the property under cons,'ideration. Nwtt, the significance of each 'recorded site should be determined.by a qualified professional archaeologist and/or historian. Then protective measures should be ci,osen carriedAnd t. All signif3l caret sites could be placed i.`,1 a t� resourceconb,.bevation gone established for their continuec,h �nvtranmen�ai �t.�r(►vi, bipt Tel (016) 895 ,6109 JUN gee 10$ SOCIETY FOR CALIFORNIA ARCHAEOLOGY District 2 Clearinghouse r, Mr, Earl, Nelsen, page two IV'er June 25, 157$ proted4-ion. If this is unfeasible,' the rezoning of the property should maximize parcel size with 15 to 20 acre parcel minimums'. Two and 5 acre parcel sizes are too small, to offer protection to cultural. resources while the larger sizes would allow home construction, a,cce;�,s roads, utilities, etc..and still :avoid disturbance of significant historic and prehistoric sites. An archaeological °easement agreement, which has been used successfully in Butte County to, -protect cultural resources, should be a condition of approval for any parcel map involving historic or prehistoric sites in the Craig-1400retowh Rezone area. Sincerely, n 4 Keith L Lloh-son Coordinator District 2 Clearingho"se cc E John Luvaaa To )116) 605.610 n.- el , Xl �7 (b) The Review Environmental i � w Lirector�ls rlosponse to ,thp letter..' from the Society for Califov ia. Archo.(_jology. ,, 1 The archaeological and historical sensitiv.�y'and importance of this area is, acknowledged. Please ref or to the previous comments ahu) responses contained ''in this Appendik � reg�d ,,^di:ng f this subject (III (b) The Environmental Review Direct�?.ri e response to the letter from the Calif ornu;,o,, Department,, of Parks (r and Recreation, Office of Historic P'r- 'eserlra bion;). A complete�_,l inventory of the subject 'land area is noir considered necessary at this rezone level since specificland division and'Jto de velopment proposals would require a site inventory for possible z, archaeological and. historical[ ,resources at the time of permit appli�.atidn. Mitigation measures cannot be .applied to rezone proposals`to' alleviate or reduce environme'ntal 'impacts. They can, only be attached to actual development or i1afta divi8iontiiproposals. The only consideration at this time is alternative zonings which could protect archaeologiWal resources with larger mini- mum parcel sizes. The Conservation. consider.,At,.,on of Resource �` � vation. zonir,., l,argex minimum parcel z ping, and °archaeological easem r,nt agreement'' as- conditions of future parcel. map ��Pvovals where historic or prehistoric sites exist are recommendations to be noted and 17, ,considered. t 1 ,/9 7 M71 CdJv?Y I i?D OF SUI)�W[S4U6 17/ &L COCIL <= 00,111 .k6 6.4 X 7470 F. F ST�4i? r?T 0 -01/IC ,� 9S9�5 A"lo S-17 rLMS CO.IV,S1VI NIS i"F0IMAL S VSC i0 C��i?T,6IN r?T,IQVS OF 71r6 D'V6 1978 641111 OVA64,7AL IAY-P�7 X)6�'712i T FOi? M6 CPAI�a.11l,?6TaPN O kimw B &r -i6 cmiw 6NVl1'OW tY17AL VI(fP u2T NT ail 72IPAL COCIL,CO� I IS6D OF LcC)4t IYAIL P601S, & ' AT& kvid 6'C 771IS %�W, 45 CM6 fWS V16 OF INDIAV lPRA MO WS#6S 70'7,,W6 .ISS06 WN 71/06 rte' 71OVS ? MT,INg j�lO !iY%JZ,4VS OF TPIS �fA. M WSN IS 70 1606 6 % lAt 71,)6 8!11-16 CO_'!N Y ON10 OF Strr'61VISOU A V6 INS FWA; AU CO►C&'WfD fl'l7��S �Fo AA l/6 Rry Lfgslau,%f 7116 PPO-OS6D C I.(1-11 ON MZ 23 OF M6 i fins t LJ.�b'L 2 r,, IST l ?ICAL. Ji l h'l1 r y � inib i`s M6 CS L , " , . , . C� T1161P Mil)Ie6 70 W6 ikS60 FCIV 4w NIU ALIAS T716M 06S IN T716 MONI1:L S(�ZT:IOVS, t, TNN f«' P/ OF 7716 A4776P IS MAT A'� ,414 MW I1UMVL 69 ' IiV T7r FUNILIS >4 OF �,�I'/kl d 0��1.��5 LIV.Ih'C C �W IN 7/16 CMIr-'ZM,, O;UN; ACr M6;% Af >itiN&N -FIV, , 101,4V FAVU S IPI T IV ,T1r6 AVS Z *L M AM 6I97r POSOVS4 j JUL. 26 1978 ri l ON �.(1-6 Y4 OF 7116 k7JR7 UN452, W CAtOLrICAL r Satr S SO,N NSD TNAT IN 7176 C24I9 krl W61'?f Ai� 'MR1 T(ZN ma ;S; OVI�?SS_ SIT DZ?(J�T INF®RMATIGV 1-�7i M L6 AL 1AMAY'608-6 1AIDIC,4i�S 711,4T CVC OF T116 ', INCI ML 'W' D POST 601 rN11Wi f)14k A5 OF FOr?r�6R � INDIN #A817AMV IS IN T716 C291G,4. P6LIM1.6 S _' f ' S F`lw 711tc 72A01T. UO-k INIMO COi}rfiY YRY IN W6 COO TOLL US RA 7I1(Tl\& l(ei P;4ly 71116S P16 FIqPf,� OF FallMffN SI16S,M RAT y AOS; SIDS A/'� kh%V TO V61W F6P CV 6A' MMS Sr R, IN&W 160rL6. 106A6` OF f)gnnTICUL* S RI ML '. SlWrICM65 r affD HIIV6 V61-Y/ LIM6 C&14,C6 OF Sn'avlAU�'' IN ,4��� � a`�Iiz/ THIS 15 CSr IALLV ?i U Or C nAT zc�V O;7 �Cll?ISL S1, S '. MlCt;f .IS A L(545701 f i IAL S176 A16111? 7I16 CSI -C'OJI P745 L i4' �N CO1''1'Ih'UAL USC FOR >I Tmla A vt) , yu 8NI LI AL ' INDI, V P6q�M. 61~64 IN ' 71 P 04,16PIbis way, 7IJ PI T r� 7'�ADILV STA, 7 s "711AT 0 ►)6OF 7#6 4�6tL M,f�1 N F�t7S IS 711W 7116W✓- Mg,"",RPY OF ''PA ua 1, X-CllltM rCAL SITCS X4 f 70,13,c MIND IN, il-H6 -r IN (IICI.USItt j lUG lUiSf 1 rO SM%c, T11A7 0V64LLt TNS 6. 1. R. A776W-Ylt�O TO �jl'V6,,4 MIR AW MY6Y TIVC T OV 7116 MA7T61 OF 'r1srOIC�LD A,�CrA�O .TICAL ?fMll Zs klvtkssiS MAT TVs A10017IOVk R 7716 TI A,6 O. 16,�ISI.OV AMINg OV `gr cml( ,` RO OF DIr,� , 701U XII - (b) The Env'ironment al Review direct'oto the r's response Butte Tribal Co�uzc l letter, Glen Watson, Oha_'rman. The additional a_r�.tormation �eoncer ing india�i cultural ;re- sources is noted, including the fact "that 25 indian �;amili-s ' currently .reside �n tie area, and that,numorous' cultural and arch 'eolagi al sites (recorded and unreco:Y ded sites) exibt ,in t}ie area: Also, the importance of the Craig areaas a principle and concentrated locale of former Indian habitation is ackrowl.edged' ' TJ �.s information is hereby made a ''part of � t dec�.s�.an and �n .is ElR and Zould be considered in 4rriving, at the proper ,i s • i achieving the most sound zoning for the area . G t Y i!J r i o PE"1` m', FULLER, RUSH, SCH06UNG 8 LuVAA5 A pgRTNL'RSHIP INC:.UDING PROFE55`IONAL v_:.ORPORATIONS JERGMe D. PE TkRs,I99t•i9S3 AfTORC'; YS AT LAW (1 o S TEI CPtICNE AREA>CODE 916 JL;�tld4s D.pEtFiS. IR, 4.14 '$ALCM STREET - p, P.O. 90X' 3509 342.359 «, bAVo R. FULLFR, INC• DAVID H. RUSH % CHICO, CALIFORNIA 95927 �J JOHN W, SCHOOLING.,ItIC, �1{ JOHN L,LUVAAS.JR, �� .t7,�'ly 24, 1978 Earl Nelson Ener�>.roizniental Re�a.ew Director County of Buy`t e y , 7 County Center Drive Orovi lle, CA :'15965 ate: Crag-MaoretoiHn`' lte.7oring and SIR i Dear Mr. Ne 18 on II „ c " The '" � ' " g 1 ��° � azz' m �ollowin f additiona t ' en�Es are suY�ini%;tted for , • i inclusion ift'the fi.na`L BIR oil this proposal. Th", cow_ents are,l :limited Eo tho, subject of GUTn� VOR SNTERPPXTING ENG2NE R1+NG._ 111�E5 i OF S'a%L's, wJh1ch is a �' blication of the IS I Conservation dery .ce of the, IU, S 0 .,Depart lent b�f A3rirul tures Tht+ following; l' Vage from,;this report' 1.s most appropriate. 1.. Page 20: Moderate Soil Limitation: "This degree of limitation car be overcome or modified by special pl.ann_: n,g, „ design, a�' maintenance.. I' Even.` where moderate limitations exist quiteis reza,ne area, the expense of overcoming them twill be ' .• sub8ta7` y p _ .xn, h: he alternat Lve 't�'ill be not to overcome the l�:mxtati perky owners, tial, both to the count and to the ro �' ons; with 7 i resulting ' iwatershed, streams; lakes, etc. _.,.2, I Page 21: "Sbvere soil limitation is the rating given soi lig, that have onef or more prope i.es unfavorable for the, rs,-ted use, such as steep slopes,. bedtock, near th�1 'surface , ...3'„ or ! l: jw boating strength. • This degree of limitation generally ,.r requiroa major soil reclamation, special design; or intensive maintenance, Some .of tljiese soil s, however, c�h be improved by reducin' or removing tl�e soil. featuie that la.mits use r but ,in :-Orlost situat orI8 it is i`tifficult-. and costly to alter -the soil or—) to design a s truc�tlak, re �o as to compensate for a severe degree,, bf limitatiori.11 3. -Page 21 "A` soil vated very severe has one or more features so uh9avorable for the rated lisp, that the limitation is Very diffa cult. and Opensi. y, • to overcome. ,_ " ReclR;iation would be a �l'` di f+nom le t g i i q. removed, extrema wxdtilt- re u rx the soil material to be rept ce, or c p ly modii �ic,d. VeI' shallow soils over hard „ rock.:. , for e.�a .p have vel,* sev li.mitationS fob,' houses �Rtll baseitents or far, C7k Syt SE'%n� e t1 j"J,1�5 1 . C) , 0 fi.P Earl Nelson July 24,:1978 Page Tj?" 4 - 4 a e 23 : Soil i l Limitation Ratings 'for SPt.i c Tank k,sor tion Fields:' 11 copy of this chart is enclosed, far your referencei Among other things it indicates a severe or very f severe degree of soil limitation for septic tank leach :fields,.,` with decomposed granitic soil," with a rapid percolation ra't-ej}, combined with "a caster table of less than 48 inches depth` and/or cl.�eptlz to hardtc tof less than 48 inches andd :lope more than 5 A13 oo' I ase factors c a in' - in t - he - Z -.-ie area to `create a severe eq ee, of soy l limitation for septic tank ;leach fields_. A ,Vast majority of tho, xez-ane area has slopas of more than 15%,,, granitic soils, : and w` ter,,'r t..able and/or depth to hard rock of " les,-, than 48 inches .�S Mo6t has Well. less than 24 inches of soili v I, t a.a to be noted +��atth�� suggestea reguxrement of 48 inches of" soil is. contrad,i'torywith this county's health Depart- ,"Aent standards of only 2 feet f or bevel ground xrt any event, there is almost no level gYound i�hvolved here, for which the leal.th Department admits even more soil is requ. rod, a. Page 24; ":Lt should, be noted that a cont,&'tn.ination hazard may exist if water supplies, streams, ponds, lakes, or water course's are Nearby and redeive`see,ta,Uje frc��; the ab:�orptioh �`', field. 6. Page `25: "A seasonal wateshould be at "least 4 feet below the bottom of the trelich at all times for 'ZI -Pis rated as having light liriiwation, further on p g,� 25 `xm- i 1 bts, f_ 1layers, LngonShould 4iesmorebelot,thebottonofthetilo treAchflobr"Thissugge i that aoil depth-.rf even more than 4 feet should be required, since the trench itself, uses aepti W an a i a n ecessar I adequate soil cower M''permi.ts unfiltered S2c>yage to 'travel long` Page 25 Creviced or fractured rock without an `i di8tancos ,through old or nese aquifers, as in. deeply cracked limottone. At least 4 feet of hiode,t:ately course be finer: tex" tured soil material should be between the bottom of the ,Ule trenches and such ruck." " Pis indicated in the )EIRe water flowsl` through the soil Just below, the ground surface in this areae until. it loCate8 and kl bws=into deep fractures. 'these are `the source of water -in present wells`. Bince there is less than 'i!° feet o�- 80il in nearly all of th .s area, the water supply wilj.. be threatened by sewage. I N ,j Earl' Nel.s,on July 24t 1978 Page Three, Page ;, a �� Vxr cc $, Fa e 25 loam sand, course sand, and g5 materials. ,These s''&il materi< ong 4istances . ; RE,ttngs are nate "foie ,tabl c-5hould ar�n 71 _47 er - it C1 ;e textured ,soil materials .(course :l) are relatives oc,r r":ilterinq .permit unfiltered sewage to travel d on permeability cklone.,, A foot - Lt coni amination of, nearblr water granite, ana contaa.ns' or. I -s under:lain with course sand and grave-, poor' filter ;ng matser . �� s . Even if there were more th"ori 4 feet of soi'1 throug ,� itt�tYiis, urea (plus enough for the dept;; of the tiles) the soil is a puo3; ia,ttering ma:,erial anc,",xI a hazard' to nearby water exists. 'Since the entire area is watershed' for Ponderosa Reservoir and. Lake Qrovil.l a major, hazard is threatened) 9 Page 2 � �o�.ls w�.th lopes of less than Hai the be. }- ,mites for setaa�. e clzs osal Systems from the stands ointse p y , of �> cons rur:tion and suo�cesa ul op,erat:.on of at n fie d, MebTanl ar probRns ';w ayout all Construction, however, 1nEiredse t `� with steej nhessla9e. Lateral seepage e or down-s1.o e g ip flow is a ; especially psloping especially where bands of imp;(rmeable material occur, Within the"4 foot depth. Large rocks, bouldars, and rock outoropu `lncre�',se construction costs. The the grade is' „ cliff ioultto maintain it, the obstacle cannot be removed:" 11 �� I . l�ac;e ;25 r "D` terc encs in solution are readily trans-'' mitted through �=6 sc,ais\,and may contaminate ground water supplies." ll. Page g 30. Limitation R��inS��G;F for Shallot Exca- �s yations • V! e attached ^hlai,;t for shallow exca ,>ations ridicates that a seasonal, crater t,a1,,}le', above a dep th of 36inches, as in t,, tis }� area, and/or slope. c� m,re than 15 + depth 'to bedrock o, Less than A ` inches, and C+rsr�y or gra,,relly`'deeomp�lsed granitic soils create a severe degree of soil limitation for !��hal�OW ekcavations such as 1!�ta.ln would >>e required' here th level building sites. g a LimitatioillThe fsoilo tags limitations ;"b ;:or soil�� a season. � ,•;��th al (one month or more) water table above a depth of 2„0 inches j slope of more, ,than l5t depth to bedrock of 'less than 20inohes, arid' pos�- sibly with decomposed granite: This Creates a further sever6. jimi'-, ta,tiop for residential use of the` areae since the seasonal. wad rk� flow frequently is just below the ground ;5Urfac,�i and depth tv! ��o ire less thaninches han 7 {es area 1 ;� y51o��'e exceeds yc 15 et of 8 .� _ sof 5 to l5� th t a",noderafe de ee of j� imitat cin, g, ti , r 0, Y4 , Earl Nelson July 24, 1970 Page Four 13. Page 38; Soil Limitation, Ratings for Local Roads and Streets: Severe problems are created with S';lopes exceeding .15%xnd ° hartst isrdn 20, neo equiredt�odeterm ne�),whetherg�6:�ea iticSoilsci atefmoil�;' limitation. A moderate degree ;bf limitateion exists .evenwith slopes of Ei to '/15% and 20 to 40 irichesK.,of soil.. See; thy„attached chart. - p 14. Page 39:°"Ef,fort is made in, designing and constructing roads to have the volume of filr matPxial equal, withintshort dis- tances, to the volume "of mate`r'ial taker from Cuts. Much of the road fill, therefore, come from nearby cuts if material is suit- �'' able. Where cuts "do. not yield enough mater sl for' local embankments, the fill material is obtained `from bbirrow,�, pew".a lat much greater s ►� expense , Furthev from page s9: If the;. thickhLoss of" sulta!Ae materiels is less than 3 feet ,,because of sha1.].owi depth to bedrock or to other, unsuited or noorlyy suited _material i the -;whole. soil i,s- �] CrIV4 n . a rating of soot, tega Bless of the, aual:i ty� of the ittatgrial. less than 3 feet thick. This limitation applies � rezone area, so road-onstructon _r�r realignment nese y all 'of lim � - n ap� r � �Ithe�� r twill •be ° extrome� %f ly difficult, expensive, and require ,,hzuling horn and creation of barrow pigs. Creating such borrow pits may itself create significant environmental impacts, riot addres.6,e i'r7 the ErR. 15: See also the attached copy of sample table D, which summarizes the degree and kind of, limitation for various soils, n YnC� i Yig the decomposed granite of this area,, A complete copy of the Guide ,for lnterp'etirhg Engineering Uses of Soila'was submitted by us to the Environmental Review ; Director within the 30 day comment period. The enclo"8ed summary, �-oald not be submitted within that tame, because of the date when the above document was obtained. This summary is submitted so that a d6ndise analysis may be inciuded in the tit j wi:thotit the riecessirty of including the complete document. a Yours very truly j n - PExEI25C�LLEit �t�Tei#, SCHOO & .I VAAS i AZ'i Zbt ttj\t R. rA torneysv or rezone area resident. o. q - JA 1/ Class limit6 are the same as those suggested b;4'the Wotk--Planning Conferehce of the national Cooperative Soil Survey , jThe limitation ra�.'inge should be related to the permeability o soil. layers4l t and below depth of rt, the the line. 1` 2/ Indicate, by foothate there pollution -�s a hazard to dater,supplied. In arid ter semiarid areas, soils with madetately slow permeability may`have a Iimitatiph rating of nmdetUte. r; 4/ Bd4ed -on th ,. a absusdpt'ion that filo is, at, a depth of 2 feet:: ,. $J For class de- nition's .see szi.3 �s PP , 1 u Degree of soil limitation item affezt,ing Lee . � Sl ght i Moderate' Severe n Pe eabilit class -1/ rm y Ra id2/► p ewer end Moderately moderately of moderate s1ow3/ and e, rapid, and el"a.�, f l 0 upper end 'moderate of Hydraillic condtictivity , ',Mote than 1-0,6 -1n. /hr Less than rate - l din.hr2/ 0.6 In. /,4r (Uhlan'd cote method) Perculatioh ra%:A Faster than. 45-60 min/in. Slower than Auger hole me`,,,od) 45 min/in.2/ 60 min/in, Depth to hater table„ - More 'than 48-72 in. Less thea 0 72 in. " 48 in. Flooding `; �i None Occasional or fieq,4ent S�Iope 1,,� 0-8 p M 8-15 pct Mote than ` 15 pet p'�kh: to hard rock,4/ More than 48-12 in. Less than bedrock, orllother 72 in,,. 48 in. itipervidus mr terials x-- Stohihess classy/ n and 1 2 8, 4, and 5 Rockiness class/ -�0 1 2, 3, 4, (I ti and 5 JA 1/ Class limit6 are the same as those suggested b;4'the Wotk--Planning Conferehce of the national Cooperative Soil Survey , jThe limitation ra�.'inge should be related to the permeability o soil. layers4l t and below depth of rt, the the line. 1` 2/ Indicate, by foothate there pollution -�s a hazard to dater,supplied. In arid ter semiarid areas, soils with madetately slow permeability may`have a Iimitatiph rating of nmdetUte. r; 4/ Bd4ed -on th ,. a absusdpt'ion that filo is, at, a depth of 2 feet:: ,. $J For class de- nition's .see szi.3 �s PP , 1 u 4 e, JA 1/ Class limit6 are the same as those suggested b;4'the Wotk--Planning Conferehce of the national Cooperative Soil Survey , jThe limitation ra�.'inge should be related to the permeability o soil. layers4l t and below depth of rt, the the line. 1` 2/ Indicate, by foothate there pollution -�s a hazard to dater,supplied. In arid ter semiarid areas, soils with madetately slow permeability may`have a Iimitatiph rating of nmdetUte. r; 4/ Bd4ed -on th ,. a absusdpt'ion that filo is, at, a depth of 2 feet:: ,. $J For class de- nition's .see szi.3 �s PP , 1 u v ,+ 30lo- - excav ons • 4vyshallow 5 rSo' j 4, ratio s for �y iL scion iu► Gr uide Sheet egree of soil limitation° o f�£ectit& use Moderate Iev tem Slight Somewhat. paorlY ned, poorly r�orlexat drain ral ly ;! well dXaii�ed �. 'Indy gxcessively' drams ��anage class drained., some- yery poQr1Y' cessi Y Soil � st ��� and a lwha, 1' draine•d , .,, drain► ; drained depth Well ove I B de» hs I Bet wee SO ow a�d th 30 60 t l of R tl of n !i n��: 17 tin . t1n t P • t r' AY n Jkare ��r; ,frequent '�. None Floodins t�a�xs than '15 6_15 pct pct��;i Q-S pct,.:,� 4 j si , Slope �__�---- sl, � gi1,_ s3=j � r� �� i c► �o � ot�a�t3.c s fsl� all g llis; all b£ sail to sicl, scl types ravelly Texture very, g pth t4 be p ,, t es e�oavatedll �y�� � , Less than 40 60 yin. n` than 60 5 % 'More ,• Depth to' be 34�_ .and 5 2 and 5 gtoniness alassb-� 0 and 1 2, 3, 4+ 0 -'"` --- �tat�ility sidewall S „' ltocltineas class index to work�«3•litY and ( , here as an aterial difficult E used oY other m 11 Texture is �, an, duripai�, , the liraitetioh.. «acing ,? , if sail contaihs a tt7ick frith handtoolaan. inc«ease" ,r impossible) to excavate �' to o3 ht ut not imp t is g!��: =• sting .-- -- �' f y one stFsp loess, «educe « t cuts)like unless i . deduce 3 j if soil stetiaa in Verticil kaol.i►itie Paleudults is fYat?le, as are some 4j If the eo•ll with otcl na to ._ Aa atd be dug out s ofi � a1 e t`ating oar};`ate: r h so that it can tedute Xatlns s soft enoug back h6es� mo e if bed'rbak stack as 5%equip menk, ,. hatidtoels o't light one step pp 21��223; �.� and sev� by NTaniial, b l Vo't al"assefiti�ition3 sea foil Stix�e ;i u