Paradise City Council
June 14, 2022

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TOWN OF PARADISE HOUSING ELEMENT 38
paper surveys, implementation of revised survey questions to follow HUD guidelines (e.g., chronic homeless, domestic violence), planned targeting of encampment sites, and broad participation from the community.

The 2019 PIT Survey identified 1,551 homeless households countywide. Of these, 201 households resided in Emergency Shelter, 65 in Transitional Housing, 397 in FEMA housing, and 888 were unsheltered. Despite these efforts to improve the accuracy of the survey, the actual number of homeless individuals is estimated to be higher than PIT Survey results due to ongoing challenges in locating homeless individuals, especially those who are displaced and unhoused due to the Camp Fire.

Of the 891 unsheltered individuals, 2 percent had slept in the Town of Paradise the night prior to the count (see Figure 26).

Figure 26: Unsheltered Point-in-Time (PIT) Count in Butte County Universe: Population experiencing homelessness
Notes: This data is based on Point-in-Time (PIT) information provided to HUD by CoCs in the application for CoC Homeless Assistance Programs. The PIT Count provides a count of sheltered and unsheltered homeless persons on a single night during the last ten days in January.

Source: Butte Countywide Homeless Continuum of Care.

In Butte County, the most common type of household experiencing homelessness is those without children in their care. Among households experiencing homelessness that do not have children, 73 percent are unsheltered. Of homeless households with children, most are sheltered in transitional housing or emergency shelter (see Figure 27).
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Figure 27: Homelessness by Household Type and Shelter Status, Chico, Paradise/Butte County
Universe: Population experiencing homelessness
Notes: This data is based on Point-in-Time (PIT) information provided to HUD by CoCs in the application for CoC Homeless Assistance Programs. The PIT Count provides a count of sheltered and unsheltered homeless persons on a single night during the last ten days in January.

Source: U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations Reports (2019).

For the data table behind this figure, please refer to the Data Packet Workbook, Table HOMELS-01.

People of color are more likely to experience poverty and financial instability as a result of federal and local housing policies that have historically excluded them from the same opportunities extended to white residents. Consequently, people of color are often disproportionately impacted by homelessness.

In Butte County, American Indian or Alaska Native (Hispanic and Non-Hispanic) make up 6 percent of the homeless population, while making up only 1 percent of the overall population. Similarly, Black or African American (Hispanic or Non-Hispanic) residents make up 6 percent of the homeless population, while making up only 2 percent of the overall population (see Figure 28). 18%
43%
20%
9%
48%
8%
73%
9%
73%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
People in Households
Composed Solely of
Children Under 18
People in Households
with Adults and Children
People in Households
without Children Under 18
Sheltered - Emergency Shelter Sheltered - Transitional Housing Unsheltered
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Figure 28: Racial Group Share of General and Homeless Populations, Butte County Universe: Population experiencing homelessness
Notes: This data is based on Point-in-Time (PIT) information provided to HUD by CoCs in the application for CoC Homeless Assistance Programs. The PIT Count provides a count of sheltered and unsheltered homeless persons on a single night during the last ten days in January. HUD does not disaggregate racial demographic data by Hispanic/Latinx ethnicity for people experiencing homelessness. Instead, HUD reports data on Hispanic/Latinx ethnicity for people experiencing homelessness in a separate table. Accordingly, the racial group data listed here includes both Hispanic/Latinx and non-Hispanic/Latinx individuals.

Source: U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations Reports (2019); U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B01001(A-I).

For the data table behind this figure, please refer to the Data Packet Workbook, Table HOMELS-02.

In Butte County, Latinx residents represent 13 percent of the population experiencing homelessness, while Latinx residents comprise 16 percent of the general population (see Figure 29). 80%
6%
0%
6% 7%
82%
1%
5% 2%
11%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
White (Hispanic
and NonHispanic)
American
Indian or Alaska
Native (Hispanic
and NonHispanic)
Asian / API
(Hispanic and
Non-Hispanic)
Black or African
American
(Hispanic and
Non-Hispanic)
Other Race or
Multiple Races
(Hispanic and
Non-Hispanic)
Percent of Population
Share of Homeless Population Share of Overall Population 268

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Figure 29: Latinx Share of General and Homeless Populations, Butte County Universe: Population experiencing homelessness
Notes: This data is based on Point-in-Time (PIT) information provided to HUD by CoCs in the application for CoC Homeless Assistance Programs. The PIT Count provides a count of sheltered and unsheltered homeless persons on a single night during the last ten days in January. The data from HUD on Hispanic/Latinx ethnicity for individuals experiencing homelessness does not specify racial group identity. Accordingly, individuals in either ethnic group identity category (Hispanic/Latinx or nonHispanic/Latinx) could be of any racial background.

Source: U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations Reports (2019); U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B01001(A-I).

For the data table behind this figure, please refer to the Data Packet Workbook, Table HOMELS-03.

Many of those experiencing homelessness are dealing with severe issues – including mental illness, substance abuse and domestic violence – that are potentially life threatening and require additional assistance. In Butte County, homeless individuals are commonly challenged by severe mental illness, with 282 reporting this condition (see Figure 30). Of those, some 67 percent are unsheltered, further adding to the challenge of handling the issue.
13%
87%
16%
84%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Hispanic/Latinx Non-Hispanic/Latinx
Percent of Population
Share of Homeless Population Share of Overall Population 269

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Figure 30: Characteristics for the Population Experiencing Homelessness, Butte County Universe: Population experiencing homelessness
Notes: This data is based on Point-in-Time (PIT) information provided to HUD by CoCs in the application for CoC Homeless Assistance Programs. The PIT Count provides a count of sheltered and unsheltered homeless persons on a single night during the last ten days in January. Per HCD’s requirements, jurisdictions will need to supplement this county-level data with local estimates of people experiencing homelessness. These challenges/characteristics are counted separately and are not mutually exclusive, as an individual may report more than one challenge/characteristic. These counts should not be summed.

Source: U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations Reports (2019).

For the data table behind this figure, please refer to the Data Packet Workbook, Table HOMELS-04.

In Paradise, there were 353 reported
students experiencing homelessness
in the 2019-20 school year, a 110
percent increase from 2017-18 before
the fire (see Table 3). By comparison,
Butte County has seen a 50 percent
increase in the population of students
experiencing homelessness in the
same time frame, adding undue
burdens on learning and thriving, with
the potential for longer term negative
effects. As defined by the Department
of Education, students are
experiencing homelessness if they are
unsheltered, living in temporary
shelters for people experiencing
homelessness, living in hotels/motels,
or temporarily doubled up and sharing
the housing of other persons due to
the loss of housing or economic hardship.
188
66 28
106
40 30
65 14 7
63 10 7 6 1 3
0 50
100
150
200
Unsheltered Sheltered - Emergency
Shelter
Sheltered - Transitional
Housing
Severely Mentally Ill Chronic Substance Abuse
Veterans Victims of Domestic Violence

HIV/AIDS
TABLE 3: STUDENTS IN LOCAL PUBLIC SCHOOLS EXPERIENCING

HOMELESSNESS
Academic Year Town of Paradise Butte County
2016-17 142 799
2017-18 168 882
2018-19 10 738
2019-20 353 1,314
Universe: Total number of unduplicated primary and short-term enrollments within the academic year (July 1 to June 30), public schools
Notes: The California Department of Education considers students to be homeless if they are unsheltered, living in temporary shelters for people experiencing homelessness, living in hotels/motels, or temporarily doubled up and sharing the housing of other persons due to the loss of housing or economic hardship. The data used for this table was obtained at the school site level, matched to a file containing school locations, geocoded and assigned to jurisdiction, and finally summarized by geography.

Source: California Department of Education, California Longitudinal Pupil Achievement Data System (CALPADS), Cumulative Enrollment Data (Academic Years 2016-2017, 2017-2018, 2018-2019, 2019-2020).

This table is included in the Data Packet Workbook as Table HOMELS-05. 270

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TOWN OF PARADISE HOUSING ELEMENT 43
Finally, an analysis of mobile home park locations can help to identify disproportionate housing needs including displacement risk. According to HCD, people residing in mobile homes, residential trailers, or recreational vehicles (RVs) are the most vulnerable residential population to natural disasters including flooding. Emergency preparedness, response, and evacuation therefore calls for an inventory of mobile home park locations. Figure 31 shows locations that represent mobile home, residential trailer, and recreational vehicle (RV) parks in Butte County. Mobile home parks are generally concentrated in the communities of Chico, Paradise/Magalia, and Oroville/Thermalito/Palermo, with some mobile home parks located in less populated areas of the county. This map shows data from 2018 which is also the year of the 2018 Camp Fire in eastern Butte County. Many of the mobile home parks located in Paradise and Magalia were destroyed or damaged in the fire, with residents displaced to other housing units or communities according to the Homeland Infrastructure Foundation Level Data database.

LOCAL DATA AND KNOWLEDGE
Local data and knowledge from a variety of sources centers on the impacts of the 2018 Camp Fire on disproportionate housing needs and displacement risk in the Town of Paradise.

Prior to the 2018 Camp Fire, Paradise had more women, seniors, disabled and veterans than any other local jurisdiction, as well as the State or Country as a whole. In 2010, Paradise was home to approximately 13,765 women (52.5 percent of the population), 6,580 seniors (25.1 percent), 4,615 disabled persons (17.6 percent), and 2,600 veterans (9.9 percent). These populations represent protected classes under federal anti-discrimination law and are considered to be more vulnerable.

Perhaps due to the larger number of elderly and disabled, at this time the overall labor force as a percent of population (49.9 percent) was notably lower than that of the County (55.6 percent), the State (63.1 percent) or nation (63.3 percent). However, the Town did have the highest median household income ($44,923) in the County, above Chico ($42,342) and the County as a whole ($43,444) but considerably lower than the State ($61,818) and US ($53,889). Interestingly, the per capita income ($25,427), also the highest in the County, was closer to that of the State ($30,318) and US ($28,930).

Although in 2010 the Town had the lowest percent of persons living in poverty (16.0 percent) within the County, that percent was still higher than that of the State (15.3 percent) and US (13.5 percent) at the time.

Through discussions and through relying on alternative data collected by Next 10 and UC Berkeley’s Center for Community Innovation, it was revealed that seniors, low-income households, and renters were disproportionately affected and displaced by the Camp Fire, and that many people are eager to come back to Paradise and miss their home. This sentiment was expressed especially through interviews with CVI, a non-profit organization dedicated to providing residential and vocational support to developmentally disabled adults. CVI representatives shared that they often hear “I want to go back home.” However, there are few units to come back to after the fire’s destruction. CVI clients do not understand this. In addition to the lack of housing, the presence of services, especially medical services, is one issue impacting if or when past residents with a developmental disability may return. 271

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Figure 31: Butte County, Mobile Home Parks Map, 2018
Source: HCD AFFH Data Resources and Mapping Tool: 2018 Homeland Infrastructure Foundation Level Data database 272

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TOWN OF PARADISE HOUSING ELEMENT 45
As discussed in the Paradise Safety Element, Paradise is at very high risk for future wildfire. Research has shown that renters, and especially low-income renters, are often disproportionately exposed to environmental hazards and housing tenure is a decisive factor in a society’s vulnerability to disaster.5 Housing tenure is such an important factor in disaster recovery because renters do not control the housing units in which they live. According to HCD, “renters bear the brunt of the existing affordable housing shortage, and their adaptive capacity to cope and recover from the impacts of environmental hazards may be reduced due to systemic inequities and limited resources.” Renters are more likely to be displaced post-disaster because they do not determine if or when their housing unit will be rebuilt, there are fewer financial resources to rebuild rental housing than for homeowners, and renters are more likely to live in multi-family buildings that can take longer to rebuild post-disaster than a singlefamily home. Furthermore, renters do not control vegetation management and other fire risk reduction measures, or the ability to add resilience investments on the property where they live. Finally, rental prices increase as rental housing supply decrease.

Indeed, nearly all rental housing was destroyed in the fire. According to data from Urban Footprint, approximately 75 percent of parcels developed with multi-family housing and approximately 88 percent of all multi-family dwelling units were destroyed in the fire. The destruction included some of the Town’s only deed-restricted affordable housing projects. One affordable project, Paradise Gardens III, is prioritized to be rebuilt and is expected to be completed in the next few years and another, Paradise Community Village, is actively under reconstruction. The Cypress Acres Convalescent Hospital, however, is the third project in the town with federal assistance that was destroyed, and it is not anticipated to rebuild. The Town has issued a certificate of occupancy for 242 units in multi-family buildings since the Camp Fire, all of which are rental housing units.6 These 242 units represent approximately 32 percent of the approximately 750 multi-family units lost in the fire, according to data from Urban Footprint.

In addition to the availability of housing that is affordable, the lower incomes of the residents of Paradise ($49,270), when compared to the average Californian ($71,228), have implications regarding where those displaced by the Camp Fire will be able to relocate.7 If the cost of rebuilding is too high, former Paradise residents may permanently move out of the state in search of cheaper housing options.

Whereas much of California faces displacement due to increasing housing prices, the situation in Paradise is unique because displacement took on a new meaning after the 2018 Camp Fire when most residents lost a home, place of work, and/or the same sense of community with such a large population loss. When individuals or families are forced to leave their homes and communities, they also lose their support network. Displacement has the most severe impacts on low- and moderate-income residents who had less savings to fall back on during the crisis. A report written by Next 10 and UC Berkeley’s Center for Community Innovation, Rebuilding for a Resilient Recovery: Planning in California’s Wildland 5 Lee & Van Zandt, 2018. Social Vulnerability to Disasters: A Review of the Evidence. 6 Hartman, Susan, Community Development Director, Town of Paradise. 2021. Personal communication with Urban Planning Partners. October 26. Updated based on permit counts as of December 29, 2021. 7 Perry, Noel et al., 2021. “Rebuilding for a Resilient Recovery: Planning in California's Wildland Urban Interface.” Next10 and Center for Community Innovation. UC Berkeley. Retrieved from: https://www.next10.org/sites/default/ files/2021-06/Next10-Rebuilding-Resilient.pdf.
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Urban Interface, included Paradise as a case study and revealed important information on who was most affected by the fire:
 Before the fire, Paradise had a large population of retirees — 35 percent of residents were over 60 years old, and 7 percent were over 80 years old. Nearly 85 percent of those who perished in the fire.  The Camp Fire displaced 13,314 households, and of those, 43 percent (5,679 households) had moved to a new census tract by 2019. Of those who moved census tracts, 38 percent (2,148 households) were senior-led households. Low-income households represented 41 percent of households that relocated, compared to 50 percent of households that stayed, indicating that lower-income households were less likely to move.
 While 34 percent of all households affected by the 2018 Camp Fire were renters, 40 percent of households that moved were renters. The average household income of households that moved was $54,153, higher than $49,974 for the households that did not move.

The report also revealed that most of those displaced from Paradise lived in their homes for generations and were more likely to live in a single-family home and own their home than else in California. Before the Camp Fire, approximately 70 percent of residents owned their homes, higher than the 55 percent homeownership rate statewide. The median home value of $218,400 was nearly half the average home value in California, which is $475,900. The lower incomes of the residents of Paradise ($49,270), when compared to the average Californian ($71,228) imply that many lived in Paradise due to the relatively lower housing costs, and with the high levels of destruction, low-income families may choose to permanently move out of the state in search of cheaper housing options elsewhere. These findings suggest that lower-income residents may not have the resources to relocate as easily as their higher-income peers, especially lower-income homeowners. Renters, seniors, and lowincome households are special populations to consider when designing policies and programs to address displacement.

OTHER RELEVANT FACTORS
Butte County Department of Employment and Social Services (Butte County DESS) administers employment and social services to Butte County residents. Butte County DESS provided its “Camp Fire Relief Grant Final Report, January 2019 through July 2021” for use in the City of Chico’s Housing Element on October 5, 2021 via email correspondence to the City, which is included in the Town of Paradise’s Housing Element as well due to its relevance. In January 2019, North Valley Community Foundation provided a one-million-dollar grant to Butte County DESS to assist 2018 Camp Fire survivors with housing, mental health, and replacing belongings. Table 4 depicts the dollar amount of assistance provided to Camp Fire survivors by assistance type. Vehicles and RVs, home repairs/rebuilds, rent and mortgage, and vehicle items/RV repair were the assistance types with the largest amount of assistance provided in dollars. These findings illustrate that both temporary and permanent housing was a significant need following the Camp Fire.
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TABLE 4: BUTTE COUNTY DEPARTMENT OF EMPLOYMENT AND SOCIAL SERVICES,

FINANCIAL ASSISTANCE PROVIDED TO CAMP FIRE SURVIVORS TABLE, JANUARY 2019 TO JULY 2021
Assistance Type
Total Assistance Provided
(in Dollars)
Vehicles and RVs $289,978
Home Repairs/Rebuilds $214,806
Rent and Mortgage $170,031
Vehicle Items/RV Repair $165,540
Property Replacement $69,747
Shelter $55,166
Utilities $12,703
Deliveries $11,716
Miscellaneous $10,192
Total $999,968.70
Source: Butte County Department of Employment and Social Services, Camp Fire Relief Grant Final Report, January 2019 to July 2021.

Butte-Glenn 211 is an information and referral non-profit agency serving Butte and Glenn counties by connecting people in need with services that offer help. Table 5 depicts information on the number of Camp Fire contacts and referred services in Butte-Glenn 211’s database system. From the time period of November 1, 2018 to October 31, 2021, the number of referred services to Camp Fire contacts who contacted Butte-Glenn 211 by phone from Butte County was 27,134. The total number of Camp Fire contacts to Butte-Glenn 211 originating from Butte County was 23,832 and the total number of Camp Fire contacts from all counties and states was 34,892 (Butte-Glenn 211, November 2021 Email Correspondence). This data illustrates the magnitude of the impact of the Camp Fire on Butte County residents. Over 30,000 people contacted Butte-Glenn 211 for assistance during and after the Camp Fire, and Butte-Glenn 211 referred over 25,000 services to Camp Fire phone callers contacts from Butte County.

TABLE 5: BUTTE-GLENN 211, CAMP FIRE CONTACTS AND REFERRED SERVICES DATA TABLE, NOVEMBER 2018 TO OCTOBER 2021
Time Period
Number of
Referred Services
to Camp Fire
Phone Caller
Contacts
Originating from
Butte County
Total Number of
Camp Fire
Contacts
Originating from
Butte County
Total Number of
Camp Fire
Contacts to 211
(all
counties/states)
November 1, 2018 to October 31, 2021 27,134 23,832 34,892 Source: Butte-Glenn 211, City of Chico’s Housing Element. 275

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3CONCLUSIONS AND SUMMARY OF ISSUES
In conclusion, the Town is paying close attention to any disparities by race, income, and other characteristics throughout the rebuild process. The Town is aware that renters, large families, and lowincome households are experiencing more cost burden in their monthly housing costs, and that while there are not very many people of color living in the Town currently, Asian and Native Hawaiian or Other Pacific Islanders also appear to be facing higher degrees of cost burden. Helping people who have experienced displacement and homelessness, especially due to the Camp Fire, also remain a top priority for the Town. In Paradise, displacement took on a new meaning after the 2018 Camp Fire when most residents lost a home, place of work, and/or the same sense of community with such a large population loss. The large percentage of women, seniors, disabled persons, and veterans in the town prior to the Camp Fire has meant that these populations struggled disproportionately and will continue to need extra assistance throughout the rebuild process.

F. FAIR HOUSING ACTION PLAN
Due to all the forces and findings described above, it is important that the Town of Paradise prioritize rebuilding rental housing and providing financial assistance for renters to return to the community and to facilitate integrated living patterns as old residents return and new residents arrive. The Town has several ongoing or upcoming planning efforts that present an opportunity to AFFH, including the sewer project, mastered ADU plans, SB 2 projects, the long-term community recovery plan, transportation master plan, and forthcoming General Plan update.

Chapter 6: Housing Element Goals, Policies and Programs describes the Town’s goals and efforts to rebuild, conserve existing stock and affordability, and provide adequate housing for all persons. This 2022-2030’s Housing Element goals, in tandem with the Safety Element, work to affirmatively further fair housing in Paradise. Specifically, the policies listed below seek to foster an inclusive community, further housing choice, and address racial and economic disparities by increasing the availability and diversity of housing, prioritizing multi-family housing in areas near services, enforcing fair housing laws, and establishing programs to house special needs groups (e.g., seniors, individuals with disabilities, large families, the unhoused).
 HP-1. The Town will encourage a full range of housing types, including both lower- and higherdensity housing, at rents and sales prices suitable for a range of household incomes, including extremely low, very low, low, and moderate.
 HP-2. The General Plan will identify lands most suitable for multi-family development and safeguard this type of use on these sites.
 HP-6. The Town will encourage the production and availability of new affordable housing through a variety of measures including the density bonus program and second unit development, providing incentives such as expedited processing, relaxed zoning restrictions where appropriate, support for funding applications, and Community Development Block Grant (CDBG) funds when available.  HP-8. The Town will encourage providers to give priority to the very low- and low-income housing developments pursuant to Government Code Section 65589.7. The Town will also provide a copy of the 2022–2030 Housing Element to local water providers upon its adoption. Should a public sewer system, such as an off-site clustered system or alternative wastewater treatment system, be 276

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developed and made available, the Town will provide its operator with a copy of the Housing Element and encourage the operator to give priority to very low- and low-income housing developments pursuant to Government Code Section 65589.7.  HP-9. The Town will pursue county, State, and federal programs and funding sources that provide housing opportunities for low- and moderate-income households.  HP-10. In accordance with applicable federal and State laws, the Town will promote equal housing opportunities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, or color.
 HP-12. The Town will pursue the development of tiny home villages to be used as affordable housing.
 HP-15. The Town will design and implement housing programs that maximize access to the market, such as housing rehabilitation, including replacement housing, and down payment assistance for first-time homebuyers.
 HP-17. New housing and rehabilitated housing will be constructed in accordance with design standards and Town-adopted Building Code requirements that will ensure the safety and integrity of each housing unit.
 HP-18. The Town will continue to provide a revolving loan fund for housing rehabilitation and down payment assistance programs.
 HP-19. The Town will support the continuance and expansion of the Housing Authority’s rental assistance program.
 HP-20. The Town will regulate conversion of housing stock that, by its nature, is affordable to residents of modest means, such as apartments and mobile homes, to either market-rate, for-sale, or nonresidential uses, by requiring such conversions to provide a housing relocation plan and replacement assistance to residents who would be displaced by the conversion and by requiring that the Town make a finding of clear public benefit.
 HP-23. The Town will consider increased building and landscaping requirements for fire resiliency and add supportive programs to assist households with vegetation management. The Town will consider providing grants or no-interest loans to low-income households for home hardening to ensure the most vulnerable households are not left behind.  HP-28. The Town will support post-disaster funding for multi-family and affordable housing development.
 HP-29. The Town will continue to encourage the development and expansion of housing opportunities for the elderly and the disabled through techniques such as smaller unit sizes, a reduction in parking space requirements, common dining facilities, and fewer but adequate amenities.
 HP-30. The Town will encourage development of suitable sites with rest homes and care facilities for the elderly and the disabled and developmentally disabled and will encourage senior citizen housing in the Central Commercial area of Paradise.
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 HP-31. The Town will facilitate housing opportunities for the homeless by accommodating transitional and supportive housing and allowing emergency, transitional, and supportive housing consistent with state law.
 HP-32. The Town will encourage development housing types and programs for senior citizens, the disabled, developmentally disabled, large families, and other groups identified as having special housing needs.
 HP-33. The Town will continue to require the first floors of multi-family developments to accommodate access and use by the elderly and the disabled  HP-34. The Town will continue to assess the Zoning Ordinance, Municipal Code, and Town procedures for constraints and address changes in state law, particularly regarding housing for special needs groups, including seniors, the disabled, developmentally disabled, large families, farmworkers, and the homeless.

In addition to the policies above, the Town of Paradise will take the meaningful actions found in Table 6.

TABLE 6: FAIR HOUSING ACTION PLAN
Actions Fair Housing Issues Contributing Factors Implementation Action Area 1. Enhancing housing mobility strategies
Action 1.1: Incentivize the creation of ADUs to
provide housing that is affordable in higher
opportunity areas. If being used as a rental,
persons using the Town’s mastered ADU
plans would be required to affirmatively
market their ADU to populations with
disproportionate housing needs, including
persons with disabilities and female-headed
households. This would include sharing
information with community organizations
that serve these populations. The Town will
also affirmatively market the mastered ADU
plans to low-income households for wealthbuilding purposes.

Persons with disabilities
have disproportionate
housing needs and a lack
of affordable housing
stock. Renters were
disproportionately
displaced by the Camp
Fire.

Lack of affordable rental
housing; lack of
accessible affordable
units.

Objectives: Increase housing
mobility by generating wealth
for low-income homeowners
and by facilitating the
development of ADUs that are
affordable to lower-income
households in areas with
higher access to opportunity
Quantified Objectives: 12-15
ADUs created through the
mastered ADU plans and 30-
40 ADUs permitted during the
Housing Element cycle
Responsible Party: Housing
Services staff
Timeline: Ongoing
Action 1.2: Continue to disallow the
enforcement of Covenants, Conditions, and
Restrictions (CC&Rs) given their potential to
cause areas of affluence and exclusion.

Continue to allow all housing types (e.g., stick
built, modular, manufactured) in all
residentially zoned areas.

Concentrated areas of
poverty and/or
concentrated areas of
affluence can form when
housing types are
isolated and housing
mobility is constrained.

Across California and the
nation, racial segregation
has historically been
promulgated through
Homogeneous
population
Objectives: Increase housing
mobility by allowing singlefamily homes at different
prices points within the same
neighborhoods.

Quantified Objectives: 350
manufactured homes
permitted during the
planning period in
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TABLE 6: FAIR HOUSING ACTION PLAN
Actions Fair Housing Issues Contributing Factors Implementation CC&Rs. neighborhoods throughout
the town.

Responsible Party: Housing
Services staff
Timeline: Ongoing
Action Area 2. Encouraging new housing choices and affordability in high resource areas and outside of areas of concentrated poverty.

Action 2.1: Require affordable housing
developments be affirmatively marketed to
households with disproportionate housing
needs, including persons with disabilities and
female-headed households. This would
include sharing information with community
organizations that serve these populations,
such as legal service or public health
providers. All marketing plans would include
strategies to reach groups with
disproportionate housing needs.

Persons with disabilities
have disproportionate
housing needs and a lack
of affordable housing
stock. Neighborhoods
with greater portions of
non-White populations
(i.e., downtown) have
older housing stock.

Lack of affordable
housing and especially
affordable housing in
high opportunity areas;
Lack of accessible
affordable units.

Objectives: Encouraging new
housing choices and
affordability
Quantified Objectives:

Affordable housing projects
and available affordable units
are advertised to at least three
community organizations
Responsible Party: Housing
Services staff
Timeline: Ongoing. Marketing
plans are submitted at time of
building inspection.

Action 2.2: Allow residential care facilities for
seven or more person by-right in the sewer
service area. This will make it easier to
develop needed housing for special needs
populations and ensure that these facilities
are located in areas with access to
commercial services, near evacuation routes,
and with adequate sewer capacity.

Persons with disabilities
have disproportionate
housing needs and
housing for persons with
disabilities has not yet
been rebuilt to replace
units that were in
Paradise pre-fire.

Lack of accessible
affordable units; Lack of
access to economic
opportunity; Camp Fire.

Objectives: Encouraging new
housing choices and
affordability for populations
with special needs housing
Quantified Objectives:

Development of 80 housing
units for extremely- and very
low-income households in the
sewer service area.

Responsible Party: Planning
Department
Timeline: Amend Zoning
Ordinance by January 2025.

Action 2.3: Utilize zoning tools to facilitate the
construction of diverse housing types and a
mix of uses within the sewer service area. This
will increase access to opportunity by
increasing the number of people who live in
proximity to transit and services within the
sewer service area. Encouraging mixedincome housing and diverse housing types will continue to facilitate integrated living
patterns. Consistent with program HI-4, the
Town could use changes to its fee structure
and/or parking standard revisions to incentive
Paradise has constrained
access to jobs given its
rural nature. Reliance on
septic systems constrains
densities, creating
barriers for deedrestricted multi-family
housing units.

Lack of affordable units;
Lack of access to
economic opportunity;
infrastructure
constraints.

Objectives: Encouraging new
housing choices and
affordability
Quantified Objectives:

Development of 80 housing
units for extremely- and very
low-income households in
the sewer service area.

Construction of mixed-use
buildings in the sewer
service area.
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TOWN OF PARADISE HOUSING ELEMENT 52
TABLE 6: FAIR HOUSING ACTION PLAN
Actions Fair Housing Issues Contributing Factors Implementation active ground floor uses below residential
units.

Responsible Party: Planning
Division

Timeline: June 2024 for mixeduse incentives and January 2025 for rezoning parcels with
the Sewer Overlay Zone.

Action 2.4: Utilize an equity lens in the
upcoming General Plan update as well as the
ongoing implementation of the Long-Term
Community Recovery Plan. This includes
ensuring an equitable community
engagement process is implemented to
capture feedback from historically excluded
communities.

Upcoming planning
efforts and the rebuild
process present an
opportunity to ensure all
protected classes are
participating
The Town has
historically not been
very racially diverse, but
does have high
proportion of other
protected classes
Objectives: Encouraging new
housing choices and
affordability
Quantified Objectives:

Participation amongst people
of color and those in
protected classes increases 10
percent from the first
engagement activity to the last

Responsible Party: Planning
Department
Timeline: Ongoing between
2023-2025 during the General
Plan Update.

Action Area 3. Improving place-based strategies to encourage community conservation and revitalization including preservation of existing affordable housing.

Action 3.1: Continue to fund minor home
repairs for income-eligible households
through the owner-occupied rehab program.

Work with FEMA to establish a grant program
for home hardening retrofits.

Low-income households
need resources for
housing conservation.

The Camp Fire -
housing stock that
survived the fire are
scattered across town
and are not place
based. However, they
are in need of
community
conservation and
revitalization.

Objectives: Conserve and
improve assets in areas of
lower opportunity and
concentrated poverty.

Quantified Objectives:

Rehabilitation of 40 homes in
target neighborhoods.

Responsible Party: Housing
Division

Timeline: Conduct publicity
campaign for the program
once annually in addition to
hosting information on Town
website.

Action 3.2: Target accessibility upgrades in
areas with greatest need. Implement the
Transportation Master Plan (TMP) to prioritize
intersection improvements where ADA
upgrades are needed.

Persons with disabilities
face disproportionate
housing impacts.

Community wide lack of
sidewalks because of
rural nature of Town.

Objectives: Place-based
infrastructure improvements
to increase access for persons
with disability

Quantified Objectives: All
intersections are ADA
compliant
280

APPENDIX B
TOWN OF PARADISE HOUSING ELEMENT 53
TABLE 6: FAIR HOUSING ACTION PLAN
Actions Fair Housing Issues Contributing Factors Implementation

Responsible Party: Public
Works Department

Timeline: During public road
repaving project from August
2022 through 2025.

Action Area 4. Protecting existing residents from displacement Action 4.1: Through partnerships with the
Paradise Ridge and Butte County Fire Safe
Councils explore home hardening programs
that allow policyholders to lower their
insurance rates through home hardening,
vegetation management, or other risk
reduction measures. Implement an equitable
community engagement strategy and work
with key stakeholders to identify Wildfire Risk
Reduction Buffers to protect homes from the
areas with greatest fire risk.

All residents are at risk
of displacement from
climate hazards.

Impacts are greatest for
those who are already
underserved or
experiencing
disproportionate
housing impacts.

Wildfire risk Objectives: Protect residents
from future wildfire-related
displacement.

Responsible Party: Planning
Division and Fire Department

Timeline: . Meeting on Wildfire
Risk Reduction Buffers by
January 2023. Community
engagement plan on Wildfire
Risk Reduction Buffers by
August 2023.
281

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TOWN OF PARADISE HOUSING ELEMENT 54
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282
APPENDIX C: TOWN OF PARADISE

GENERAL PLAN DESIGNATIONS

AND ZONING DISTRICTS
283
284

APPENDIX C
TOWN OF PARADISE HOUSING ELEMENT 1

PARADISE GENERAL PLAN
The Paradise General Plan provides a range of residential building types and densities in various areas of Paradise. Densities range from a low of one unit or less per acre in the Agricultural-Residential designation to 15 units per acre in the Multi-Family designation. Below is a brief description of each General Plan residential land use designation.

AGRICULTURAL-RESIDENTIAL (A-R)
This designation applies to existing and planned residential areas characterized by larger parcels and accessory agricultural uses, including the raising of livestock and other forms of agricultural production.

It provides for single-family detached homes, limited agricultural uses, churches, and public uses.

Residential densities are in the range of one or less dwelling unit per gross acre. This designation is mainly applied to areas in the southern portion of town characterized by larger parcels and existing agricultural/residential land uses. The minimum lot area for this designation is 1 acre.

RURAL-RESIDENTIAL (R-R)
This designation applies to a substantial portion of existing and planned single-family rural residential areas in the town. It is characterized by moderately large parcels and residential densities that range from 1 to 2 dwelling units per acre. This designation provides for single-family detached homes and secondary residential units as well as accessory rural uses. It may also provide for churches and public uses.

TOWN-RESIDENTIAL (T-R)
This designation applies to existing residential areas characterized by small (0.5 gross acres or less) parcels and the absence of accessory rural uses, particularly the keeping of livestock. It provides for single-family detached and attached homes, mobile home parks, churches, and public uses. These designated areas may be served by a community sewer system if established. Residential densities are in the range of 1 to 3 dwelling units per gross acre. Mobile home parks with densities no greater than six dwelling units per gross acre may also be deemed consistent with this designation.

MULTI-FAMILY RESIDENTIAL (M-R)
This designation applies to existing and planned multiple-family residential areas. It provides for singleand multiple-family residential structures, mobile home parks, convalescent homes, residential care facilities, churches, and public uses. Planned multi-family residential areas shall be located in areas near existing or planned commercial uses, community service uses, and along designated arterial or collector streets. Depending on the presence and application of constraints, maximum potential residential densities up to 15 dwelling units per acre are allowed if served by an approved clustered wastewater treatment and disposal system. Mobile home parks with densities no greater than 8 dwelling units per gross acre may also be deemed consistent with this designation. 285

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2 TOWN OF PARADISE HOUSING ELEMENT

NEIGHBORHOOD-COMMERCIAL (N-C)
This designation applies to existing and planned neighborhood and locally oriented commercial retail and service uses. This designation is primarily applied to small sites adjacent to residential neighborhoods and along designated arterial or collector streets. Single-family residential structures, accessory dwelling units, convalescent homes, and residential care facilities are permitted uses with Town approval and issuance of a site plan review or by conditional use permit.

CENTRAL-COMMERCIAL (C-C)
This designation provides for retail and service uses, public uses, professional and administrative office uses, and multiple-family residential uses. This designation is applied only to the central commercial (downtown or core) area of Paradise and is intended to accommodate visitor-oriented as well as locally oriented commercial uses and mixed uses that conform to an adopted architectural design theme and guidelines. Maximum potential residential densities cannot exceed 15 dwelling units per gross acre if served by an approved clustered wastewater treatment and disposal system.

TOWN-COMMERCIAL (T-C)
This designation provides for a full range of locally and regionally oriented commercial uses, including retail, retail centers, wholesale, storage, hotels and motels, restaurants, service stations, automobile sales and service, light fabrication, professional and administrative offices, churches, and public uses.

This classification is applied to existing moderate- to high-intensity commercial uses that are suitable for infill and to areas located at the intersection of designated arterial and/or collector streets.

Maximum potential residential densities cannot exceed 10 dwelling units per gross acre.

COMMUNITY-SERVICE (C-S)
This designation provides for private uses that serve a community purpose or benefit the community.

These uses include private hospitals, medical offices, schools, residential care facilities and day care facilities (other than those located in private residences), convalescent homes, emergency shelters and transitional housing, auditoriums and other places of assembly, senior citizen and youth centers, clubs and lodges, private utilities and facilities, and airports. This designation is primarily applied to existing or planned uses of this nature throughout the primary study area. Depending on the presence and application of constraints, maximum potential residential densities cannot exceed 15 dwelling units per gross acre if served by an approved clustered wastewater treatment and disposal system.

ZONING ORDINANCE
The Zoning Ordinance classifies the following types of residential uses that may be permitted in a zone:

Single-family residential – Means use of a site for only one dwelling unit and its allowed accessory uses, or for one primary dwelling unit and 1 secondary dwelling.

Two-family residence – Means use of a site for two dwelling units, either in the same building or in separate buildings, except when one of the dwelling units is a secondary dwelling. 286

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TOWN OF PARADISE HOUSING ELEMENT 3
Multiple-family residential – Means use of a site for three or more dwelling units, in one or more buildings, including units intended for individual ownership together with common areas or facilities.

Secondary dwelling – Means an attached or detached residential dwelling unit that provides independent living facilities (i.e., provisions for living, sleeping, eating, cooking, and sanitation) for one or more people and is located on a site with a proposed or existing primary dwelling. Secondary dwellings are allowed on the same parcel as single-family homes or multi-family buildings. Efficiency units and manufactured homes can be types of secondary dwellings.

Accessory Dwelling – Means a dwelling unit accessory to a nonresidential principal use on the same site, intended for occupancy by the landowner or a person employed on the site for security, maintenance, or management purposes.

Mobile/manufactured home – Means a transportable factory-built housing unit designed and equipped for use as a dwelling unit with or without a permanent foundation. A mobile/manufactured home may include two or more sections separately transported and joined together as one integral unit. A mobile home shall not include a recreational vehicle.

Mobile home park – Means a unified residential development with two or more mobile home spaces, together with internal streets, common areas, and facilities for parking, recreation, laundry, utility, storage, or other services for the residents.

Group residential – Means residential occupancy of dwelling units or sleeping units by groups of more than six persons not defined as a family. Typical uses include rooming or boarding, dormitories, residence halls, and fraternity and sorority houses.

Community care facility – Means a facility, place, or building that is maintained and operated to provide nonmedical residential care, adult day care, child day care, intermediate care, congregate living, health care, or home-finding agency services for children, adults, or children and adults, including but not limited to the physically handicapped, mentally impaired, or incompetent persons and does not include drug recovery facilities.

Community care facility, limited – Means a community care facility that provides service for six or fewer persons, with the residents and operators of the facility being considered a family.

Day care home, large family – Means a family day care home facility in the provider’s own residence that provides family day care for 7 to 14 children, including children under the age of 10 years who reside at the home.

Day care home, small family – Means a family day care home facility in the provider's own residence that provides family day care for eight or fewer children, including children under the age of 10 years who reside at the home.

Emergency shelters – Means facilities providing emergency shelter to homeless individuals or others in need of shelter. These accommodations include lodging and may include the following as ancillary uses: meals, laundry facilities, bathing, counseling, and other support services. 287

APPENDIX C
4 TOWN OF PARADISE HOUSING ELEMENT
The Zoning Ordinance identifies 10 residential districts (Agricultural Residential, Rural Residential, Town Residential, and Multi-family Residential and their respective subzones) and 6 other zones (Agricultural, Neighborhood Commercial, Central Business, Community Commercial, Community Facilities, and Community Services) that allow residential development. Some zones have varying zoning treatments, or sub-zones. Below is a brief description of each zoning district.

RESIDENTIAL ZONES
Agricultural Residential (AR) Zones – The Agricultural Residential zone is intended for land areas that are planned or are existing residential areas characterized by larger parcels and accessory agricultural land uses, including raising of livestock and other forms of agricultural production. The Agricultural Residential-1, Agricultural Residential-3, and Agricultural Residential-5 zones are consistent with the Agricultural-Residential (A-R) land use designation of the Paradise General Plan. The Agricultural Residential-3 and Agricultural Residential-5 zones are also consistent with the Open-Space/Agricultural land use designation of the Paradise General Plan.

Rural Residential (RR) Zones – The Rural Residential zone is intended for land areas that are planned or are existing single-family rural residential areas characterized by moderately large parcels and with residential densities that range from 1 to 2 dwelling units per acre. The RR-1, RR-2/3, and RR-1/2 zones are consistent with the Rural-Residential (R-R) land use designation of the Paradise General Plan.

Town Residential (TR) Zones – The Town Residential zone is intended for land areas that are planned or are existing single-family residential areas characterized by small (0.5 gross acres or less) parcels and the absence of accessory rural land uses, particularly the keeping of livestock. The TR-1, TR-1/2, and TR-1/3 zones are consistent with the Town Residential (T-R) land use designation of the Paradise General Plan.

Multiple-Family Residential (M-F) Zones – The Multiple-Family Residential zone is intended for land areas that are planned or existing multiple-family residential areas. Depending on the presence and application of constraints, maximum potential residential densities cannot exceed 15 dwelling units per acre and eight dwelling units per acre in mobile home parks. The Multiple-Family Residential zone is consistent with the Multi-Family Residential (M-R) land use designation of the Paradise General Plan.

OTHER ZONES THAT ALLOW RESIDENTIAL USES
Central-Business (C-B) Zone – The Central-Business zone is intended for land areas located in the central commercial (downtown or core) area of Paradise and that provide for commercial retail and service uses, public uses, professional and administrative office uses, and multiple-family residential uses. The Central-Business zone is consistent with the Central-Commercial (C-C) land use designation of the Paradise General Plan and is potentially consistent with the Town-Commercial (T-C) Paradise General Plan land use designation.

Community-Facilities (C-F) and Community-Services (C-S) Zones – The Community-Facilities and Community-Services zones are intended for land areas that are planned to or already provide for public and public institutional land uses or private land uses which serve a community purpose or benefit the community. The Community-Facilities zone is consistent with the Public-Institutional (P-I), Community-Service (C-S), and Recreational (R) land use designations of the Paradise General Plan. The 288

APPENDIX C
TOWN OF PARADISE HOUSING ELEMENT 5
Community-Services zone is consistent with the Community-Service (C-S) and Recreational (R) land use designations of the Paradise General Plan. In addition, the Community-Services zone is potentially consistent with the Multi-Family Residential (M-R) land use designation of the Paradise General Plan.

Agricultural-10 (AG-10) and Agricultural-20 (AG-20) Zone – The Agricultural-10/20 (AG-10, AG-20) zones are intended for land areas planned and deemed suitable to remain in their natural, primarily undeveloped state or to be used for open space and agricultural purposes. Such land areas can also be deemed inappropriate for urban development due to steep slopes, a significant lack of public services, and a substantial desire to retain existing agricultural or open space characteristics. The Agricultural-10 and Agricultural-20 zones are consistent with the Open-Space/Agricultural land use designation of the Paradise General Plan.

Community-Commercial (C-C) Zone – The Community-Commercial zone is intended for land areas that are planned or are providing a full range of locally and regionally oriented commercial land uses, including retail, retail centers, wholesale, storage, hotels and motels, restaurants, service stations, automobile sales and service, professional and administrative offices, etc. Depending on the presence and application of constraints, maximum potential residential densities shall not exceed 10 dwelling units per acre. The Community-Commercial zone is consistent with the Town-Commercial (T-C) land use designation of the Paradise General Plan and is potentially consistent with the Community-Service (C-S) Paradise General Plan land use designation.

Neighborhood-Commercial (N-C) Zone – The Neighborhood-Commercial zone is intended for land areas that are characterized by existing and planned neighborhood and locally oriented commercial retail and service uses. This zone is primarily applied to small sites adjacent to residential neighborhoods and along designated arterial or collector streets. The Neighborhood-Commercial zone is consistent with both the Neighborhood-Commercial (N-C) and the Town-Commercial (T-C) land use designations of the Paradise General Plan.

COMBINING ZONES
Planned Development Combining (P-D) Zone – The purpose of the Planned Development Combining zone is to allow the establishment of planned developments with flexibility in the design of development projects; to promote economical and efficient use of the land, an increased level of urban amenities, and preservation of the natural environment; and to provide for phased completion of planned development projects.
289

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APPENDIX D: SITES INVENTORY, Scenario Without the Sewer Jurisdiction Name Site Address/Intersection 5 Digit ZIP Code Assessor Parcel Number Consolidated Sites General Plan Designation (Current) Zoning Designation (Current) Minimum Density Allowed (units/acre) Max Density Allowed (units/acre) Parcel Size (Acres) Existing Use/Vacancy Infrastructure Publicly-Owned Site Status Identified in Last/Last Two Planning Cycle(s) Lower Income Capacity Moderate Income Capacity Above Moderate Income Capacity Total Capacity Optional Information1 Optional Information2 PARADISE 8634 SKYWAY 95969 051-102-047-000 TR TR 1/3 0 1 2.29 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Previous use (pre-fire) was COMMERCIAL Maximum density of 2 is per site. Density convention has been back-engineered for this site to provide a density per acre metric in Column I, consistent with HCD conventions.

PARADISE 3631 CONNIE CIR APT A 95969 051-440-001-000 A MR MF 0 15 9.8 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 8 16 62 86 This entry includes the realistic capacity for the entirety of Consolidated Site A, which is an approximately 10-acre that was listed for sale: https://www.estately.com/listings/info/3600-connie-circle PARADISE 3631 CONNIE CIR APT B 95969 051-440-002-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.

PARADISE 3631 CONNIE CIR APT C 95969 051-440-003-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3631 CONNIE CIR APT D 95969 051-440-004-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3619 CONNIE CIR APT A 95969 051-440-005-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3619 CONNIE CIR APT B 95969 051-440-006-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3619 CONNIE CIR APT C 95969 051-440-007-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3619 CONNIE CIR APT D 95969 051-440-008-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3605 CONNIE CIR APT A 95969 051-440-009-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3605 CONNIE CIR APT B 95969 051-440-010-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3605 CONNIE CIR APT C 95969 051-440-011-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3605 CONNIE CIR APT D 95969 051-440-012-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3593 CONNIE CIR APT A 95969 051-440-013-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3593 CONNIE CIR APT B 95969 051-440-014-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3593 CONNIE CIR APT C 95969 051-440-015-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3593 CONNIE CIR APT D 95969 051-440-016-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3606 CONNIE CIR APT A 95969 051-440-017-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3606 CONNIE CIR APT B 95969 051-440-018-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3606 CONNIE CIR APT C 95969 051-440-019-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3606 CONNIE CIR APT D 95969 051-440-020-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3622 CONNIE CIR APT A 95969 051-440-021-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3622 CONNIE CIR APT B 95969 051-440-022-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3622 CONNIE CIR APT C 95969 051-440-023-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3622 CONNIE CIR APT D 95969 051-440-024-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3549 CONNIE CIR APT A 95969 051-440-025-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3549 CONNIE CIR APT B 95969 051-440-026-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3549 CONNIE CIR APT C 95969 051-440-027-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3549 CONNIE CIR APT D 95969 051-440-028-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3559 CONNIE CIR APT A 95969 051-440-029-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3559 CONNIE CIR APT B 95969 051-440-030-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3559 CONNIE CIR APT C 95969 051-440-031-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3559 CONNIE CIR APT D 95969 051-440-032-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3569 CONNIE CIR APT A 95969 051-440-033-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3569 CONNIE CIR APT B 95969 051-440-034-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3569 CONNIE CIR APT C 95969 051-440-035-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3569 CONNIE CIR APT D 95969 051-440-036-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3581 CONNIE CIR APT A 95969 051-440-037-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3581 CONNIE CIR APT B 95969 051-440-038-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3581 CONNIE CIR APT C 95969 051-440-039-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 3581 CONNIE CIR APT D 95969 051-440-040-000 A MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the inventory count given it is a condo parcel.PARADISE 5848 BLACK OLIVE DR 95969 052-160-016-000 MR MF 0 15 0.27 Vacant YES - Planned NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 0112 PARADISE 5995 MAXWELL DR 95969 053-030-020-000 MR MF 0 15 0.44 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0112 PARADISE 5975 MAXWELL DR APT 1 95969 053-380-001-000 E MR MF 0 15 6.50 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 6 10 41 57 This entry includes the realistic capacity for the entirity of Consolidated Site E, which was the 6.5-acre Central Park Condominiums and was listed for sale (https://www.landandfarm.com/property/6_52_Acres_in_Butte_County-10254839/) PARADISE 5975 MAXWELL DR APT 2 95969 053-380-002-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.

PARADISE 5975 MAXWELL DR APT 3 95969 053-380-003-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 4 95969 053-380-004-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 5 95969 053-380-005-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 6 95969 053-380-006-000 E MR MF 0 15 0.00 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.

PARADISE 5975 MAXWELL DR APT 7 95969 053-380-007-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.

PARADISE 5975 MAXWELL DR APT 8 95969 053-380-008-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 9 95969 053-380-009-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 10 95969 053-380-010-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 11 95969 053-380-011-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 12 95969 053-380-012-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 13 95969 053-380-013-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 14 95969 053-380-014-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 15 95969 053-380-015-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 16 95969 053-380-016-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 17 95969 053-380-017-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 18 95969 053-380-018-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 19 95969 053-380-019-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 20 95969 053-380-020-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 21 95969 053-380-021-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 22 95969 053-380-022-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 23 95969 053-380-023-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 24 95969 053-380-024-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 25 95969 053-380-025-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 26 95969 053-380-026-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 27 95969 053-380-027-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 28 95969 053-380-028-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 29 95969 053-380-029-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 30 95969 053-380-030-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 31 95969 053-380-031-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 32 95969 053-380-032-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 33 95969 053-380-033-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 34 95969 053-380-034-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 35 95969 053-380-035-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 36 95969 053-380-036-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 37 95969 053-380-037-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 38 95969 053-380-038-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 39 95969 053-380-039-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 40 95969 053-380-040-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 41 95969 053-380-041-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 42 95969 053-380-042-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 43 95969 053-380-043-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5975 MAXWELL DR APT 44 95969 053-380-044-000 E MR MF 0 15 0 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 This parcel is excluded in the count given it is a condo parcel.PARADISE 5998 WILLIAMS DR 95969 053-080-034-000 MR MF 0 15 0.29 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Previous use (pre-fire) was SINGLE FAMILY RESIDENCE PARADISE 5734 BLACK OLIVE DR 95969 052-143-001-000 MR MF 0 15 0.28 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Previous use (pre-fire) was SINGLE FAMILY RESIDENCEPARADISE 5989 MAXWELL DR 95969 053-030-021-000 MR MF 0 15 0.34 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Previous use (pre-fire) was SINGLE FAMILY RESIDENCEPARADISE 6003 MAXWELL DR 95969 053-030-019-000 MR MF 0 15 0.48 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0224 Previous use (pre-fire) was SINGLE FAMILY RESIDENCEPARADISE 6029 MAXWELL DR 95969 053-030-031-000 MR MF 0 15 0.46 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0224 Previous use (pre-fire) was SINGLE FAMILY RESIDENCEPARADISE 5772 BLACK OLIVE DR 95969 052-143-003-000 MR MF 0 15 0.41 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Previous use (pre-fire) was SINGLE FAMILY RESIDENCEPARADISE 5798 BLACK OLIVE DR 95969 052-143-004-000 MR MF 0 15 0.23 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Previous use (pre-fire) was SINGLE FAMILY RESIDENCEPARADISE 6055 MAXWELL DR 95969 053-030-045-000 C MR MF 0 15 0.95 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0167 This acreage and capacity includes 6045 Maxwell Dr which has the same owner and is adjacent PARADISE 6045 MAXWELL DR 95969 053-030-046-000 C MR MF 0 15 0.00 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0000 The realistic capacity and acreage for this parcel is counted under 6055 Maxwell Drive, which has the same owner.

PARADISE 9115 SKYWAY 95969 050-040-001-000 MR MF 0 15 1.30 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0 2 8 10 Previous use (pre-fire) was SINGLE FAMILY RESIDENCE PARADISE 9101 SKYWAY 95969 050-040-002-000 MR MF 0 15 1.00 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0167 Previous use (pre-fire) was SINGLE FAMILY RESIDENCE PARADISE 9089 SKYWAY 95969 050-040-003-000 MR MF 0 15 0.50 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0224 Previous use (pre-fire) was SINGLE FAMILY RESIDENCEPARADISE 9079 SKYWAY 95969 050-040-147-000 MR MF 0 15 1.12 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 1 2 7 10 Previous use (pre-fire) was RETAIL PARADISE 5726 BLACK OLIVE DR 95969 052-143-010-000 MR MF 0 15 0.66 Vacant YES - Planned NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 0145 Previous use (pre-fire) was SINGLE FAMILY RESIDENCE PARADISE 5436 CLARK RD 95969 054-120-021-000 MR MF 0 15 18.58 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0 83 83 166 Previous use (pre-fire) was COMMERCIAL PARADISE 6035 MAXWELL DR 95969 053-030-041-000 MR MF 0 15 0.53 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0134 Previous use (pre-fire) was SINGLE FAMILY RESIDENCE PARADISE 6025 MAXWELL DR 95969 053-030-017-000 MR MF 0 15 0.54 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0134 Previous use (pre-fire) was SINGLE FAMILY RESIDENCEPARADISE 6015 MAXWELL DR 95969 053-030-018-000 MR MF 0 15 0.54 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0134 Previous use (pre-fire) was SINGLE FAMILY RESIDENCEPARADISE 1340 BILLE RD 95969 053-150-103-000 MR MF 0 15 10.79 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0 64 64 128 Previous use (pre-fire) was COMMERCIAL PARADISE 6240 CLARK RD 95969 053-040-040-000 MR MF 0 15 1.00 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0167 Previous use (pre-fire) was COMMERCIALPARADISE 6254 CLARK RD 95969 053-040-041-000 MR MF 0 15 0.69 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0145 Previous use (pre-fire) was SINGLE FAMILY RESIDENCE PARADISE 780 WILLOW ST 95969 052-160-011-000 MR MF 0 15 0.52 Vacant YES - Planned NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 0134 Previous use (pre-fire) was SINGLE FAMILY RESIDENCE PARADISE 1368 GARNET LN 95969 050-190-039-000 MR MF 0 15 10.96 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0 57 57 114 Previous use (pre-fire) was COMMERCIAL PARADISE 1280 WAGSTAFF RD 95969 050-190-053-000 MR MF 0 15 12.48 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0 56 56 112 Previous use (pre-fire) was COMMERCIALPARADISE 1047 ROCHELLE LN 95969 051-164-039-000 MR MF 0 15 0.69 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0145 Previous use (pre-fire) was SINGLE FAMILY RESIDENCE PARADISE 6137 LUCKY JOHN RD 95969 052-012-052-000 MR MF 0 15 1.90 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0 3 12 15 Previous use (pre-fire) was SINGLE FAMILY RESIDENCEPARADISE 6189 CENTER ST 95969 052-040-085-000 MR MF 0 15 1.71 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0 2 10 12 Previous use (pre-fire) was SINGLE FAMILY RESIDENCEPARADISE 6184 CENTER ST 95969 052-060-027-000 MR MF 0 15 0.57 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0134 Previous use (pre-fire) was COMMERCIAL 291
PARADISE WILLIAMS AND CENTRAL PARK DRIVE 95969 053-080-006-000 MR MF 0 15 1.89 Vacant YES - Planned NO - Privately-Owned Available Used in Two Consecutive Prior Housing Elements - Vacant 0 3 12 15 PARADISE WILLIAMS AND CENTRAL PARK DRIVE 95969 053-080-005-000 MR MF 0 15 1.84 Vacant YES - Planned NO - Privately-Owned Available Used in Two Consecutive Prior Housing Elements - Vacant 0 3 11 14PARADISE WILLIAMS AND CENTRAL PARK DRIVE 95969 053-080-003-000 MR MF 0 15 1.32 Vacant YES - Planned NO - Privately-Owned Available Used in Two Consecutive Prior Housing Elements - Vacant 0 2 8 10PARADISE WILLIAMS AND CENTRAL PARK DRIVE 95969 053-080-002-000 MR MF 0 15 1.84 Vacant YES - Planned NO - Privately-Owned Available Used in Two Consecutive Prior Housing Elements - Vacant 0 3 11 14PARADISE ALMOND ST AND ELLIOT RD 95969 052-150-054-000 MR MF 0 15 1.12 Vacant YES - Planned NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 0178 PARADISE SKYWAY AND ARLENE WAY 95969 051-132-038-000 TR TR 1/2 0 2 1.00 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Maximum density of 2 is per site. Density convention has been back-engineered for this site to provide a density per acre metric in Column I, consistent with HCD conventions.

PARADISE BURDAPARADISE LN AND SKYWAY 95969 050-070-060-000 MR MF 0 15 0.41 Vacant YES - Planned NO - Privately-Owned Available Used in Two Consecutive Prior Housing Elements - Vacant 0112PARADISE 6674 PENTZ RD 95969 050-230-058-000 TR TR 1/3 0 0.4 4.82 Vacant YES - Potential NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Previous use (pre-fire) was COMMERCIAL Maximum density of 2 is per site. Density convention has been PARADISE KILCREASE CIR 95969 050-150-111-000 TR TR 1/3 0 0.08 25.42 Vacant YES - Potential NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Previous use (pre-fire) was COMMERCIAL Maximum density of 2 is per site. Density convention has beenPARADISE 6656 PENTZ RD 95969 050-240-078-000 TR TR 1/3 0 0.6 3.16 Vacant YES - Potential NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Previous use (pre-fire) was COMMERCIAL Maximum density of 2 is per site. Density convention has beenPARADISE 6280 PENTZ RD 95969 053-250-115-000 TR TR 1/3 0 0.5 4.17 Vacant YES - Potential NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Previous use (pre-fire) was COMMERCIAL Maximum density of 2 is per site. Density convention has beenPARADISE 1348 ELLIOT RD 95969 053-330-070-000 TR TR 1/2 0 0.5 3.79 Vacant YES - Potential NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Previous use (pre-fire) was COMMERCIAL Maximum density of 2 is per site. Density convention has beenPARADISE 7075 CLARK RD 95969 050-051-052-000 B MR MF 0 15 1.00 Vacant YES - Potential NO - Privately-Owned Available Not Used in Prior Housing Element 0167 Previous use (pre-fire) was COMMERCIALPARADISE 7075 CLARK RD 95969 050-051-048-000 B MR MF 0 15 6.13 Vacant YES - Potential NO - Privately-Owned Available Not Used in Prior Housing Element 5 10 39 54 Previous use (pre-fire) was COMMERCIALPARADISE 1080 PEARSON RD 95969 054-151-060-000 MR MF 0 15 2.97 Vacant YES - Potential NO - Privately-Owned Available Not Used in Prior Housing Element 2 4 19 25 Previous use (pre-fire) was COMMERCIALPARADISE 7075 CLARK RD 95969 050-051-049-000 MR MF 0 15 2.23 Vacant YES - Potential NO - Privately-Owned Available Not Used in Prior Housing Element 2 3 14 19 Previous use (pre-fire) was COMMERCIALPARADISE 6799 SKYWAY 95969 052-060-036-000 MR MF 0 15 0.48 Vacant YES - Potential NO - Privately-Owned Available Not Used in Prior Housing Element 0224 Previous use (pre-fire) was COMMERCIALPARADISE 9141 SKYWAY 95969 050-011-013-000 MR MF 0 15 3.79 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 7 12 48 67 PARADISE CLARK RD AND BUSCHMANN RD 95969 054-060-103-000 MR MF 0 15 4.41 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 8 14 56 78PARADISE CLARK RD AND BUSCHMANN RD 95969 054-060-102-000 MR MF 0 15 2.13 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 4 7 27 38PARADISE SKYWAY AND ARLENE WAY 95969 054-060-101-000 MR MF 0 15 4.93 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 9 16 63 88PARADISE NEAR INTERSECTION OF CLARK RD AND BUSCHMANN RD 95969 054-080-005-000 MR MF 0 15 4.77 Vacant YES - Planned NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 9 15 61 85 PARADISE 6186 CENTER ST 95969 052-040-084-000 MR MF 0 15 2.29 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 2 3 14 19 PARADISE 772 WILLOW ST 95969 052-160-004-000 MR MF 0 15 0.21 Vacant YES - Potential NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Previous use (pre-fire) was SINGLE FAMILY RESIDENCE PARADISE 6075 MAXWELL DR 95969 053-030-036-000 MR MF 0 15 0.20 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0112 PARADISE 758 WILLOW ST 95969 052-160-002-000 MR MF 0 15 0.21 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Previous use (pre-fire) was SINGLE FAMILY RESIDENCE PARADISE 773 WILLOW ST 95969 052-160-010-000 MR MF 0 15 0.19 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Previous use (pre-fire) was SINGLE FAMILY RESIDENCEPARADISE 766 EDWARDS LN APT A 95969 052-040-092-000 MR MF 0 15 3.46 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 2 5 22 29 PARADISE 5826 BLACK OLIVE DR 95969 052-143-006-000 MR MF 0 15 0.20 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 0112 Previous use (pre-fire) was SINGLE FAMILY RESIDENCE PARADISE 5754 BLACK OLIVE DR 95969 052-143-002-000 MR MF 0 15 0.21 Vacant YES - Planned NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 0112 PARADISE 7726 SKYWAY 95969 051-164-060-000 MR MF 0 15 8.75 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 8 16 65 89 Previous use (pre-fire) was COMMERCIAL PARADISE 931 ELLIOTT RD 95969 053-111-034-000 CS CS 0 15 4.35 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 4 7 27 38 former church site with no plans to rebuild Will be rezoned to MF (General Plan designation MR) as part of the Town's planning for the sewer project. This rezoning is not to accommodate a shortfall of sites and instead is related to the Town's General Plan update. The rezoning is therefore not included on Table B.

PARADISE 8764 SKYWAY 95969 050-070-082-000 MR MF 0 15 3.12 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 8 15 59 82 Previous use (pre-fire) was COMMERCIAL PARADISE 5500 CLARK RD 95969 054-080-038-000 MR MF 0 15 6.18 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 4 10 39 53 Previous use (pre-fire) was COMMERCIALPARADISE 759 WILLOW ST 95969 052-160-013-000 MR MF 0 15 2.45 Vacant YES - Planned NO - Privately-Owned Available Used in Prior Housing Element - NonVacant 2 4 15 21 Previous use (pre-fire) was SINGLE FAMILY RESIDENCE PARADISE 5838 BLACK OLIVE DR 95969 052-160-015-000 MR MF 0 15 3.35 Vacant YES - Planned NO - Privately-Owned Available Used in Prior Housing Element - NonVacant 2 5 21 28 Previous use (pre-fire) was COMMERCIAL PARADISE 6799 SKYWAY 95969 052-060-013-000 MR MF 0 15 3.50 Vacant YES - Planned NO - Privately-Owned Available Not Used in Prior Housing Element 2 5 22 29 Previous use (pre-fire) was COMMERCIAL 292
APPENDIX E: PUBLIC ENGAGEMENT
INPUT
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TOWN OF PARADISE HOUSING ELEMENT 2022-2030 1

STAKEHOLDER INTERVIEWS
Interviews were conducted with eight stakeholders to better understand constraints, housing needs, and housing opportunities.

The main constraints and opportunities identified during these interviews are listed below.

CONSTRAINTS

1. Septic system capacity is the main limiting factor for MF development. Increasing densities will likely not be possible until sewer goes in.
▪ Developers viewed the proposed sewer project as uncertain, both in terms of its anticipated timing and how it will be funded. They also seemed to think that only a small portion of residential parcels would be able to utilize it.
▪ Developing a MF project on a sewer parcel would add to the project’s total development costs.

How should we estimate these costs?
▪ Generally, developers didn’t seem to want to target densities beyond 15 du/acre, even when asked about the sewer project. This might be because of the uncertain timing of the project, or because they anticipate the sewer project only affecting certain sites in the Town. ▪ The Town has determined that many properties have a failing septic system (40-60% of all properties). Replacing the septic is expensive. The Town and Rebuild Paradise Foundation have grants to support existing homeowners with these costs, but nothing for multi-family developers.

2. Site availability.
▪ There aren’t large parcels available for single-family home subdivisions in Paradise, so developers are taking a scattered site approach – which can be less cost effective and take more time. ▪ There are also limited parcels zoned for multi-family housing in Paradise. This issue also intersects with the sewer project boundary question – see above.

3. Insurance in wildfire zones.

While insurance payouts have allowed both SF and MF property owners to rebuild, obtaining insurance for new construction has been very challenging – especially for multi=family housing (e.g., CHIP). Even when properties are able to get insurance, rates are at least 2x what they used to be. State legislation protects existing homeowners to some extent by requiring insurers to provide coverage, but there is no protection for multi-family/commercial properties of over $3m in value.

4. Market-related barriers, including high construction costs for both SF and MF development. ▪ Primarily due to shortage of labor and materials.
▪ For individual homeowners, accessing construction loans can be a barrier. ▪ The market is “dampened”, low risk tolerance from development community. 295

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5. Lack of amenities, facilities (health care, schools) and infrastructure (roads, fiberoptic, etc.) makes it challenging to attract residents and development, but the lack of population makes it harder to attract businesses back. “Chicken and egg” problem. Affordable housing funding sources also score Paradise lower because of the lack of amenities/facilities.

6. Local resistance to higher MF densities. The community prefers open space and very low densities.

Developers talked about the need for a culture shift. Need to figure out “appropriate” densities in the right locations, such as commercial corridors, while also respecting the existing character.

7. Special housing needs.

The large population of Paradise residents and ex-residents with disabilities are on a fixed income and can’t pay more than $400/month on rent. Can’t find these rates for brand new housing that just got built. Some service providers used insurance money to buy replacement housing instead of rebuilding.

Housing would need ADA compliance and to be close to the resources the town has to offer (e.g., transit, medical facilities, local events) to best serve those with disabilities. California Vocations has three sites in Paradise that are now vacant and could be potential sites for rebuilds, but need to find funding.

Specific to affordable housing development, the following barriers were cited. ▪ Very limited recent affordable housing development. Paradise Community Village is the only recent tax credit project. Recently rebuilt by CHIP after the fire. ▪ Disaster recovery tax credits:
▪ Town of Paradise may struggle to secure credits if TCAC reinstates the readiness requirements (minimum zoning & access to basic amenities). The Town is still recovering, so meeting the TCAC scores related to access to amenities will be particularly challenging. ▪ Butte County AMIs:
▪ Market rates rents are sometimes equivalent to low-income rents (80% AMI). ▪ Subsidized affordable housing projects target very low or extremely low incomes. ▪ Potential for on-site below market rate (BMR) units is low, given current market rate rents. ▪ Few developers had heard of the state density bonus. Again, sewer capacity constrains density on most sites.

OPPORTUNITIES
▪ Residential floorplan library has been helpful.
▪ Some developers see an opportunity to “build back better” and implement key community infrastructure early on (walking/biking, etc.).
▪ Developers mentioned new building technologies as potential solutions, but it isn’t clear yet that they will provide significant cost savings.
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▪ On the question of ADUs, some developers stated that there was potentially some interest, but generally not as popular as in other places. Certain challenges include meeting the septic system and the Town’s dwelling size requirements.
▪ Fire science woven into zoning would be helpful; give the Town more enforcement capabilities for mitigation measures; want the Town to have ability to enforce/abate properties that are creating fire safety hazards.
▪ Provide more opportunities for parks/green buffers – areas to be zoned residential and park at the same time if identified as a key piece of risk mitigation area; allow nonprofit buy it and turn it into greenbelt.

INCORPORATION INTO HOUSING ELEMENT
Feedback from stakeholder interviews was used to inform the Constraints section of the Housing Element, and policies and programs are proposed to directly address the barriers that were identified, as summarized below.
▪ The Sewer Service Overlay is proposed to address density constraints and provide flexibility while the Paradise Sewer Project progresses.
▪ Site consolidation programs (HI-7) are proposed to address site availability. ▪ Coordination and partnerships with local insurance companies and Fire Safe Councils are proposed to address challenges related to insurance (HP-27, HI-14). ▪ In addition to incoming subsidy provided by CDBG-DR funds, challenges related to high construction costs could be alleviated through innovative construction methods and new types of housing like tiny homes (HP-12 and HP-13).

PUBLIC MEETING COMMENTS
The public meeting on September 21, 2021 utilized breakout rooms and a live poll to gather community feedback.

BREAKOUT OUT ROOMS
Breakout rooms were utilized at the September 21, 2021 community meeting to discuss potential housing policies and programs. Participants answered six questions and the feedback received during these discussion groups is listed below.

What do you think about increasing the allowed density of housing along Skyway and Clark for when the sewer system comes in? Would you support three-story buildings on these key corridors? Do you have concerns about this approach? ▪ 3 stories is very large for the region, even in Chico. Too dense. ▪ There are dorms that are that large, has no problem with it as long as there is architectural control and they look nice.
▪ Some of the existing 3 story buildings are not aesthetically pleasing. 297

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4 TOWN OF PARADISE HOUSING ELEMENT 2022-2030
▪ All the houses are too close together, the density does not match the feel of Paradise. ▪ Would prefer to keep it at 2 stories.
▪ Some of the ones on Elliot are 2 stories and are nicely landscaped. ▪ If there was space for landscaping it does look better. ▪ No utilitarian/military block look.
▪ With all the open space requirements for fire resiliency, we need to add density elsewhere. ▪ We could put the open space within the buildings.
▪ Support higher density in moderation if it maintains neighborhood character. ▪ Like the idea of mixed uses for higher density buildings – also promotes walkability and safety to have mixed use.
▪ Preference for one story.
▪ Concern for traffic with increasing density along Skyway. ▪ Wary of aesthetic of massing with larger buildings.

How do you see the wildfire shaping future housing and safety goals? Which wildfire resiliency policies do you support? Do any give you concern? Policy Reasons for Support Reasons for Concern
Incorporation into
Housing Element
Parks and
greenbelts as
buffers
▪ Very needed and desired
▪ Would like to see the river edge be
purchased by the state or county to
maintain it as a buffer and protect against
fires coming from the canyon
▪ Can’t rebuild the old footprint of the town,
some lots are too narrow or have other
issues. So we have to erase parts of Town,
which is difficult due to personal
connections
▪ Management
▪ Concern for increasing setbacks
Planning for Wildfire
Risk Reduction Buffers
is included in HP-26.

Implementation of this
policy includes
continued outreach
around it.

Wildfire hazard
impact fee
▪ Support for fire safe materials What does that look like? Depends on how much.
▪ Slight reservation, there are already
a lot of fees associated with building
▪ Would hate it to prevent someone
from building on the land
HP-25 calls for the
Town to consider the
feasibility of a fee.

Increased bldg/
landscape reqs.
▪ Very supportive, realistic about energy and
forces needed for maintenance effort
▪ support for programs to increase
enforcement of vegetation management
What about homes that are already
being rebuilt/been rebuilt?
HP-23 and numerous
policies in the Safety
Element would
increase education
around fire-safe
practices. The Town
would also monitor
and consider the
application of more
stringent fire-safe
requirements. Grants
or no-interest loans
would be considered
Home hardening
or fuel mgmt
programs
▪ Interest in more resources for this
▪ Enthusiasm for this
▪
▪ It would be good to help homeowners with
this, especially for disabled people or
someone without a lot of income
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APPENDIX E
TOWN OF PARADISE HOUSING ELEMENT 2022-2030 5
Policy Reasons for Support Reasons for Concern
Incorporation into
Housing Element
to help low-income
property owners with
vegetation
management and
home hardening.

Other: Insurance
reform and
communitybased insurance
There has been increase in homeowner’s
insurance for some, others not so much. Some
have had trouble finding insurance at all and
was not able to switch providers. There is hope
that we can reduce the risk factor and lower
prices with these policies. RCAC looking into
which combination of policies would satisfy the
insurance companies that the town is enough
safer to act normal again.

Residents report there are noticeably fewer
trees and more space, so the town is already a
lot safer than 3 years ago, and this should be
modelled for the insurance companies.

Coordination and
partnerships with local
insurance companies
and Fire Safe Councils
are proposed to
address challenges
related to insurance
(HP-27, HI-14).

What do you see as best practices for managing and maintaining adequate defensible space?
▪ Fire Dept is issuing citations or warnings, The Town is letting folks know if they meet the requirements. Important to go lot by lot and make sure every owner is doing what they have to do to maintain all of our defense. We have to do it as a group. ▪ But this is also difficult for some owners, especially some who aren’t physically in Town. It takes too long for some people to do their tasks.
▪ Maybe what we need is faster acting laws on our books that allows the Town to act faster than in one year, which is inadequate. The whole process just takes too long. ▪ Need year-round reminders and enforcement of vegetation and weed management. ▪ Education for what to plant and what not to plant.
▪ Fence materials?
▪ Cutting weeds requires a lot of manual labor.
▪ Enforcement or safety around using herbicide.
▪ Mulching is costly and laborious.

What can the Town do to support residents in extreme weather events related to heat and drought?
▪ There aren’t as many extremes in Paradise as other areas, no need for this. ▪ Community centers to use power, making facilities available for AC. A lot of people in RVs. ▪ Identify and establish cooling centers; especially for those living in temporary housing (RV’s and trailers, mobile homes).
▪ School district, other public facilities, churches to serve as cooling centers. 299

APPENDIX E
6 TOWN OF PARADISE HOUSING ELEMENT 2022-2030
▪ Implement transportation contact network→ volunteers. ▪ County already has network for those with disabilities. ▪ Understanding resiliency plan for flooding, increased chance in burn scarred areas. ▪ Important to re-imagine what the vegetation can look like; Black Oak as opposed to Pine trees. ▪ Encourage tree planting programs→ County Resource Conservation District (RCD). ▪ Education program for resilient landscaping and understanding what fire safe materials mean and look like.

What other ideas, policies, program, or suggestions do you have to meet our housing needs?
▪ Concern for mobile home parks from financing by developers/owners of parks to rebuild, while holding on to land for PG&E settlement.
▪ Mobile homes offer housing but ARE large fire risk.
▪ Volunteer housing for rebuilding homes.
▪ Provide greater flexibility for workforce and temporary housing. ▪ Ensure there’s adequate sprinklers and up to fire code.

How do you feel about policies to facilitate unconventional building methods, typologies, or labor forces to get around high construction costs? Do you have ideas for partnerships or programs? Do you have other ideas to address high construction costs? ▪ Housing for Volunteers.
▪ Storage container homes serve as effective alternative materials and are fire safe, not always done in an aesthetically pleasing way—design standards for alternative housing? ▪ Support for more uniform development that maintains character, want new construction being rebuilt to be long-lasting.
▪ Grouping of tiny homes into villages.
▪ Fire-safe constructed, affordable alternative modular units that ship cheaply (Boxabl). ▪ Interest in tiny home villages/concentration of affordable units. 300

APPENDIX E
TOWN OF PARADISE HOUSING ELEMENT 2022-2030 7

LIVE POLL
In addition to the breakout rooms, a live poll was used to collect data. The results are shown below.

INCORPORATION INTO HOUSING ELEMENT
Feedback from breakout rooms and live poll shaped the policies and programs included in the Housing and Safety Elements. Programs with the most support were included in the elements, including allowing tiny home villages, enforcing and helping property owners with vegetation management, working with community partners to try to tie insurance rates to home hardening and other fire-safe practices, pursuing the creation of Wildfire Risk Reduction Buffers, and concentrating more housing along key evacuation corridors that will be served by the future sewer system. 301

APPENDIX E
8 TOWN OF PARADISE HOUSING ELEMENT 2022-2030

ONLINE SURVEY
An online survey was open from September 22, 2021 to September 29, 2021 and 355 responses were collected. The results are shown below.
302

APPENDIX E
TOWN OF PARADISE HOUSING ELEMENT 2022-2030 9
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APPENDIX E
10 TOWN OF PARADISE HOUSING ELEMENT 2022-2030

INCORPORATION INTO HOUSING ELEMENT
Feedback from the online survey shaped the policies and programs included in the Housing and Safety Elements. Programs with the most support were included in the elements, including the densification of the town in the Sewer Service Area, establishment of potential Wildfire Risk Reduction Buffers, and pursuing potential partnerships with stakeholders working in non-traditional construction. Based on community feedback, policies and programs to discourage development in the most dangerous areas and policies that would add additional costs to development (e.g., impact fees, additional fire resiliency measures) are tempered to ensure tradeoffs with development feasibility are considered. With implementation of the Housing and Safety Elements, the Town will balance the need for fire safety and the need for housing.
304
Town of Paradise Housing and Safety Elements

INITIAL STUDY
Town of Paradise
Community Development Department
Building Resiliency Center
6295 Skyway
Paradise, CA 95969
April 2022
305
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TABLE OF CONTENTS
I. PROJECT DESCRIPTION .................................................................................................. 1 II. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED ..................................................... 8 III. ENVIRONMENTAL CHECKLIST....................................................................................... 10

1. Aesthetics Resources ....................................................................................... 10

2. Agricultural and Forestry Resources................................................................. 13

3. Air Quality ....................................................................................................... 15

4. Biological Resources ........................................................................................ 18

5. Cultural Resources........................................................................................... 22

6. Energy............................................................................................................. 24

7. Geology and Soils ............................................................................................ 26

8. Greenhouse Gas Emissions .............................................................................. 30

9. Hazards and Hazardous Materials .................................................................... 32

10. Hydrology and Water Quality............................................................................ 40

11. Land Use and Planning..................................................................................... 44

12. Mineral Resources............................................................................................ 47

13. Noise............................................................................................................... 48

14. Population and Housing................................................................................... 50

15. Public Services................................................................................................. 52

16. Recreation ....................................................................................................... 57

17. Transportation and Traffic ............................................................................... 59

18. Tribal Cultural Resources................................................................................. 71

19. Utilities and Service Systems ............................................................................ 73

20. Wildfire............................................................................................................ 76

21. Mandatory Findings of Significance.................................................................. 80 IV. LIST OF PREPARERS ..................................................................................................... 82 V. REFERENCES................................................................................................................ 84 307
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List of Tables
Table 1 Final Town of Paradise RHNA by Income Tier ........................................................... 3 Table 2 Town of Paradise Quantified Objectives 2022-2030 ................................................. 3 Table 3 Sewer Area Rezoning............................................................................................. 45 Table 4 BCAG Travel Demand Model Daily Home-Based VMT per Resident.......................... 67 Table 5 BCAG Housing Forecasts - Total Dwelling Units 2018-2040.................................... 68 Table 6 Paradise Growth Projects – Total Dwelling Units..................................................... 68 List of Figures
Figure 1 Project Location....................................................................................................... 6 Figure 2 Housing Element Sites ............................................................................................. 7 Figure 3 Evacuation Routes ................................................................................................. 36 Figure 4 Evacuation Zones .................................................................................................. 37 Appendices
Appendix A: Technical Transportation Memorandum
Appendix B: Town VMT Policies
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I. PROJECT DESCRIPTION
The following is an Initial Study and Environmental Checklist for the proposed Paradise Housing Element and Safety Element Updates (the Project).

1. Project Title: Housing and Safety Element Updates

2. Lead Agency Name and Address:

Town of Paradise
Community Development Department
6295 Skyway
Paradise, CA 95969

3. Contact Person and Phone Number:

Susan Hartman, Community Development Director
530-872-6291 (ext. 417)
[email protected]

4. Project Sponsor’s Name and Address:

Town of Paradise
6295 Skyway
Paradise, CA 95969

5. General Plan Land Use Designation: N/A

6. Zoning: N/A

7. Project Location: Town-wide

8. Surrounding Land Uses and Setting:

The environmental setting consists of the areas located within the Town of Paradise, which is located in north central Butte County. Paradise is located at the juncture of the western slopes of the Cascade and Sierra Nevada systems. The area is defined by steep canyons - to the east by the West Branch of the Feather River drainage, and to the northwest by the Butte CreekLittle Butte Creek drainage. The Town of Paradise is accessible via Skyway Road, Clark Road, Neal Road, and Pentz Road from the south, while Clark Road transitions into Highway 191 through town. Old Skyway Road is the main entrance to town from the north. 309
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9. Description of Project:

The 2022-2030 Housing Element identifies the polices and implementation measures that the Town will implement to ensure that housing in Paradise is affordable, safe, and decent. The Housing Element addresses housing needs by encouraging the provision of an adequate quantity of sites planned for multi-family housing, preservation of existing housing, rebuilding housing lost in the 2018 Camp Fire, and increasing the safety and resiliency of housing in the town. In conjunction with the 2022-2030 Housing Element update, the Safety Element is being updated to also address wildfire risk reduction and to identify and mitigate other natural or man-made hazards.

These Housing and Safety Element updates (the Project) facilitate the rebuilding of the town since the 2018 Camp Fire at the densities that were previously developed and/or the densities allowed under the current General Plan and Zoning Code. The Project also looks at increased residential densities in the downtown core where a sewer system is currently in the planning phase (See Figure 1). As part of the implementation of the Housing Element, a Sewer Service Overlay Zone would be developed to enable mixed-use and multi-family development at higher densities on parcels within the Sewer Service Area. Figure 2 shows sites identified in the Housing Element update to accommodate the Town’s Regional Housing Needs Allocation (RHNA). The Town’s assigned RHNA is shown in Table 1. The vast majority of the parcels identified in the Housing Element were previously developed with housing that was destroyed in the Camp Fire and 95 percent of the Town’s RHNA was allocated to rebuild units lost in the fire. Although the Housing Element demonstrates the land availability to accommodate the entirety of the Town’s RHNA, the quantified objectives for the Housing Element are shown in Table 2. These quantified objectives represent the number of units likely to be constructed, rehabilitated, or conserved/preserved by income level during the planning period. The quantified objectives do not represent a ceiling on development, but rather set a target goal for the jurisdiction to achieve, based on needs, resources, and constraints. The Town’s quantified objectives are for the construction of 3,020 units and rehabilitation of 55 units.

No physical development changes are proposed as part of the Project. Instead, the Project establishes housing and safety-related goals, policies, and programs and the Housing Element identifies suitable land for development to achieve its RHNA. The general goals of the Safety Element are to minimize risk and vulnerability of the community to hazards, increase the community’s ability to be prepared for and respond to disaster events, reduce fire severity and intensity in and around Paradise, and increase resiliency in the face of climate change. The general goals of the Housing Element are to encourage and facilitate the production of all housing types; improve, rebuild, and preserve safe and decent housing; and accommodate housing designed for persons with special housing needs. 310
APRIL 2022 PARADISE HOUSING AND SAFETY ELEMENTS INITIAL STUDY PUBLIC REVIEW DRAFT 3
TABLE 1 FINAL TOWN OF PARADISE RHNA BY INCOME TIER
Income Group
Town of
Paradise
Units
Town of
Paradise
Percent
Butte County
Units
Town of
Paradise
Percent of
County RHNA
Very Low Income
(<50 percent of AMI) 383 5% 2,081 18%
Low Income
(50 percent-80 percent of AMI) 374 5% 1,290 29%
Moderate Income
(80 percent-120 percent of
AMI)
1,319 18% 3,202 41%
Above Moderate Income
(>120 percent of AMI) 5,103 71% 8,933 57%
Total 7,179 100% 15,506 46%
Source: Butte County Association of Governments Regional Housing Needs Plan, December 2020.

TABLE 2 TOWN OF PARADISE QUANTIFIED OBJECTIVES 2022-2030 Income Levels Construction Rehabilitation Preservation
Extremely and Very Low Income
(<50 percent of AMI) 133 30 -
Low Income
(50 percent-80 percent of AMI) 483 25 -
Moderate Income
(80 percent-120 percent of AMI) 402 0 -
Above Moderate Income
(>120 percent of AMI) 2,002 0 -
Total 3,020 55 -
No at-risk units were identified, and therefore no preservation is required at this time.

Source: Town of Paradise, 2021.

The Town of Paradise General Plan was adopted by the Town Council in 1994 and amended through 2010. The General Plan was designed to serve as a long-term guide for orderly growth and development in Paradise. The General Plan also forms the foundation for zoning, subdivision regulation, and other planning decisions. The General Plan includes seven elements, including the Housing Element and Safety Element. The Housing Element has been periodically updated though the years, with the most recent 2014-2022 Housing Element adopted in June 2014. The 1994 General Plan including the 2014-2022 Housing Element serve as the Town’s current, comprehensive and long-term plan for the future physical and orderly development of the community, consistent with the State’s regulatory requirements. The 311
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2022-2030 Housing Element is a continuance of this update process and, if adopted by the Town, would require an amendment to the General Plan for its inclusion. The Safety Element has not been updated since the adoption of the General Plan, but other planning efforts, including the Butte County Local Hazard Mitigation Plan and Butte County Community Wildfire Protection Plan, have continued to analyze and mitigate safety hazards. State legislation since the 2014-2022 Housing Element now requires the Safety Element be updated whenever the Housing Element is updated.

The proposed Housing and Safety Elements include programs which would require amendments to the Town's Municipal Code. The way in which these changes impact the physical environment in the town is the basis of the analysis provided in this Initial Study.

10. Required Approvals:

The Housing and Safety Elements require adoption by the Town of Paradise along with General Plan Amendments to incorporate the updated Elements into the General Plan.

11. Other Public Agencies Whose Approval is Required:

The Town of Paradise is the lead agency with responsibility for approving the Project. There are no other public agencies whose approval is required (e.g., permits, financing approval, or participation agreement) for the proposed Housing and Safety Elements.

The California Department of Housing and Community Development (HCD) reviews the proposed Housing Element and determines whether it complies with State law. While HCD approval is not required for the Town’s adoption of the Housing Element, certification from HCD indicates that a housing element is adequate. Similarly, the California Board of Forestry and Fire Protection reviews the Safety Element for land use considerations in high fire risk areas.

12. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? If so, has consultation begun?
The Town of Paradise started the AB 52 and SB 18 90-day Tribal Consultation opportunity period, according to Government Code Section 65352.3, by sending out certified written notices on November 2, 2021 inviting the appropriate tribes to consult on the project. The tribes that were notified are: United Auburn Indian Community of the Auburn Rancheria, Mooretown Rancheria, Mechoopda Indian Tribe, Greenville Rancheria, Berry Creek Rancheria, Enterprise Rancheria, Washoe Tribe of Nevada and California, and Konkow Valley Band of Maidu (Tribes). Two tribes responded: the United Auburn Indian Community of the Auburn Rancheria and the Berry Creek Rancheria. The United Auburn Indian Community of the Auburn Rancheria confirmed that the Project site is outside of its geographic area of traditional and cultural affiliations. The Berry Creek Rancheria tribe requested a consultation related to the sewer system and the corresponding Sewer Service Overlay Zone, and consultation occurred 312
APRIL 2022 PARADISE HOUSING AND SAFETY ELEMENTS INITIAL STUDY PUBLIC REVIEW DRAFT 5
between the tribe and the Town’s engineering department (the lead agency for the Town’s sewer project). The sewer project is a separate effort for this Project and currently undergoing its own environmental review. Upon further conversations with the tribe, the Berry Creek Rancheria shared that they did not have concerns with the Project, which is related to making land available for rebuilding and new construction of housing. Consistent with Government Code 21080.3.2, tribal consultation is considered concluded given the tribe’s input that no significant effect exists.
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Figure 1 Project Location
Source: Town of Paradise and HDR, 2021
314
Skyway
Skyway
Neal Rd
Foster Rd
Clark Rd
Clark Rd
Nunneley Rd
Stark Ln
Merrill Rd
Bille Rd
Wagstaff Rd Wagstaff Rd
Castle Dr
S Libby Rd
Edgewood Ln
Pentz Rd
Kibler Rd
N Libby Rd
Sawmill Rd
Rocky Ln
Lucky John Rd
Pentz Rd
Scottwood Rd
Redbud Dr
Town of Paradise Housing Element 2022-2030
Figure 2
Adequate Residential Sites
Source: Esri, HERE, Garmin, OpenStreetMap contributors, 2021; Town of Paradise, 2022; Urban Planning Partners, 2022.

Single-Family Rebuilds/New Construction
Proposed Sewer Service
Town of Paradise
Sewer Service Area Sites
Multi-Family Development Outside Sewer Area
N 0 125 250 500
1 inch = 500 feet
Feet
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II. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
The environmental factors checked below would be potentially affected by the Project, involving at least one impact that is a Potentially Significant Impact, as indicated by the checklist on the following pages.
 Aesthetics Resources
 Agriculture and Forestry Resources
 Air Quality
 Biological Resources
 Cultural Resources
 Energy
 Geology & Soils
 Greenhouse Gas Emissions
 Hazards & Hazardous Materials
 Hydrology & Water Quality
 Land Use & Planning
 Mineral Resources
 Noise
 Parks & Recreation
 Population & Housing
 Public Services
 Transportation & Traffic
 Tribal Cultural Resources
 Utilities & Service Systems
 Wildfire
 Mandatory Findings of Significance
Determination:

On the basis of this initial evaluation:
 I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
 I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
 I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
 I find that the proposed project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.  I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.
4/15/2022
___________________________________________________ _________________ Signature Date
Susan Hartman Environmental Review Officer
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III. ENVIRONMENTAL CHECKLIST

1. Aesthetics Resources
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Have a substantial adverse effect on a scenic
vista?
☐ ☐ ☒ ☐
b. Substantially damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic buildings within a
state scenic highway?
☐ ☐ ☒ ☐
c. In non-urbanized areas, substantially
degrade the existing visual character or
quality of public views of the site and its
surroundings? (Public views are those that
are experienced from publicly accessible
vantage point). If the project is in an
urbanized area, would the project conflict
with applicable zoning and other regulations
governing scenic quality?
☐ ☐ ☒ ☐
d. Create a new source of substantial light or
glare which would adversely affect day or
nighttime views in the area?
☐ ☐ ☒ ☐
Have a substantial adverse effect on a scenic vista? Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to a non-agricultural use?
Less Than Significant. Scenic resources in the vicinity of Paradise include the Sutter Buttes, Coastal Range, Sierra Nevada, and scenic water resources. The Town’s General Plan establishes four “gateway areas” where views of unique environmental settings are to be preserved and enhanced. These gateway areas are described below.
 Lower Skyway Gateway. An area approximately 2,000 feet in circumference along lower Skyway at the Town limits and in the western Sphere of Influence boundary. Honey Run Road goes through this gateway.
 Neal Road Gateway. An area approximately 2,000 feet in circumference right near the Town limits and in the southwestern Sphere of Influence boundary. 318
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 Lower Clark Gateway. An area of approximately 2,000 square feet in circumference along lower Clark Road (Highway 191) outside of Town limits and in the southern Sphere of Influence boundary.
 Pentz Road Gateway. An area of approximately 2,000 square feet in circumference along lower Pentz Road outside of Town limits and in the southern Sphere of Influence boundary.

In addition to the gateway areas, scenic corridors link and branch off the gateways, extending into and through town. Within Town limits, southern portions of Skyway and Neal Road are identified as scenic corridors and the entirety of Pentz Road within town is identified as a scenic corridor.

The Project does not include any specific designs or proposals, nor does it grant any entitlements for development. Implementation of the Housing Element Update would potentially lead to an increase in residential units within Paradise; however, the Town has adequate housing sites to accommodate its RHNA over the current housing cycle without annexing natural lands. Development along Pentz Road would remain low-density and the portions of the town envisioned for medium-density development in the Sewer Service Area (SSA) are in the downtown core with substantial distance from the scenic gateways. In addition, future development would be subject to objective standards in the Zoning Code and General Plan, including Section 17.06.820 Scenic highway corridors that maintain key viewsheds and prohibit incompatible uses on scenic corridors. In addition, most of the housing sites identified to accommodate the Town’s RHNA were previously developed with housing that was destroyed in the fire.

For these reasons, the Project’s impacts on scenic vistas would be less than significant.

Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? Less Than Significant. According to the California Department of Transportation, there are no eligible or designated State scenic highways in Paradise. The nearest eligible highway is Route 70 between Route 149 near Wicks and Route 89 near Blairsden. Route 70 is east of Paradise, ranging from approximately 2.5 miles away in the southeast edge of town to 6.3 miles in the northeast edge of town. Paradise is not visible from the Highway given the topography.

While the Housing Element Update encourages the provision of a range of housing types and affordability levels, it does not include any specific designs or proposals, nor does it grant any entitlements for development that would degrade the existing visual character of the Town.

Future residential development projects would be required to comply with the General Plan policies related to visual resources (e.g., OCEP-3, OCEP-5) and Municipal Code requirements associated with planning and development regulations.

As mentioned above, the Project envisions development be more clustered in the downtown core than the pre-Camp Fire (pre-Fire) conditions. Densifying areas in the middle of town that 319
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are better served by evacuation routes and utilities is compatible with maintaining the scenic resources surrounding the Town limits.

For these reasons, the Project’s impacts on scenic resources would be less than significant.

In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? Less Than Significant. While the Project encourages the provision of a range of housing types and affordability levels, it does not include any specific designs or proposals, nor does it grant any entitlements for development that would degrade the existing visual character or quality of public views within the Town. Future residential development projects would be required to comply with the General Plan policies related to visual resources (e.g., OCEP-3, OCEP-5) and Municipal Code requirements, including Section 17.06.820 Scenic highway corridors, associated with maintain the visual quality of public views of the town’s scenic surroundings.

As previously mentioned, the Project includes policies and programs to facilitate mediumdensity, multi-family development in the SSA. The SSA is in the downtown core and a substantial distance from the scenic gateways identified in the General Plan.

For these reasons, the Project would not degrade the visual character of the town and the potential impacts would be less than significant.

Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Less Than Significant. The Project does not include any specific development designs or proposals, nor does it grant any entitlements for development that would increase daytime glare or nighttime illumination in the town. Future residential development projects in Paradise would be required to be designed and constructed in accordance with Town regulations, including Municipal Code Sections 17.06.810 Lighting fixtures, which requires lighting fixture designs and placement to reflect away from nearby residences within 200 feet and to minimize glare and illumination onto adjoining or nearby properties.

For these reasons, the project would not create new sources of light or glare that could adversely affect daytime or nighttime views in the area.

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2. Agricultural and Forestry Resources
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance
(Farmland), as shown on the maps prepared
pursuant to the Farmland Mapping and
Monitoring Program of the California
Resources Agency, to a non-agricultural use?
☐ ☐ ☐ ☒
b. Conflict with existing zoning for agricultural
use, or a Williamson Act contract?
☐ ☐ ☒ ☐
c. Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code section 12220(g)),
timberland (as defined by Public Resources
Code section 4526), or timberland zoned
Timberland Production (as defined by
Government Code section 51104(g))?
☐ ☐ ☐ ☒
d. Result in the loss of forest land or conversion
of forest land to non-forest use?
☐ ☐ ☐ ☒
e. Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of
Farmland to non-agricultural use or
conversion of forest land to non-forest use?
☐ ☐ ☐ ☒
Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to a non-agricultural use? No Impact. The Project would not affect prime, unique, or farmland of statewide importance.

According to the California Department of Conservation, no potentially important farmland has been mapped in Paradise.

Conflict with existing zoning for agricultural use, or a Williamson Act contract? Less Than Significant. Paradise has no Williamson Act Contracts according to the California Department of Conservation. Paradise has agricultural zones in various areas of the Town, consistent with the open-space agricultural land use designation of the Paradise General Plan.

The project would not conflict with the existing zoning for agricultural use and therefore would have a less than significant impact.
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Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
No Impact. The Project would not affect timberland. The sites identified to satisfy the RHNA do not include timberland, according to the Paradise General Plan Land Use Element, Figure 2-1.

There would be no impact from the Project.

Result in the loss of forest land or conversion of forest land to non-forest use? No Impact. The Project would not affect forestland. The Town does not contain any lands for forest use and the Project would only affect development within the Town limits. There would be no impact to or conversion of forest land from the Project.

Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use?
No Impact. Implementation of the Project would not result in the conversion of Farmland or forest land to non-agricultural or non-forest use, respectively. The Project facilitates vegetation management and future residential development, but only within Town limits. The Town has adequate residential capacity inside the Town limits to accommodate its RHNA and implementation of the Project would not affect the agricultural or forest lands surrounding Town. The Project would have no impact.

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3. Air Quality
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Where available, the significance criteria established
by the applicable air quality management or air
pollution control district may be relied upon to make
the following determinations. Would the project:
a. Conflict with or obstruct implementation of the
applicable air quality plan? ☐ ☐ ☒ ☐
b. Result in a cumulatively considerable net
increase of any criteria pollutant for which the
project region is non-attainment under an
applicable federal or State ambient air quality
standard?
☐ ☐ ☒ ☐
c. Expose sensitive receptors to substantial
pollutant concentrations? ☐ ☐ ☐ ☒
d. Result in other emissions (such as those leading
to odors adversely affecting a substantial
number of people?
☐ ☐ ☐ ☒
Paradise is located in a region identified as the Sacramento Valley Air Basin (SVAB), which principally includes all of Sacramento, Yolo, Yuba, Sutter, Colusa, Glenn, Butte, Tehama, and Shasta counties and parts of Solano and Placer counties. This larger air basin is divided into local air districts, which are charged with the responsibility of implementing air quality programs. The project site is located in Butte County, which is under the jurisdiction of the Butte County Air Quality Management District (BCAQMD). The BCAQMD adopts and enforces controls on stationary sources of air pollutants through its permit and inspection programs and regulates agricultural and nonagricultural burning. Other district responsibilities include monitoring air quality, preparing air quality plans, and responding to citizen air quality complaints. In Butte County, the two pollutants of most concern are fine particulate matter (PM2.5) and Ozone (O3). PM2.5 is a common wintertime pollutant and Ozone is a common summertime pollutant.

Conflict with or obstruct implementation of the applicable air quality plan? Less Than Significant. Although Butte County is in non-attainment for 8-Hour Ozone, changes based on the Housing Element and Safety Element Updates would not obstruct the implementation of the air quality plan addressing this. The Northern Sacramento Valley Planning Area 2018 Triennial Air Quality Attainment Plan (2018 Air Quality Attainment Plan) proposes strategies to attain California Ambient Air Quality Standards (CAAQS) for ozone.

Ozone can be caused by stationary source emissions (e.g., internal combustion engines, boilers), mobile sources (e.g., cars, trucks, trains) or area sources (e.g., consumer products, 323
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wildfires). In addition, the Northern Sacramento Valley Planning Area (NSVPA) can experience ozone from the Broader Sacramento Area; emissions originally created in the Broader Sacrament Area can be blown north into the NSVPA and affect the NSVPA pollution levels.

The 2018 Air Quality Attainment Plan utilized existing and projected data for population, industry, and vehicle-related emissions growth. The population projections were based on data from the California Department of Finance (DOF) Demographic Research Unit. The Butte County Association of Governments 6th Cycle Regional Housing Needs Plan is likewise based on DOF population projections (in addition to data from the relevant Regional Transportation Plan).

Therefore, the housing units the Project is planning for are part of the population growth planned for in the 2018 Air Quality Attainment Plan.

The Project includes policies and programs to facilitate housing construction. However, any future construction in the Town must follow the regulations set forth by the Butte County Air Quality Management District and the Town of Paradise. For example, future residential development projects would comply with General Plan policies related to improving air quality (e.g., Policies CP-11, CP-13, CP-15, CP-17, CP-20, CP-21, and CP-23).

Environmental impacts of subsequent development projects would also be considered pursuant to CEQA on a case-by-case basis following submittal of a specific development proposal.

Therefore, implementation of the 2014-2022 Housing Element would have a less-thansignificant impact associated with obstructing implementation of the regional air quality attainment plan.

Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard?
Less Than Significant. As previously mentioned, Paradise (and all of Butte County) does not meet national standards for ozone. Future development of housing units facilitated by the implementation of Project could result in an increase in criteria pollutants during both construction and operational activities and could also contribute to the existing nonattainment status of the NSVPA for ozone. Construction activities such as excavation and grading operations, construction vehicle traffic, and wind blowing over exposed earth could generate exhaust emissions and fugitive particulate matter emissions that would affect local air quality.

This is variable depending on the weather, soil conditions, and the amount of activity taking place, as well as the nature of dust control efforts. Likewise, operational air quality impacts are dependent on the density and size of specific residential land uses.

The Project does not include any specific development designs or development proposals, nor does it grant any entitlements for development. All future development would be required to be in accordance with local regulations. Environmental impacts of subsequent development projects would also be considered, pursuant to CEQA, on a case-by-case basis following submittal of a specific development proposal. Furthermore, future residential development projects would be required to comply with General Plan policies related to air quality (e.g., 324
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Policies Cl-11. Cl-13, and Cl-16). Finally, policies and programs in the Safety Element would mitigate hazards related to poor air quality from wildfire smoke. Therefore, Project implementation would have a less than significant impact associated with contributing substantially to an existing or projected air quality violation and increasing criteria pollutants during both construction and operational activities.

Expose sensitive receptors to substantial pollutant concentrations? No Impact. The Project is a policy document. It does not include any specific development designs or development proposals, nor does it grant any entitlements for development.

Housing units facilitated by the Project would be considered sensitive receptors that could be exposed to pollutant concentrations. However, future residential development would be required to comply with General Plan policies and environmental health regulations related to pollutants, during both construction and operational activities, including national ambient air quality standards and BCAQMD thresholds. There would be no impact from the Project.

Result in other emissions (such as those leading to odors adversely affecting a substantial number of people?
No Impact. Residential developments are not considered to be an emission source that would result in objectionable odors. The Project does not include any specific development designs or development proposals, nor does it grant any entitlements for development. All future development would be required to be in accordance with local regulations. The project would have no impact.
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4. Biological Resources
Would the project:

Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Have a substantial adverse effect, either directly
or through habitat modifications, on any
species identified as a candidate, sensitive, or
special status species in local or regional plans,
policies, or regulations, or by the California
Department of Fish and Game or U.S. Fish and
Wildlife Service?
☐ ☐ ☒ ☐
b. Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional plans,
policies, regulations or by the California
Department of Fish and Game or U.S. Fish and
Wildlife Service?
☐ ☐ ☒ ☐
c. Have a substantial adverse effect on state or
federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.)
Through direct removal, filling, hydrological
interruption, or other means?
☐ ☐ ☒ ☐
d. Interfere substantially with the movement of
any native resident or migratory fish or wildlife
species or with established native resident or
migratory wildlife corridors, or impede the use
of native wildlife nursery sites?
☐ ☐ ☒ ☐
e. Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
☐ ☐ ☒ ☐
f. Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural Community
Conservation Plan or other approved local,
regional, or State habitat conservation plan?
☐ ☐ ☐ ☒
Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S.

Fish and Wildlife Service?
Less Than Significant. The Project would affect lands in the Town of Paradise. According to the US Fish and Wildlife Service, the following species are threatened, endangered, or candidate species that may be present in Butte County: yellow-billed cuckoo, giant garter snake, California red-legged frog, California tiger salamander, Sierra Nevada yellow-legged frog, delta smelt, 326
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valley elderberry longhorn beetle, fairy shrimp, vernal pool fair shrimp and vernal pool tadpole shrimp. According to the California Department of Fish and Wildlife, the following species of special concern or threatened species occur vicinity of Paradise (i.e., one of the quadrangles that Town touches): foothill yellow-legged frog, bald eagle, California spotted owl, fisher, western pond turtle, golden eagle, California black rail, western spadefoot, greater sandhill crane, long-eared owl, burrowing owl, coast horned lizard, and tricolored blackbird. State, federal, and local policies exist to protect threatened and endangered species, including the federal Endangered Species Act, California Endangered Species Act, Migratory Bird Act, and Native Plant Protection Act.

The proposed Housing and Safety Element Updates are policy level documents. While the Project encourages the provision of a range of housing types and affordability levels, it does not include any specific development designs or development proposals, nor does it grant any entitlements for development. All future residential development occurring within the Town would be required to be in accordance with local regulations addressing special status species and would be subject to CEQA review once a specific development proposal is submitted.

Furthermore, wildfire prevention and resiliency policies in the Safety Element could improve the health of the ecosystem by facilitating the use of native plant species, drought-tolerant and fireresistant landscaping, and healthy forest best management practices. The Project also seeks to facilitate the use of key parcels as open space Wildfire Risk Reduction Buffers and to concentrate more housing in the SSA near the center of town. Concentrating future development on sites located within or surrounded by already developed communities/neighborhoods is consistent with the existing General Plan policies (e.g., OCEP15, OCEP-17, OCEP-27) to preserve important natural lands and habitat areas.

For these reasons, the Project would have a less-than-significant impact on candidate, sensitive, or special status species.

Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? Less Than Significant. There are several freshwater ponds and creeks within the Town limits.

As discussed under a) above, the proposed Project is a policy-level document and it does not include any site-specific designs or development proposals, nor does it grant any entitlements for development. Future residential development resulting from Project implementation may result in adverse impacts to sensitive natural communities such as riparian habitat. However, the future development would be subject to the environmental reporting requirements of CEQA and to Paradise General Plan policies that protect natural communities (e.g., OCEP-24, OCEP-26, OCEP-27). In addition, the Project includes policies and programs to facilitate infill housing development and to create and preserve open space for Wildfire Risk Reduction Buffers. For these reasons, the Project would have a less-than-significant impact on riparian habitat and sensitive natural communities.
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Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) Through direct removal, filling, hydrological interruption, or other means? Less Than Significant. As discussed under a) and b) above, the proposed Project is a policylevel document and it does not include any site-specific designs or development proposals, nor does it grant any entitlements/or development. The potential for future development influenced by the Project to have an adverse effect on wetlands cannot be determined, as no specific details regarding future land use development are provided. Although additional impacts are not expected to result from the implementation of future individual residential projects as they relate to the sites identified to satisfy the RHNA or by the Project’s proposed regulatory changes, review would be required of these future proposals and would identify and if necessary, require avoidance or provide mitigation for any impacts to wetlands in the Town.

The adoption of the Project would have a less than significant impact.

Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Less Than Significant. As discussed above, the Project is a policy-level document and it does not include any site-specific designs or development proposals, nor does it grant any entitlements for development. The potential for future development influenced by the proposed changes to the Housing Element to interfere substantially with the movement of native resident or migratory fish or wildlife species or migratory wildlife corridors or the uses of wildlife nursery sites cannot be determined, as nonspecific details regarding future land use development are provided. Although additional impacts are not expected to result from the implementation of future individual residential projects as they relate to the sites identified to satisfy the RHNA or by the Project’s proposed regulatory changes, review would be required of these future proposals and would identify, and if necessary, require avoidance or provide mitigation for any impacts to native wildlife corridors and nursery sites. The adoption of the Project would have a less than significant impact.

Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Less Than Significant. The Project does not include any specific development proposals, nor does it grant any entitlements for development that would affect biological resources. The Project does include programs and policies to increase community awareness of best practices for vegetation management, facilitate effective fuels management programs, and increase the use of fire-resistant plantings. Such policies would enhance, not contradict, existing Town policies related to the preservation of healthy trees and biological resources, including Municipal Code Sections 8.12 Felling, removal, destruction, damaging and replacement of trees and 8.58 Defensible space and hazardous fuel management. Policies proposed by the Project 328
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are consistent with the Municipal Code and General Plan and future development under the Project would be subject to local regulations, including the Town’s tree replacement programs codified in Section 8.12.120 of the Municipal Code.

Therefore, the Project would not conflict with any local policies or ordinances protecting biological resources and potential impacts would be less than significant.

Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan or other approved local, regional, or State habitat conservation plan? No Impact. There are currently no adopted or proposed habitat conservation plans (HCPs), natural community conservation plans (NCCPs), or other approved local, regional, or State habitat conservation plans that affect the Town. The Butte Regional Conservation Plan (BRCP) is a joint HCP/NCCP currently under development, but it is for the cities of Chico, Oroville, Gridley, and Biggs, as well as lowland Butte County; Paradise is not within the proposed conservation area of this plan. Because the HCP/NCCP is not yet final and the town is not within the proposed conservation area, there would be no potential for conflict with the Project.

Moreover, the Project does not include any specific development proposals, nor does it grant any entitlements for development that would affect biological resources. There would be no impacts from the Project.

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5. Cultural Resources
Would the project:

Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Cause a substantial adverse change in the
significance of a historical resource pursuant to
Section 15064.5?
☐ ☐ ☒ ☐
b. Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to Section 15064.5?
☐ ☐ ☒ ☐
c. Disturb any human remains, including those
interred outside of formal cemeteries?
☐ ☐ ☒ ☐
a-c) Cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5? Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5? Disturb any human remains, including those interred outside of formal cemeteries?
Less Than Significant. Paradise lies within territory formerly inhabited by the Northwestern Maidu or Konkow peoples. This group of native peoples divided themselves into territorial groups known as "tribelets" or "village communities," which consisted of multiple politically confederated villages. Each tribelet was sovereign in matters of land ownership, reaction to trespass, and ceremonies. Major villages were located atop the crests of ridges high above the rivers.1
Future residential development under the Project could conflict with existing known cultural and historical resources. There is a band of land that runs across southern Paradise, roughly following Honey Run, Bushman, and Pearson Roads, that is known for archaeological sensitivity (see Figure 2-3 Land Use Constraints Diagram of the General Plan). In addition to "known" resource areas, there is the potential that there are undiscovered paleontological and archeological resources that would be encountered and potentially impacted by future construction activities. These resources could include human remains located outside of cemeteries.

While the Project encourages the provision of a range of housing types and affordability levels, it does not include any specific development designs or proposals, nor does it grant any entitlements for development that would adversely affect archaeological, paleontological, or historic resources. All future residential development occurring within the Town would be required to comply with local regulations, including General Plan policy OCEP-36, which requires development in the known archeological sensitivity area to undertake an archaeological survey and for projects outside the sensitivity area to consult the California 1 Town of Paradise, 1994. Paradise General Plan Environmental Setting Document. 330
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Archaeological Inventory, Northeast Information Center, and California State University, Chico to determine whether a survey is recommended. The Town also has policies to mitigate potential discovery of cultural resources, including ceasing work in the event of artifact discoveries (OCEI20). For these reasons, the Project’s impacts on cultural resources would be less than significant.

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6. Energy
Would the project:

Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Result in potentially significant environmental
impact due to wasteful, inefficient, or
unnecessary consumption of energy resources,
during project construction or operation?
☐ ☐ ☒ ☐
b. Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
☐ ☐ ☒ ☐
Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? Less Than Significant. Pacific Gas & Electric Company (PG&E) provides energy to Paradise.

According to the California Energy Commission, the total electricity usage in PG&E’s service area in 2020 was approximately 78,520 million kilowatt-hours (kWH).2 New housing in Paradise facilitated by the Project would lead to increased energy consumption due to both construction and operation of new residential units. Construction-related energy usage would be temporary and have a negligible contribution to the Project’s overall energy consumption. Construction contractors would have a financial disincentive to waste fuel used by construction equipment (i.e., excess fuel usage reduces profits) and therefore, it is generally assumed that energy used during construction would be conserved to the maximum extent feasible. Furthermore, regulations enforced by the California Air Resources Board (Title 13, Section 2485 of California Code of Regulations) limit the idling time of diesel construction equipment to five minutes.

In almost all cases, the sites identified for future residential development to accommodate the RHNA were previously developed with housing and almost the entirety (95 percent) of the Town’s RHNA was assigned to rebuild units lost in the Camp Fire. The potential increase in electricity consumption over baseline conditions due to operation of residential units would be comparable to the energy usage that was accommodated pre-Fire and represents a minimal increase in electricity consumption in context of the energy availability and consumption within PG&E’s service area. The Project also includes policies and programs to reduce the energy consumption of future residential households by increasing awareness of building methods and materials that increase resiliency (SP-53, SI-23) and providing assistance for low-income households to perform energy improvements (SI-2, HI-20). Future development would also comply with applicable provisions of the California Building Code related to energy efficiency. 2 CEC, 2021. “Electricity Consumption by Entity.” Available at http://ecdms.energy.ca.gov/elecbyutil.aspx. Accessed November 16, 2021. 332
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The Project includes policies and programs to encourage smaller multi-family units in infill locations well served by infrastructure (and disincentivizes density where there is poor access to evacuation routes and where wildfire risk is highest, such as parcels identified as Wildfire Risk Reduction Parcels). The type of mixed-use infill development well-served by services and infrastructure that the Project encourages tends to encourage use of public transit, walking, and biking as alternatives to private vehicles, as well as trip internalization, thereby reducing unnecessary consumption of vehicle fuels.3

For the reasons discussed above, the Project would not result in wasteful, inefficient, or unnecessary consumption of energy resources. The inclusion of policies to reduce energy consumption and facilitate development that is more energy efficient could have a positive impact on energy consumption and any impacts would be less than significant. b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency? Less Than Significant. The Project sites would not result in conflicts or obstruct plans for renewable energy. In fact, the Project includes policies and programs such as rebates and education around installing renewable energy sources and more energy-efficient building materials. It also seeks to incentivize multi-family development near services and create a more walkable pattern of development. Such policies are consistent with the Paradise General Plan (e.g., OCEG-10, OCEP-39), which addresses energy efficiency in the Open Space/Conservation/Energy Element. Impacts from the project would be less than significant.

3 Victoria Transport Policy Institute.2020. Land Use Impacts On Transport: How Land Use Factors Affect Travel Behavior. June 5.
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7. Geology and Soils
Would the project:

Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporate
d
Less Than
Significant
Impact
No
Impact
a. Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury,
or death involving:
i. Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on other
substantial evidence of a known fault? Refer
to Division of Mines and Geology Special
Publication 42.
☐ ☐ ☒ ☐
ii. Strong seismic ground shaking? ☐ ☐ ☒ ☐
iii. Seismic-related ground failure, including
liquefaction?
☐ ☐ ☒ ☐
iv. Landslides? ☐ ☐ ☒ ☐
b. Result in substantial soil erosion or the loss of
topsoil?
☐ ☐ ☒ ☐
c. Be located on a geologic unit or soil that is
unstable, or that would become unstable as a
result of the project, and potentially result in onor off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
☐ ☐ ☒ ☐
d. Be located on expansive soil, as defined in Table
18-1-B of the Uniform Building Code (1994),
creating substantial direct or indirect risks to life
or property?
☐ ☐ ☒ ☐
e. Have soils incapable of adequately supporting
the use of septic tanks or alternative wastewater
disposal systems where sewers are not available
for the disposal of waste water?
☐ ☐ ☐ ☒
f. Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
☐ ☐ ☒ ☐
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Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42;
ii) Strong seismic ground shaking;
iii) Seismic-related ground failure, including liquefaction; Less Than Significant. The Project includes policies and programs designed to facilitate the construction and conservation of housing, which could increase exposure of people and structures to seismic hazards, including rupture of a fault, strong seismic shaking, and seismicrelated ground failure. There are no known or inferred active faults within the town and none of the sites identified to satisfy the RHNA are located within an Alquist-Priolo zone. The only known active fault in Butte County is the Cleveland Hills fault, the site of the August 1975 Oroville earthquake. This earthquake had a Richter magnitude of 5.7. Due to the proximity of the Town to the nearby Cleveland Hills Fault, the Town can expect low to medium intensity shocks from time to time. The town is considered to be at a low risk of hazards from liquefaction.

The Safety Element also includes policies to minimize risk and vulnerability of the community to hazards and reduce damages. Furthermore, all future residential development would be required to be in compliance with local and State regulations, including the General Plan, Zoning Ordinance and the Alquist-Priolo Earthquake Fault Zoning Act. Environmental impacts of subsequent development projects would also be considered pursuant to CEQA on a case-bycase basis following submittal of a specific development proposal. Applicants would also have to work with the Town of Paradise Building Department to implement the proper structural specifications. The California Building Code ensures that structures be built according to required seismic standards and designed to withstand such events. Future residential development related to the Project would be required to meet the California Building Code requirements. For these reasons, potential impacts related to seismic conditions would be less than significant.
iv) Landslides?
Less Than Significant. Landslides are most likely on hillsides where rock strata parallels surface slopes, high clay content absorbs excess water, displacement has fractured a fault zone, or the base of a slope has been removed by erosion or people. The majority of Paradise is at a low to moderate risk of landslide. The areas surrounding the town are where the topography most dramatically changes and are at greater risk to landslide. The northern edge of town and pockets in the southern and western edges are at moderate risk and the Town limits on the east abut and at times overlap an area of high potential landslide risk. 335
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The Project includes policies and programs designed to facilitate the construction and conservation of housing, which could increase exposure of people and structures to landslides.

The Project includes policies to facilitate clustering development in the SSA, which is primarily contained within the area of low landslide risk. The Safety Element also includes policies and programs to minimize risk and vulnerability of the community to hazards and reduce damages.

The Town also has policies to prohibit development on steep slopes where landslide and ground failure are a greater concern; development on slopes exceeding 20 percent are required to submit erosion control plans and slope stabilization programs. Development is prohibited on slopes exceeding 30 percent. Consistency with local and State policies, including the California Building Code, would ensure future development under the Project is designed to reduce landslide risks. The Project, which is at the policy level, would have less than significant impacts related to exposing people to landslides.

Result in substantial soil erosion or the loss of topsoil? Less Than Significant. Future construction related to the Project could result in the moving and grading of topsoil, which could lead to disturbed soils that are more likely to suffer from erosion from a variety of sources, such as wind and water. However, as discussed above, the Project is a policy-level document that does not propose any specific development and does not directly result in adverse impacts associated with substantial loss of topsoil or erosion. Any future residential developments would be subject to Building and Safety codes that address grading and the environmental analysis requirements of CEQA. In addition, any future development would be required to prepare a stormwater pollution prevention plan (SWPPP) in compliance with the Regional Water Quality Control Board’s (RWQCB) General Construction Storm Water Permit. SWPPPs ore required to identify best management practices to minimize soil erosion and protect existing drainage systems during construction. Compliance with the State's General Construction Storm Water Permit minimizes soil erosion and loss of topsoil associated with development. Impacts from the Project would be less than significant. c-d) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code, creating substantial risks to life or property?
Less Than Significant. Expansive or shrink-swell soils are soils that swell when subjected to moisture and shrink when dry. Expansive soils typically contain clay minerals that attract and absorb water, greatly increasing the volume of the soil. This increase in volume can cause damage to foundations, structures, and roadways. Standard procedures used in the construction of concrete footings as required by the California Building Code address this potential impact of future development pursuant to the Project. Future development facilitated by the Project could be on unstable or expansive soils, but compliance with existing regulations like the California Building Code and CEQA would decrease any risks. The policies included in 336
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the Project seek to minimize the risk of hazards through community education, land use planning, and development standards. Impacts from the Project would be less than significant. e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? No Impact. The wastewater infrastructure in Paradise and throughout the unincorporated areas immediately adjacent to town has relied on septic and leach field systems in past years and will continue to do so during the 2022-2030 Planning Period of the Housing Element. This situation is a viable alternative for new development at lower densities, but not for development at densities of 10 units per acre or higher. Development in Paradise is constrained by the lack of a community wastewater collection and treatment system. The use of clustered wastewater treatment systems, which combine several discharges, treat the waste in one biological treatment plant to a high-quality level, and discharge to subsurface land disposal, is one alternative design that is accepted by the Town and serves as a means to allow development to move forward without the impacts that are associated with the septic leach line systems that currently serve most Paradise. This alternative can be feasible for a larger project, or a consortium of property owners, but is a constraint to small individual projects due to the relatively high cost.

The Project includes a program (HI-1) to continue planning for a sewer system and to provide education to property owners and other stakeholders as planning continues. Program HI-5 would create a zoning overlay to allowed increased densities in the SSA. The Paradise Sewer Project is undergoing its own CEQA review (an EIR began in fall 2020) and the Project under review in this CEQA document does not propose to construct, nor does it require the construction of, such a sewer system. All future housing would be required to comply with the Town's wastewater regulations, including the determination of whether a project site's soils could support a septic system or other type of wastewater disposal. As such, implementation of the Project would have no impact in this area.
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less Than Significant. The Project does not include any specific development designs or proposals, nor does it grant any entitlements/or development that would adversely affect paleontological or unique geological features. All future residential development occurring within the Town pursuant to the Project would be required to comply with local regulations, including General Plan program OCEI-20, which requires work to immediately stop should any artifacts be discovered during construction. Impacts from the Project would be less than significant.

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8. Greenhouse Gas Emissions
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Generate greenhouse gas emissions, either
directly or indirectly, that may have a significant
impact on the environment?
☐ ☐ ☒ ☐
b. Conflict with an applicable plan, policy, or
regulation adopted for the purpose of reducing
the emissions greenhouse gases?
☐ ☐ ☒ ☐
In 2006, the California State Legislature passed the California Global Warming Solutions Act (AB 32), which requires public agencies in California to support the stateside goal of reducing greenhouse gas (GHG) emission to 1990 levels by 2020. In 2016, the State legislature adopted Senate Bill (SB) 32, which requires further reduction of GHG emissions to 40 percent below the 1990 level by 2030. In addition, Executive Order S-3-05 set a GHG reduction goal of 80 percent below 1990 levels by 2050.
a-b) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions greenhouse gases? Less Than Significant. The Town of Paradise does not have a local GHG emission reduction plan, but the General Plan does include policies to increase energy efficiency (e.g., OCEG-10, OCEP-39). Future residential development related to the Project could result in an increase in GHG emissions from construction (e.g., operation of on-site heavy construction equipment, offsite construction vehicle trips) and operation (e.g., direct and indirect combustion of fossil fuels for generation of heat and electricity, decomposition of solid waste, wastewater treatment).

As previously discussed, in almost all cases, the sites identified for future residential development to accommodate the RHNA were previously developed with housing and almost the entirety (95 percent) of the Town’s RHNA was assigned to rebuild units lost in the Camp Fire. The potential increase in GHG emissions due to construction and operation of residential units would be comparable to pre-fire emissions. New units replacing destroyed units would be more energy efficient than previous residences given improved technologies and fixtures and updated requirements. The majority of the Town’s housing stock pre-fire was built between 1951 and 1970. New construction to replace the destroyed homes would be required to comply with Title 24 Building Energy Efficiency Standards and Green Building Standards. The Title 24 energy standards became effective January 1, 2020 and include residential building standards 338
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related to energy efficient lighting, HVAC systems, walls, water heating, and attics.4 According to the California Energy Commission, carbon dioxide (CO2) emissions will be reduced by 700,000 metric tons during the three-year cycle of these energy standards. 5 Furthermore, the Project also includes policies and programs to further reduce the energy consumption of future residential households by increasing awareness of building methods and materials that increase resiliency (SP-53, SI-23), assisting low-income households to perform energy improvements (SI-2, SP-73, HI-20), and providing incentives for efficient air conditioning or cooling (SP-24, SI-9). The Project also includes policies to increase the use of low-water-use, drought-tolerant plant species in parks and private development (SP-51).

The Town’s ongoing recovery has emphasized increased walkability. The construction of a transit center and grade-separated multi-use bicycle and pedestrian pathways along key evacuation routes are two planned multi-modal transportation improvements included in the Town’s list of disaster recovery projects. The Paradise Transit Center is a shovel-ready project seeking construction funding and the multi-modal pathway is currently in the planning phase as part of the Transportation Master Plan. The Project builds on the Town vision for increased walkability. The Project seeks to incentivize multi-family development near services and create a more walkable pattern of development through the SSA zoning overlay. Such policies could reduce GHG emissions by encouraging use of public transit, walking, and biking as alternatives to private vehicles and by creating trip internalization.

For the reasons outlined above, the Project is consistent with the Town of Paradise General Plan energy goals, AB 32, and State’s GHG reduction goals. Potential impacts on GHG emissions would be less than significant.

4 Title 24 also requires rooftop solar installations, but Assembly Bill 178 (2019) exempts those rebuilding after wildfires are exempt from this requirement if they rebuild before January 1, 2023. 5 California Energy Commission. Frequently Asked Questions – 2019 Building Energy Efficiency Standards. Available at https://www.energy.ca.gov/sites/default/files/2020- 06/Title24_2019_Standards_detailed_faq_ada.pdf. Accessed on November 16, 2021. 339
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9. Hazards and Hazardous Materials
Would the project:

Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Create a significant hazard to the public or the
environment through the routine transport, use,
or disposal of hazardous materials?
☐ ☐ ☒ ☐
b. Create a significant hazard to the public or the
environment through reasonably foreseeable
upset and accident conditions involving the
release of hazardous materials into the
environment?
☐ ☐ ☒ ☐
c. Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within ¼-mile of an existing or proposed school?
☐ ☐ ☒ ☐
d. Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a
result, would it create a significant hazard to the
public or the environment?
☐ ☐ ☒ ☐
e. For a project located within an airport land use
plan or, where such a plan has not been adopted,
within 2 miles of a public airport or public use
airport, would the project result in a safety hazard
or excessive noise for people residing or working
in the Project area?
☐ ☐ ☐ ☒
f. Impair implementation of or physically interfere
with an adopted emergency response plan or
emergency evacuation plan?
☐ ☐ ☒ ☐
g. Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or
death involving wildland fires.
☐ ☐ ☒ ☐
a-c) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within ¼-mile of an existing or proposed school?
Less Than Significant. Operations of future residential development does not typically include the routine transport, use, or disposal of hazardous materials. Any future development projects that do have the potential for using or containing hazardous substances or materials must be reviewed by the Butte County Environmental Health Department for compliance with applicable state and local regulations. The department, which is the Certified Unified Program Agency 340
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(CUPA) for all cities and unincorporated areas in Butte County, is responsible for consolidating, coordinating, and making consistent the administrative requirements, permits, inspections, and enforcement activities of State programs regarding the transportation, use, and disposal of hazardous materials in Butte County. All land uses that handle or store hazardous materials are subject to inspections by the Environmental Health Department, which ensure compliance with State and federal laws intended to prevent potential hazards to the public and the environment.

Moreover, the Project includes policies and programs to facilitate the safe and effective management of hazardous wastes, including the identification of preferred transportation routes for hazardous wastes (SP-22), reduction of waste incentive programs, (SI-7) and community education on proper hazardous waste disposal (SI-15). Such programs could reduce risk and damages related to hazardous materials. Impacts from the Project would be less than significant.
d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
Less Than Significant. The Town of Paradise has one case that is listed as open on the State Water Resources Control Board GeoTracker website. The case is related to a 500-gallon underground storage tank discovered during Camp Fire debris removal southeast of the Clark Road/Cypress Lane intersection. Although the tank has been removed, the case is under investigation and kerosene is the potential contaminant of concern. The hazardous waste site (1620 Cypress Lane) is zoned for Community Services, is outside the SSA, and is not identified as a site for future residential development to accommodate the RHNA. There are sites identified for residential development near the hazardous site though, and it is possible that development under on those sites could locate residential development on a site impacted by hazardous materials listed on the Cortese list. All development pursuant to the Project would be reviewed against local, State, and federal regulations and cleaned up to residential use standards in conjunction with development of the site. As mentioned above, the Project includes policies and programs that could reduce risk and damages related to hazardous materials. Impacts from the Project would be less than significant. e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? No Impact. The Paradise Skypark Airport is a privately-owned, public use airport located south of the Town limits. Airport-related hazards are generally associated with aircraft accidents, particularly during takeoffs and landings. Airport operation hazards include incompatible land uses, power transmission lines, wildlife hazards (e.g., bird strikes), and tall structures that present collision hazards and radar interferences. Land uses around airports are subject to the limitations established by the Airport Land Use Commission through the adoption of Airport Land Use Compatibility Plans. The Butte County Airport Land Use Compatibility Plan provides compatibility criteria for use by local jurisdictions in review of proposed development. There are 341
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a few parcels identified in the Project for single-family rebuilds/new construction in the Airport Compatibility Zone and a few parcels in the SSA identified in the Project for medium-density multi-family residential development in the Airport Influence Zone.

As discussed under a-d) above, the Project does not include any specific development designs or proposals, nor does it grant any entitlements for development. The development of future housing pursuant to the Project would be required to comply with CEQA and the Town's environmental review regulations and would be checked for compliance with the Butte County Airport Land Use Compatibility Plan. This is consistent with policy and programs (e.g., SP-29, SI12) of the Safety Element update. There would be no impacts from the Project. f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less Than Significant. The Town of Paradise Emergency Operations Plan (EOP) (November 2011) addresses the Town’s planned response to extraordinary emergency situations associated with natural disasters, technological incidents, and national security emergencies in or affecting the Town of Paradise. The EOP establishes the emergency management organization required to mitigate any significant emergency or disaster and identifies the roles and responsibilities required to protect the health and safety of Paradise residents and public and private property. The EOP also establishes the operational concepts associated with a field response to emergencies, the Town of Paradise Emergency Operations Center (EOC) activities, and the recovery process. The goals of the EOP are to mitigate hazards, meet basic human needs, address needs of people with access and functional needs, restore essential services, and support community and economic recovery. Future housing development pursuant the Project would not interfere with the EOP. Furthermore, the Safety Element would facilitate implementation of the EOP by working to mitigate hazards and increase public awareness around emergency preparedness, consistent with the EOP goals.

As shown in Figure 3, the main evacuation routes in Paradise are along Skyway, Clark Road, and Pentz Road. Each of these roads runs north-south and secondary evacuation routes run eastwest to connect residents to these roads. Specific evacuation routes will vary depending on the emergency’s location, direction, and rate of spread. As shown in Figure 4, the town is split into 14 evacuation zones. The zones allow officials to designate specific areas for evacuation advisories based on the emergency. The Town also has four designated assembly points.

Assembly points are used to gather evacuees for immediate safety in situations where evacuation routes are not accessible or residents need assistance evacuating.

In addition, the Town’s Transportation Master Plan (TMP) was developed in response to the Camp Fire and includes analysis and recommendations related to local road safety, evacuation planning, parking, and circulation/roadway improvements. The TMP provide recommendations related to emergency and traffic control plans; public-facing evacuation literature, websites, and maps; transportation improvements to address serious injury and fatal crashes and increase evacuation capacity; multi-agency coordination and agreement recommendations to facilitate an 342
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evacuation beyond the Town limits; and contraflow travel and controls during emergency events. Figure 3 shows the planned roadway improvements to repair damage from the Camp Fire and improve evacuation operations.
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Figure 3 Evacuation Routes
Source: Town of Paradise and Headway, 2021.
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Figure 4 Evacuation Zones
Source: Town of Paradise, 2022.
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Finally, the Butte County Local Hazard Mitigation Plan (LHMP) also provides guidance on evacuation and emergency response. A component of Goal 4 of the LHMP is to “improve communities’ circulation, ingress and egress, and primary and secondary evacuation routes during disasters.” The LHMP identifies several high-priority actions relative to evacuation, including Action 4 to outfit Sheriff patrol cars with special sirens to be used during evacuation, Action 6 to develop a Butte County Fairground Emergency Shelter Operation Plan to improve operation of the fairground as an emergency evacuation shelter, Action 8 to expand the capacity of the Butte County Fairground to shelter more evacuees, and Actions 12 through 15 to make improvements to Cohasset Road, Concow Road, Skyway, Neal Road, Pentz Road, Hone Run Road and Centerville Road. The LHMP was adopted in 2019 and is annually reviewed by the Butte County Office of Emergency Services. The Project incorporates by reference the LMP and would facilitate, not impair, implementation of the LHMP.

The Project identifies parcels throughout the town as locations for potential future residential development to accommodate the RHNA. All sites would be located within one of the Town’s existing evacuation zones and future development pursuant to the Project would not physically interfere with the Town’s existing evacuation plans and policies nor with the improvements identified in the TMP. Instead, the Project facilitates smoother evacuation procedures by including programs and policies to cluster development and critical services in areas near evacuation routes; discourage development with poor evacuation access (SP-5, SP-30, SP-41); and provide education on emergency response and evacuation plans (SI-16), including evacuation simulations (SP-43, SI-19). Development in areas that is not as well-served by evacuation routes would be disincentivized through an impact fee or overlay zone (SP-46) and the Town would prohibit any increase of existing residential density on parcels that are served access by either an existing or resultant cul-de-sac exceeding a maximum length of 1,800 lineal feet (SI-19). Similarly, development of critical facilities in wildfire risk reduction buffers would be prohibited (SI-13).

The Project’s programs and policies are consistent with the EOP, Town evacuation plans, draft TMP (scheduled for review and adoption by the Town Council May 10, 2022), and LHMP. For these reasons, the Project would have a less-than-significant impact related to impairing or interfering with emergency response and evacuation.
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
Less Than Significant. Wildfires are a major hazard in Butte County and in the State of California. Wildland fires burn natural vegetation on developed and undeveloped lands and include timber, brush, woodland, and grass fires. While low intensity wildfires have a role in the ecosystem, wildfires put human health and safety, structures (e.g., homes, schools, businesses), air quality, recreation areas, water quality, wildlife habitat and ecosystem health, and forest resources at risk. Wildland fire hazards exist in varying degrees over approximately 70 percent of Butte County. The highest wildfire risk to human health and safety occurs in the 346
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foothill communities, including in Paradise. This area is considered a wildland-urban interface (WUI). Fires that occur in the WUI affect natural resources as well as life and property. During the past decade, Butte County has experienced several large and damaging wildfires in and around the wildland-urban interface areas, including Paradise. In November 2018, Paradise and some surrounding areas in Butte County faced one of the most destructive wildfires in California history. This fire, known as the 2018 Camp Fire, resulted in the loss of 85 lives, nearly 19,000 structures, the burning of more than 150,000 acres over two weeks, and $9 billion in insurance claims. It took less than six hours for the Camp Fire to destroy over 90 percent of Paradise. The vast majority of the town is identified by CAL FIRE as a very high fire hazard severity zone (VHFHSZ).

The Project identifies parcels throughout the town as locations for potential future residential development to accommodate the RHNA, including sites that are in the VHFHSZ. Future development would expose people or structure to wildland fire risk. However, the Project includes policies and programs to reduce fire risk, including but not limited to the creation of Wildfire Risk Reduction Buffers, the clustering of development in the SSA where it is flatter and easier to evacuate, establishment and enforcement of fuels management programs and education, analysis and potential implementation of more stringent fire-resistant building requirements, and implementation of community-wide evacuation drills. Such policies and programs would reduce the risk of loss, injury, or death due to wildfire.

As discussed above, the Project is a policy-level document that does not propose any specific development designs or proposals, nor does it grant any entitlements for development.

Potential wildland fire impacts to subsequent development projects would also be considered pursuant to CEQA on a case-by-case basis following submittal of a specific development proposal. Future development in the WUI would also be subject to applicable California Building Code and Board of Forestry requirements for development in the VHFHSZ. For these reasons, this impact is considered less than significant.

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10.Hydrology and Water Quality
Would the project:

Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Violate any water quality standards or waste
discharge requirements or otherwise substantially
degrade surface or ground water quality?
☐ ☐ ☒ ☐
b. Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge
such that the project may impede sustainable
groundwater management of the basin?
☐ ☐ ☒ ☐
c. Substantially alter the existing drainage pattern of the site or area, including through the alteration of
the course of a stream or river or through the
addition of impervious surfaces, in a manner
which would:
i. Result in a substantial erosion or siltation
on- or off-site;
ii. substantially increase the rate or amount
of surface runoff in a manner which would
result in flooding on- or offsite;
☐ ☐ ☒ ☐
☐ ☐ ☒ ☐
iii. create or contribute runoff water which
would exceed the capacity of existing or
planned stormwater drainage systems or
provide substantial additional sources of
polluted runoff; or
☐ ☐ ☒ ☐
iv. impede or redirect flood flows? ☐ ☐ ☒ ☐
d. In flood hazard, tsunami, or seiche zones, risk
release of pollutants due to project inundation?
☐ ☐ ☐ ☒
e. Conflict with or obstruct implementation of a
water quality control plan or sustainable
groundwater management plan?
☐ ☐ ☒ ☐
Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
Less Than Significant. Paradise is within the jurisdictional boundaries of the Central Valley Regional Water Quality Control Board (RWQCB), one of nine regional boards in the state. The Central Valley RWQCB develops and enforces water quality objectives and implementation plans that safeguard the quality of water resources in its region. 348
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Future residential development under the Project could result in both construction and operational impacts to water quality and discharge standards. Potential operational impacts include the use of fertilizers, herbicides, and pesticides to maintain lawns, as well as motor vehicle operation and maintenance. Potential construction impacts include grading and vegetation removal activities that would result in the exposure of raw soil materials to the natural elements (wind, rain, etc.). All future residential development occurring in the town would be required to comply with all applicable regulations, including the requirements of the National Pollutant Discharge Elimination System (NPDES) Stormwater Permits enforced by the RWQCB. The NPDES permits require water quality and watershed protection measures for all development projects and prohibit discharges that would violate applicable water quality standards or result in conditions that create a nuisance or water quality impairment in receiving waters. Project construction contractors are also required to prepare a stormwater pollution prevention plan (SWPPP) pursuant to RWQCB standards and subject to RWQCB review and approval. The SWPPP must include measures to reduce or eliminate erosion and runoff into waterways during construction.

The Town of Paradise is the largest unsewered incorporated community in California.

Wastewater treatment facilities in Paradise consist of privately owned septic tanks and soil absorption disposal systems known as leach fields, together with several engineered subsurface disposal systems serving commercial and institutional facilities. The Project includes a program (HI-1) to continue planning for a sewer system and to provide education to property owners and other stakeholders as planning continues. Program HI-5 would create a zoning overlay to allowed increased densities in the SSA. The Paradise Sewer Project is undergoing its own CEQA review (an EIR began in fall 2020) and the Project under review in this CEQA document does not propose to construct, nor does it require the construction of, such a sewer system. All future housing would be required to comply with the Town's wastewater regulations, including the determination of whether a project site's soils could support a septic system or other type of wastewater disposal. If groundwater is present anywhere on the subject parcel for development, the Town requires soils testing to determine whether an alternative wastewater is necessary.

The test holes are dug in the presence of the Town’s Onsite Sanitation Division Onsite Official.

Water quality is reviewed for contamination through creek and groundwater monitoring performed by the Onsite Division.

For the reasons discussed above, the Project would have a less than significant impact on water quality.

Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Less Than Significant. The primary source of water in Paradise is treated surface water from Magalia Reservoir and Paradise Reservoir. Groundwater supplies make up only a very small portion of the potable water supplies used to serve Paradise. Groundwater is therefore not 349
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anticipated to be impacted by future development pursuant to the Project and impacts would be less than significant.

Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i. result in a substantial erosion or siltation on- or off-site; ii. substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite;
iii. create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or
iv. impede or redirect flood flows?
Less Than Significant. The Project identifies sites for future potential housing development and encourages a range of housing types at varying affordability levels. The Town has adequate vacant land that was previously developed and destroyed in the Camp Fire to accommodate its RHNA. If development of housing were to occur in previously undeveloped areas, increased impervious surfaces and grading and vegetation removal activities could increase surface runoff and potentially contribute to the potential for localized flooding and/or erosion. Future residential development in the town would be required to comply with NPDES stormwater permit requirements, California Building Code, and Town requirements related to erosion and drainage (e.g., Paradise Municipal Code Sections 8.56.130 - Watercourse protection and

17.06.800 - Slope limitations). Finally, the Project includes policies and programs to reduce the risks related to localized flooding (e.g., SI-6, SP-27), including a policy to update the Storm Drain Master Plan. Impacts from the Project would be less than significant.

In flood hazard, tsunami, or seiche zones, risk release pollutants due to project inundation? No Impact. Paradise’s location on a ridge makes it less susceptible to flooding and it does not have any designated flood hazard areas as depicted on the Federal Emergency Management Agency (FEMA) Digital Flood Insurance Rate Map (DFIRM). The entire Town of Paradise is located outside both the 1 percent and 0.2 percent annual chance flood zone as defined by FEMA. It is not located near any ocean, coast, or seiche hazard areas. Any flooding that occurs is localized in nature, resulting from a temporary lack of capacity or blockage of a drainage basin.

According to the Butte County Local Hazard Mitigation Plan, dam failure is unlikely in Paradise and limited in severity. The Paradise Dam north of the town is considered an Extremely High Hazard dam for inundation, but the inundation area is completely outside of the Town limits.

The Project includes policies and programs to reduce the risks related to localized flooding (e.g., SI-6, SP-27).
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Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Less Than Significant. The Central Valley Regional Water Quality Control Plan (Basin Plan) is the water control plan for Paradise’s hydrologic area. The Basin Plan identifies objectives and implementation measures to protect water quality in the RWQCB’s jurisdiction. Any future residential development identified within a water quality control or sustainable ground water management plan area would be required to follow it. Impacts from the Project would be less than significant.

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11.Land Use and Planning
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Physically divide an established community? ☐ ☐ ☐ ☒
b. Cause a significant environmental impact due to
a conflict with any land use plan, policy, or
regulation adopted for the purpose of avoiding
or mitigating an environmental effect?
☐ ☐ ☒ ☐
Would the project physically divide an established community? No Impact. The parcels identified by the Project for future potential development to accommodate the Town’s RHNA are scattered throughout the town and intermixed with existing residential and mixed-use neighborhoods. The Project does envision denser development in the SSA where wastewater constraints would dissipate with the sewer system, but the SSA stretches through the majority of town and multi-family development is still envisioned and allowed outside of the SSA using clustered wastewater alternatives. The Project would not physically divide an established community. No impact would result from the Project.

Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Less Than Significant. The Housing Element proposes changes to the existing Municipal Code and Zoning Map, including 12 sites to rezone and the creation of a new zoning overlay. Table 2 shows the sites in the SSA identified for rezoning. These sites were selected for a rezoning because either 1) the landowner does not have plans to rebuild the destroyed previous use and therefore new uses that leverage the site’s position in the SSA are an opportunity to meet the Town’s housing goals or 2) the previous, pre-fire use was non-conforming and the rezoning enables the previous use to return more easily. All sites in Table 3 would require an amendment to their General Plan Land Use designation in addition to rezoning. 352
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Increased density in the SSA and other related policy changes are consistent with the General Plan, which includes an assumption that “a sewer system may be constructed” during the life of the General Plan and objective LUO-10 to “consider the construction and installation of a formal sewer system to service the commercial and industrial areas in the town.” The concentration of density along the Town’s main arterials going through the middle of town – where the town tends to be flatter and closer to evacuation routes, where traffic can be better accommodated, and where infrastructure constraints for wastewater would be alleviated with a potential sewer system – is consistent with the General Plan’s guiding principal to use environmental and infrastructure constraints to determine future zoning classifications and with General Plan policies and programs (e.g., LUP-2, LUP-19, LUP-45, LUP-48). Allowed increased density in the TABLE 3 SEWER AREA REZONING
APN Address Acreage
Current
General
Plan
Proposed
General
Plan
Current
Zoning
Current
Allowed
Density
Proposed
Zoning
Proposed
Density
052-080-084-
000
Luther Dr 0.23 TR C-S TR 1/3 2 CS 20 du/ac
052-080-083-
000
805 Luther
Dr 0.48 TR C-S TR 1/3 2 CS 20 du/ac
052-080-090-
000
806 Luther
Dr 0.53 TR C-S TR 1/3 2 CS 20 du/ac
052-080-089-
000
804 Luther
Dr 0.52 TR C-S TR 1/3 2 CS 20 du/ac
052-080-069-
000
784 Luther
Dr 0.31 TR C-S TR 1/3 2 CS 20 du/ac
052-191-009-
000
3851 Honey
Run Rd 0.68 RR CC RR 1/2 2 CB 30 du/ac
052-193-017-
000
3858 Honey
Run Rd 2.45 TR CC TR 1/3 2 CB 30 du/ac
053-080-038-
000
100
Brookwood
Cir

0.51 TR TC TR 1/3 2 CC 30 du/ac
053-111-034-
000
931 Elliott
Road 4.35 CS M-R CS 0 MF 30 du/ac
052-204-001-
000
5680 Black
Olive Drive 0.29 PI C-C CF 1 du/ac CB 30 du/ac
Source: Town of Paradise, 2021.
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SSA to provide more opportunity for affordable housing and different types of housing is consistent with the General Plan’s policies to encourage a range of residential densities sufficient to meet the needs of residents (e.g., LUG-13, LUG-17).

Although the Project requires amendments to the General Plan and zoning map, these changes are not CEQA impacts in and of themselves. Instead, the proposed changes are consistent with the principal of using environmental and infrastructure opportunities and constraints to determine land uses and intensities. The potential future housing on these sites would also be consistent with surrounding uses. The Project is consistent with the General Plan and would not conflict with policies or regulations adopted for the purpose of avoiding or mitigating an environmental effect. Impacts from the Project would be less than significant.

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12.Mineral Resources
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Result in the loss of availability of a known
mineral resource that would be of value to the
region and the residents of the State?
☐ ☐ ☐ ☒
b. Result in the loss of availability of a locallyimportant mineral resource recovery site delineated on a local general plan, specific plan,
or other land use plan?
☐ ☐ ☐ ☒
a-b) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State? Result in the loss of availability of a locallyimportant mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan?
No Impact. The proposed sites identified to satisfy the RHNA are located within already established communities and/or neighborhoods where no known mineral resource would be foregone by possible residential development. The Town of Paradise is not classified by the Department of Conservation as having any Mineral Land Classification. 6 The Project would have
no impact on mineral resources.

6 California Department of Conservation, 2021. CGS Information Warehouse: Mineral Land Classification. Available at
https://maps.conservation.ca.gov/cgs/informationwarehouse/index.html?map=mlc. Accessed on November 12, 2021.
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13.Noise
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project result in:
a) Generation of a substantial temporary or
permanent increase in ambient noise levels in
the vicinity of the project in excess of
standards established in the local general
plan or noise ordinance, or applicable
standards of other agencies?
☐ ☐ ☒ ☐
b) Generation of excessive groundborne
vibration or groundborne noise levels?
☐ ☐ ☒ ☐
c) For a project located within the vicinity of a
private airstrip or an airport land use plan or,
where such a plan has not been adopted,
within 2 miles of a public airport or public use
airport, would the project expose people
residing or working in the project area to
excessive noise levels?
☐ ☐ ☐ ☒
a-b) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Generation of excessive ground borne vibration or ground borne noise levels?
Less Than Significant. Project implementation could indirectly facilitate the construction of new housing in the future. The primary sources of noise associated with new housing development and operation are construction noise (short-term) and increased noise from vehicle traffic (operational). Housing is not typically considered a major source of noise, but new residential construction would generate temporary short-term sources of noise that would be subject to the Town’s allowable construction time periods. Increases in noise associated with vehicle traffic would be relatively minor, as the majority of the new residential development anticipated over the life of the Housing Element would be spread throughout the town. The Project does include policies related to infrastructure improvements, but these larger projects, including the Paradise Sewer Project, are independent of the Housing and Safety Element Updates and subject to their own CEQA review. Similarly, individual housing projects build under the Project would be subject to individual CEQA review, and a determination of potential noise impacts, and mitigation measures (if needed) would be identified. Future construction and operation would also be subject to the Town’s General Plan policies and Noise Ordinance, including noise performance standards and community noise exposure compatibility. Impacts from the Project would be less than significant.
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For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within 2 miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
No Impact. The nearest airport to the Town is the Paradise Skypark Airport. Development within the vicinity of the Paradise Skypark Airport is subject to the rules and requirements of the Butte County Airport Land Use Compatibility Plan, which restricts residential development within the airport overflight zones and within certain noise contour boundaries. Future development will be reviewed against the Airport Land Use Compatibility Plan and subject to CEQA. The Project does not include any specific development designs or proposals, nor does it grant any entitlements for development. The Project would have no impact.

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14.Population and Housing
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Induce substantial unplanned population growth
in an area, either directly (for example, by
proposing new homes and businesses) or
indirectly (for example, through extension of
roads or other infrastructure)?
☐ ☐ ☒ ☐
b. Displace substantial numbers of existing people
or housing, necessitating the construction of
replacement housing elsewhere?
☐ ☐ ☐ ☒
Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
Less Than Significant. The Project contains goals, policies, and program to encourage housing to meet Paradise’s housing needs and would therefore accommodate growth rather than induce it. The 2022-2030 RHNA for the Project’s planning period is 7,179 units. The vast majority of the Town’s RHNA (95 percent) was allocated to rebuild and recovery from the Camp Fire; only 5 percent of the Town’s RHNA is to accommodate regional growth. The Project identifies land suitable to accommodate the RHNA and establishes policies and programs to ensure safe and decent housing. Future residential development in the town would be required to comply with local regulations and CEQA. Impacts from the Project would be less than significant.

Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
No Impact. The population of Paradise remained relatively constant, within a few hundred people, between 2000 and 2018. The Town was projected to reach a population of 29,547 by 2030, a growth rate of less than 1 percent per year, which is about half as much growth as was expected for Butte County. However, according to California Department of Finance estimates, the 2018 Camp Fire led to a population decrease from 26,581 as of January 1, 2018 to 4,474 as of January 1, 2019. Population has since increased to 6,046 as of January 1, 2021.

As mentioned above, almost the entirety of the Town’s RHNA is to rebuild housing for those who lost their homes in the Camp Fire. The Project includes policies and programs to facilitate recovery and allow residents who have been displaced to return. The sites identified for residential development are all vacant properties or underutilized commercial properties. The realization of development of the sites identified to satisfy the RHNA would therefore not displace existing housing or create a situation where replacement housing would be necessary. 358
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The Project does not include any specific development designs or proposals, nor does it grant any entitlements for development. There would be no impact.

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15.Public Services
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Result in substantial adverse physical impacts
associated with the provision of new or
physically altered governmental facilities, or the
need for new or physical altered governmental
facilities, the construction of which could cause
significant environmental impacts, in order to
maintain acceptable service ratios, response
times or other performance objectives for any of
the public services:

1. Fire Protection? ☐ ☐ ☒ ☐

2. Police Protection? ☐ ☐ ☒ ☐

3. Schools? ☐ ☐ ☒ ☐

4. Parks? ☐ ☐ ☒ ☐

5. Other public facilities? ☐ ☐ ☒ ☐
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physical altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: Fire protection, police protection, schools, parks, other public facilities?
The following section addresses the project’s potential effects on: fire service, police service, schools, parks, and other public facilities. Impacts to public services would occur if the project increases demand for services such that new or expanded facilities would be required, and construction or operation of these new facilities would cause environmental impacts.

Fire Protection
Less Than Significant. The Town of Paradise and CAL FIRE provide fire protection services through a cooperative agreement. By contracting with CAL FIRE, the Town is able to staff two fire stations with three-person engine companies, and one station with a two-person engine company. In addition to the Town’s resources, CAL FIRE maintains their own stations in Paradise and the neighboring community of Magalia. These resources are available to assist with the Town’s fire protection efforts as necessary.
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The Paradise General Plan establishes a standard of a five-minute response time for 90 percent of all emergency incidents within Town limits. According to Cal FIRE, this standard is typically met, and the average response time in Paradise is four to six minutes.

The Project does include a program to establish an overlay zone in the SSA that allows densities up to 30 dwelling units/acre, which is a higher intensity of development than the Town has previously seen. However, projects on these sites would be subject to CEQA review on a caseby-case basis following submittal of a specific development proposal and future development would comply with local regulations on emergency access. The Project only identifies sites for high density when the site is well-served by evacuation routes and does not have constrained access. The Project also includes policies and programs to ensure adequate emergency access (e.g., SI-11, SP-41, SI-19), maintain response times (e.g., SP 12, SP-13), and reduce fire severity and intensity (SG-5). Finally, the area of town identified for higher density development (i.e., the Sewer Service Area) is concentrated near the Paradise Fire Station #81. The concentration of multi-family units around this station would allow quick response times and reduce potential concerns from CAL FIRE related to call stacking.
7 According to CAL FIRE, the current automatic
aid agreement is sufficient to handle the Town’s RHNA and increased population as the Town continues to rebuild, and the existing service delivery model is anticipated to accommodate buildout of the Project over the next eight years. 8
The Project does not include any specific development designs or proposals, nor does it grant any entitlements for development. The projected population increase resulting from housing production envisioned under the Project would bring the Town back to pre-fire levels that were historically accommodated by services. For the reasons explained above any impacts would be less than significant.

Police Protection
Less Than Significant. The Paradise Police Department (PPD) currently has 19 employees, including 1 chief, 2 lieutenants, 5 sergeants, and 11 officers. PPD currently has 14 volunteer staff members as well, who assist with staffing the front counter, conducting live scan fingerprinting, conduction vacation home checks, deploying the speed display radar trailer, and assisting with traffic control for incidents and/or special events. PPD is also actively trying to fill current staff vacancies.

Patrol operations is the largest of the five units, with 11 authorized sworn patrol officers and 5 sergeants. Patrols provide 24/7 service every day of the year. Patrol personnel are the first responders to routine calls and crimes that are in progress. The Paradise Police Department is currently contracting 9-1-1 emergency and non-emergency dispatch services with the Butte County Sheriff’s Office. PPD does not have a target officer ratio or established response time 7 Manson, Rick, Butte County Fire Chief, Cal Fire and Butte County Fire Department. 2021. Personal communication with Urban Planning Partners. March 31.
8 Ibid.
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goals. Instead, PPD bases their response to meet the needs of a particular call for service.

Officers are assigned to calls for service depending on level of priority and staff availability. The average emergency response time is just over five minutes, and the average non-emergency response time is just over seven minutes.9
The Project does include a program to establish an overlay zone in the SSA that allows densities up to 30 dwelling units/acre, which is a higher intensity of development than the Town has previously seen. However, projects on these sites would be subject to CEQA review on a caseby-case basis following submittal of a specific development proposal. The SSA is centered on the Town’s major roads – Skyway and Clark Road – and therefore the denser projects envisioned under the Project would be more easily accessible to emergency services. The Project only identifies sites for high density when the site is well-served by evacuation routes and does not have constrained access. The housing production envisioned under the Project would bring the Town back to pre-fire population levels that were historically accommodated by services. PPD uses calls for service and crime rates to monitor staffing needs and, independent of the Project, will be tracking and adapting their operations as population returns. PPD anticipates that their current model and facilities will carry them into the future and the buildout of the Project would not require new facilities.
10 PPD estimated that current facilities could last up to another 20 years and has actively maintained their equipment to stay up to date on trends and to ensure their employees have the necessary tools to do their jobs. Potential impacts to police protection services would therefore be less than significant.

Schools
Less Than Significant. The Paradise Unified School District (PUSD) currently serves approximately 3,500 students across three elementary schools, one middle school, two high schools, and one online learning academy. Due to the 2018 Camp Fire, multiple school sites are undergoing improvements, supported by local Measure Y, which will expand and improve the current school infrastructure. There are presently adequate busses for each school site. The Paradise Unified School District has approved a Facilities Master Plan Update, which was revised in 2020 following the Camp Fire. Phase One of this plan, which involves renovation of the existing high school and the addition of another high school, is expected to begin in 2023. The growth envisioned in the Master Plan Update is consistent with the Town’s current rate of rebuilding and with the buildout anticipated under the Project. 11 The Project does include a program to establish an overlay zone in the SSA that allows densities up to 30 dwelling units/acre, which is a higher intensity of development than the Town has previously seen. However, housing production envisioned under the Project is largely to rebuild 9 Reinbold, Eric, Chief of Police, Paradise Police Department. 2021. Personal communication with Urban Planning Partners. November 3.
10 Reinbold, Eric, Chief of Police, Paradise Police Department. 2022. Personal communication with Urban Planning Partners. March 31.
11 David McCreedy, Assistant Superintendent, Business Services, Paradise Unified School District. 2022. Personal communication with Urban Planning Partners. April 4. 362
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units lost to the Camp Fire. The Project would help facilitate residents’ return to Paradise and the Project would bring the Town back to pre-fire population levels that were historically accommodated by services, including school services. PUSD currently has extra capacity and based on the Facilities Master Plan, has the ability to accommodate future population from development associated with the Project. Therefore, impacts to schools are less than significant.

Parks
Less Than Significant. The Town of Paradise is located within the Paradise Recreation and Park District (PRPD), which serves over 50,000 individuals in the Town of Paradise and some surrounding areas within Butte County. The PRPD maintains 73 acres of developed park land and another 358 acres of natural open space. The Town of Paradise residents have complete access to facilities, programing, and special events.

The Project does include a program to establish an overlay zone in the SSA that allows densities up to 30 dwelling units/acre, which is a higher intensity of development than the Town has previously seen. However, projects on these sites would be subject to CEQA review on a caseby-case basis following submittal of a specific development proposal. Furthermore, the housing production envisioned under the Project is largely to rebuild units lost to the Camp Fire. The Project would help facilitate residents’ return to Paradise and the Project would bring the Town back to pre-fire population levels that were historically accommodated by services, including parks services. Finally, the Project includes additional Open Space provisions for wildfire buffers. The implementation of the wildfire buffers would increase the open space facilities available to the community.

Independent of the Project, the PRPD is planning for new recreation centers, community parks, trails, and improved access to existing park land, as well as rebuilding of park facilities following the Camp Fire. Development under the Project would not result in a need for new or physically altered facilities, the provision and/or construction of which would result in a significant impact to the environment.12
Other Public Facilities
Less Than Significant. Development of the Project could also increase demand for other public services, including libraries and community centers. However, the increased residential population that would result from the Project would not substantially increase the use of these facilities beyond how they were used prior to the fire, such that new facilities would be needed to maintain service standards, as these facilities are not currently overused. The Paradise Branch of the Butte County Library is currently operating with less staff and fewer hours than pre-fire levels given the decrease in population since the fire. As the population grows, the library would like to increase their staffing and operations; upon implementation, the Project 12 Efseaff, Dan, District Manager, Paradise Recreation & Park District. 2021. Personal communication with Urban Planning Partners. December 6.
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may result in increased demand that could require additional library staffing and programming, which is determined by Butte County on an as-needed basis. The library utilizes gate counts, program attendance rates, and counts of checked out items to determine when greater programming or staffing is needed. The provision of additional staff or extending library hours or programs would not have a substantial adverse physical impact on the environment. In fact, the Paradise Library is currently considering expansion of the “Open Plus System” to allow remote access to library services outside of regular hours with a library card. Such solutions would allow increased operations without affecting staffing or facilities. The Paradise Library has adequate physical capacity to accommodate the return of population to pre-fire levels, including population growth associated with the Town’s RHNA.13 Therefore, impacts to other public facilities would be less than significant.
13 Sufi, Narinder. Butte County Librarian, Butte County Library. 2022. Personal Communication with Urban Planning Partners. March 30.
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16.Recreation
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Would the project increase the use of existing
neighborhood and regional parks or other
recreational facilities such that substantial
physical deterioration of the facility would occur
or be accelerated?
☐ ☐ ☒ ☐
b. Does the project include recreational facilities or
require the construction or expansion of
recreational facilities which might have an
adverse physical effect on the environment?
☐ ☐ ☒ ☐
Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
Less Than Significant. The Town of Paradise is located within the Paradise Recreation and Park District (PRPD), which serves over 50,000 individuals in the Town of Paradise and some surrounding areas within Butte County. The PRPD maintains 73 acres of developed park land and another 358 acres of natural open space. The Town of Paradise residents have complete access to facilities, programing, and special events.

The Project would not increase the use of existing recreational facilities because most of the housing units to accommodate the Town’s RHNA would be replacing units lost in the Camp Fire. Pre-fire population levels were historically accommodated by services, including parks services. As previously mentioned, the Project also has the potential to increase the amount of open space/recreational space available to residents because it includes policies and programs to explore establishing open space wildfire buffers in key locations. Impacts from the Project would be less than significant.

Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? Less Than Significant. The Project does not require the construction or expansion of recreational facilities; however it does propose the possibility of establishing Wildfire Risk Reduction Buffers (e.g., SI-3, SP-46) that could take the form of open space. The Town would need to acquire land and/or establish a partnership with landowners to realize this vision; the Project only puts forward the idea of open space buffers as a concept that would need to be refined. If successful, the establishment of Wildfire Risk Reduction Buffer parks would be subject to all local and State requirements, including CEQA review. 365
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As previously mentioned, the PRPD is rebuilding park facilities following the Camp Fire and planning for new recreation centers, community parks, trails, and improved access to existing park land independent of the Project. PRPD’s expansion of facilities is independent of the Project and the Project does not include or require new or expanded facilities that would result in a significant impact to the environment.14

14 Efseaff, Dan, District Manager, Paradise Recreation & Park District. 2021. Personal communication with Urban Planning Partners. December 6.
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17.Transportation and Traffic
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Conflict with a program plan, ordinance or
policy addressing the circulation system,
including transit, roadway, bicycle and
pedestrian facilities?
☐ ☐ ☒ ☐
b) Would the project conflict or be inconsistent
with CEQA Guidelines Section 15064.3
subdivision (b)?
☐ ☐ ☒ ☐
c) Substantially increase hazards due to a
geometric design feature (e.g., sharp curves
or dangerous intersections) or incompatible
uses (e.g., farm equipment)?
☐ ☐ ☒ ☐
d) Result in inadequate emergency access? ☐ ☐ ☒ ☐
Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? Relevant transportation plans and policies include the Butte County Association of Governments (BCAG) 2020 Regional Transportation Plan/Sustainable Communities strategy (RTP/SCS), Paradise General Plan Circulation Element, and Transportation Master Plan.

RTP/SCS
The RTP/SCS specifies the policies, projects, and programs necessary over a 20 or more-year period to maintain, manage, and improve the region’s transportation system. The Butte County Association of Governments (BCAG) published the 2020 RTP/SCS in 2020 (adopted December 10, 2020). BCAG also prepared and certified the 2020 Regional Transportation Plan/Sustainable Communities Strategy Supplemental Environmental Impact Report (RTP/SCS SEIR) and adopted a Statement of Overriding Consideration for significant and unavoidable impacts related to transportation based upon the inability to meet state VMT requirements, largely as a result of the Camp Fire based upon the nature of the VMT calculation. The RTP/SCS SEIR included the following two-part mitigation measure (MM) (MM T-1) prescribing local and regional mitigations to reduce vehicle miles traveled (VMT):

The state recognized that additional state policy actions and funding would be required to close the VMT gap between what the MPOs could achieve through implementation of their SCSs, and reductions needed to meet state goals. Though the state must initiate these additional actions and funding programs, the exact form of the policies and funding programs must be collaboratively developed with input from MPOs, local agencies, and other organizations to ensure they provide the tools and incentives necessary to go beyond the SCSs in reducing VMT. 367
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Consequently, BCAG shall work collaboratively with Butte County and the cities of Biggs, Chico, Gridley, Oroville, and Town of Paradise to support implementation of regional and local-level strategies and measures to achieve further VMT reductions. Implementing agencies (i.e., Butte County and the cities of Biggs, Chico, Gridley, Oroville, and Paradise) shall implement the following strategies to reduce VMT.

Local Level
Implementing agencies shall require implementation of VMT reduction strategies through transportation demand management (TDM) programs, impact fee programs, mitigation banks or exchange programs, in-lieu fee programs, or other land use project conditions that reduce VMT.

Programs should be designed to reduce VMT from existing land uses, where feasible, and from new discretionary residential or employment land use projects. The following strategies from Quantifying Greenhouse Gas Mitigation Measure, CAPCOA, August 2010 were identified as strategies most suited to Butte County and the cities of Biggs, Chico, Gridley, Oroville, and Town of Paradise, given the rural and suburban land use context:

1. Increase diversity of land uses – This strategy focuses on the inclusion of mixed uses within projects or in consideration of the surrounding area to minimize vehicle travel in terms of both the number of trips and the length of those trips.

2. Provide pedestrian network improvements – This strategy focuses on creating a pedestrian network within the project and connecting to nearby destinations. Projects in Butte County tend to be small, so the emphasis of this strategy would likely be the construction of network improvements that connect the project site directly to nearby destinations. Alternatively, implementation could occur through an impact fee program or benefit/assessment district targeted to various areas in the county designated for improvements through local or regional plans. Implementation of this strategy may require regional or local agency coordination and may not be applicable for all individual land use development projects.

3. Provide traffic calming measures and low-stress bicycle network improvements – This strategy combines the CAPCOA research focused on traffic calming with new research on providing a low-stress bicycle network. Traffic calming creates networks with low vehicle speeds and volumes that are more conducive to walking and bicycling. Building a low-stress bicycle network produces a similar outcome. Implementation options are similar to strategy 2 above. One potential change in this strategy over time is that e-bikes (and e-scooters) could extend the effective range of travel on the bicycle network, which could enhance the effectiveness of this strategy.

4. Implement car-sharing program – This strategy reduces the need to own a vehicle or reduces the number of vehicles owned by a household by making it convenient to access a shared vehicle for those trips where vehicle use is essential. Note that implementation of this strategy would require regional or local agency implementation and coordination and would not likely be applicable for individual development projects.

5. Increase transit service frequency and speed – This strategy focuses on improving transit service convenience and travel time competitiveness with driving. Given land use density in Butte County, this strategy may be limited to traditional commuter transit where trips can be pooled at the start and end locations or require new forms of demand-responsive transit service. The demand-responsive service could be provided as subsidized trips by contracting to private Transportation Network Companies (TNCs, such as Uber, Lyft, and Via) or taxi companies.

Alternatively, a public transit operator could provide the subsidized service but would need to improve on traditional cost effectiveness by relying on TNC ride-hailing technology, using smaller vehicles sized to demand, and flexible driver employment terms where drivers are paid by trip versus by hour. Note that implementation of this strategy would require regional or local agency 368
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implementation, substantial changes to current transit practices, and would not likely be applicable for individual development projects.

6. Implement subsidized or discounted transit program – This strategy reduces the need to own a vehicle or reduces the number of vehicles owned by a household by incentivizing individuals to use transit for their daily commute. This strategy depends on the ultimate building tenants – whether residential landlords or businesses – and may require monitoring. This strategy also relies on B-Line continuing to provide similar or better service throughout the county, in terms of frequency and speed.

7. Encourage telecommuting and alternative work schedules – This strategy relies on effective internet access and speeds to individual project sites/buildings to provide the opportunity for telecommuting. The effectiveness of the strategy depends on the ultimate building tenants and the nature of work done by tenants’ employees (can the work be done remotely in the first place?); two factors that should be considered for potential VMT reduction. Effectiveness may also be limited in more rural areas of the county with limited broadband internet access.

8. Provide ride-sharing programs – This strategy focuses on encouraging carpooling and vanpooling by project site/building tenants, which depends on the ultimate building tenants; this should be a factor in considering the potential VMT reduction.

Regional
Implementing agencies shall require project modifications during the project design and environmental review stage of project development that would reduce VMT effects. For roadway capacity expansion projects, this would include but is not limited to demand management through transportation systems management and operations (TSMO) including the use of pricing.

The Town of Paradise specifically has adopted MM T-1 of the RTP/SCS SEIR as Town policy. On April 12, 2022 the Town adopted Resolution No. 2022-24, which adopted the VMT policies found in Appendix B.

In addition to policies related to VMT, the RTP/SCS has broader goals and policies related to the transportation system. The goals of the RTP/SCS are as follows:

1. Highways, Streets, and Roads. A safe and efficient regional road system that accommodates the demand for movement of people and goods.

2. Transit. Provide an efficient, effective, coordinated regional transit system that increases mobility for urban and rural populations, including those located in disadvantaged areas of the region.

3. Rail. A rail system that provides safe and reliable service for people and goods.

4. Goods Movement. Provide a transportation system that enables safe movement of goods in and through Butte County.

5. Aviation. A fully functional and integrated air service and airport system complementary to the countywide transportation system.

6. Non-Motorized Transportation. A regional transportation system for bicyclists and pedestrians.

7. Intelligent Transportation System (ITS). Promote the use of ITS technologies in the planning and programming process.
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8. Energy. Reduce usage of nonrenewable energy resources for transportation purposes.

9. Air Quality. Achieve air quality standards set by the Environmental Protection Agency (EPA) and the State Air Resources Board.

10. Land Use Strategies. Provide economical, long-term solutions to transportation problems by encouraging community designs which encourage walking, transit, and bicycling.

11. Transportation Financing. Develop and support financing strategies that provide for continuous implementation of the Regional Transportation Plan projects and strategies.

12. Outreach and Coordination. Provide a forum for participation and cooperation in transportation planning and facilitate relationships for transportation issues that transcend jurisdictional boundaries.

13. Quality of Travel and Livability.

Mobility. The transportation system should provide for convenient travel options for people and goods and maximize its productivity. The system should reduce both the time it takes to travel as well as the total costs of travel.

Reliability. The transportation system should be reliable so that travelers can expect relatively consistent travel times from day-to-day for the same trip by mode(s).

System Preservation and Safety. The public’s investment in transportation should be protected by maintaining the transportation system. It is critical to preserve and ensure a safe regional transportation system.

14. Sustainability. Incorporate Sustainable Community Strategies into the regional transportation planning process which works towards social equity, a healthy environment and a prosperous economy.

15. Emergency Preparedness. To support and collaborate on proactive emergency planning and projects. Projects that increase emergency readiness and preparedness including upgrading and maintaining roadways, public transit or facilities that support emergency situations.

16. Housing. To support and collaborate on proactive efforts to address housing needs in the region.

The RTP/SCS includes a number of objectives and policies/actions to implement these goals, including the provision of complementary “dial-a-ride” transit services for the elderly, persons with disabilities, or those who are not served by a fixed route transit service; supporting the acquisition of funding and other planning activities for complete streets and active transportation; increasing transit service where feasible; supporting vanpooling and carpooling programs; and supporting and encouraging infill development that is friendly to pedestrians and bicyclists.
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General Plan
The Town’s General Plan includes the goals, objectives, policies, and implementation measures related to transportation and circulation as listed below. Although the General Plan has goals, objectives, policies, and implementation measures related to maintaining mobility as measured through Level of Service (LOS), LOS is no longer deemed an appropriate transportation measure of environmental impact under CEQA and is therefore not relevant to this Initial Study of potential CEQA impacts.

Goals
 CG-1. Support cooperative and coordinated transportation planning and development activities with federal, state, regional, and local agencies in order to assure maximum coordination of effort in the Paradise region.
 CG-2. Provide safe, efficient, and effective traffic flow, both within Paradise and between Paradise and its environs.
 CG-3. Enhance and improve pedestrian and bicycle safety and use by establishing additional linkages between areas of town.
 CG-4. Provide adequate access, including access for emergency vehicles and evacuation, to all new parcels and to existing parcels when feasible.
 CG-5. Maintain and improve local and regional air quality.  CG-6. Reduce reliance on the automobile by careful land use planning and encourage the use of non-automobile travel modes through a balanced and integrated set of land use and transportation planning policies.

Objectives
 CO-3. Assure that traffic generated by high density residential land use development will not exceed roadway capacity and level of service standards.  CO-5. Plan and complete public street improvements to accommodate projected traffic during the planning period.
 CO-6. As necessary, revise and update both the bicycle and pedestrian and the Paradise Memorial Trailway master plans.
 CO-10. Encourage efforts to significantly reduce reliance on the private automobile during the fifteen-year planning period.

Policies
 CP-1. The town shall strive to maintain a level of service (LOS) “D” or better as the standard for new and existing roadways in the Paradise planning area. LOS “D” or better should be maintained on all local streets within the town limits, and LOS “C” or better should be maintained whenever feasible.
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 CP-4. New land use development shall be required to mitigate its share of the circulation impacts it creates.
 CP-5. Methods of recovering costs associated with use of roadways within the Town of Paradise by residents of the Upper Ridge should be explored, including imposition of development impact fees.
 CP-10. Safe paths for pedestrians, equestrians, and bicyclists should be provided, particularly for school children and the elderly. A sidewalk and pathway development program should be instituted for selected locations and where feasible should link with the Paradise Memorial Trailway.
 CP-12. The Town shall encourage Butte County to require development applications within the secondary planning area [Sphere of Influence] to dedicate and improve streets to town standards and to provide other transportation improvements (e.g., bus stops, park-and-ride lots).
 CP-13. Automobile dependency within Paradise should be reduced for local residents and visitors by implementing congestion management and trip reduction plan programs that decrease the number of vehicle miles travelled which, in turn, reduces air pollution and congestion and saves energy.
 CP-14. As staff and funding become available, expanded transit services for seniors and the handicapped should be promoted in accordance with the results of future studies.  CP-15. Expand public transportation services within Paradise and between Paradise and major employment centers as feasible, based on service demand and financial constraints.  CP-17. Whenever the LOS “D” is reached on roadways within Paradise, the town shall explore all feasible alternatives for improving traffic flow, rather than automatically implementing a road widening project.
 CP-19. As staff and resources become available, the town should strive to increase the transit opportunities for children and senior citizens in the community.

Implementation Measures
 CI-3. Establish a town wide development impact fee program, and review and update on an annual basis.
 CI-6. Identify locations for sidewalks and pathways along existing major collector and arterial roadways as well as standards for requiring sidewalks adjacent to new developments.
 CI-7. Require new development to provide a pedestrian pathway on at least one side of new public streets and new private roads (if feasible).
 CI-8. Improve shoulders of some roads to make them safer for pedestrians and bicyclists and relocate mailboxes where feasible from sidewalks.
 CI-9. Require transportation facilities such as bus stops to be incorporated into major new developments.
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Transportation Master Plan
The Town will review and consider the TMP for adoption on May 10, 2022. The TMP guides long-term transportation improvements and envisions safe, modern travel options, and efficient evacuation routes for the Town’s residents, business owners, and visitors.

Key components of the TMP include:
 Traffic needs analysis: This analysis will recommend improvements to the roadway system serving connections to schools, parks, shopping areas, jobs, and local homes. The recommended concepts will address traffic and circulation needs for all roadway users.  Traffic evacuation planning: This planning analyzes the Town’s transportation network to serve traffic evacuation needs and will address pinch points, improve the backbone network, identify new connections, facilitate operations during an evacuation, and coordinate with regional partners and public safety responders.  Active Transportation Plan: This plan will evaluate opportunities for walking paths, sidewalks, and bikeways and will position the Town to pursue grant funding for implementation.

As part of the evacuation planning, the Town is determining major and secondary evacuation routes, potential areas of congestion, and opportunities for roadway extensions and connections on dead-end streets for additional routes and increased evacuation capacity. Other components of the TMP include economic/redevelopment support, new roadway standards, and major projects coordination.

Impact Assessment
Less than Significant. Development associated with the Project would be comprised largely of reconstructing dwelling units destroyed by the Camp Fire. An analysis prepared by Kittelson & Associates, Inc. (Kittelson), attached and incorporated as Appendix A, concluded that no components of the Project conflict with the transportation plans or their goals, objectives, policies, and implementation measures described above. Similarly, no aspect of the Project conflicts with existing or planned bicycle facilities, rail facilities, or transit service. Additionally, development that occurs as part of the Project (Housing Element implementation) will comply with the VMT policies identified in the RTP/SCS and provided in Appendix B. The VMT policies were adopted by the Town on April 12, 2022. Policies in the RTP/SCS will promote future residential development to align with existing regional programs, plans, ordinances, and policies:
 Increase diversity of land uses. The Project includes policies to facilitate the development of a mix of uses in the Downtown, which can help minimize the number and length of vehicle trips.
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 Provide pedestrian network improvements. Network improvements that connect individual sites to existing networks and nearby destinations would improve opportunities for walking in Paradise.
 Provide traffic calming measures and low-stress bicycle network improvements. Providing low-stress bicycle infrastructure that connects areas of proposed development to existing and planned networks would improve opportunities for biking in Paradise.

For these reasons, the Project would not conflict with adopted plans, ordinances, or policies addressing the safety and performance of the circulation system. This is a less-than-significant impact; no mitigation measures are required. This finding is consistent with the RTP/SCS Supplemental Environmental Impact Report (SEIR) Impact T-1 finding.

Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3 subdivision (b)? (i.e., a proposed residential project in an area exceeding a level of 15% below existing regional average home-based VMT per resident) Less Than Significant. Senate Bill 743 (SB 743) was signed into law in September 2013. Senate Bill 743 (Steinberg, 2013) required changes to the CEQA Guidelines regarding the analysis of transportation impacts. Historically, CEQA transportation analyses of individual projects determined impacts in the circulation system in terms of roadway delay and/or capacity at specific locations. SB 743 eliminated auto delay, LOS, and other similar measures of vehicular capacity or traffic congestion as a basis for determining significant impacts and instead identified vehicle miles traveled (VMT) as the most appropriate metric to evaluate a project’s transportation impacts. Since the bill has gone into effect, automobile delay, as measured by “level of service” and other similar metrics, no longer constitutes a significant environmental effect under CEQA (although such metrics may continue to be a measure for planning purposes).

In December 2018, the California Governor’s Office of Planning and Research (OPR) and the State Natural Resources Agency submitted updated CEQA Guidelines to the Office of Administrative Law for final approval to implement SB 743. The Office of Administrative Law approved the updated CEQA Guidelines, thus implementing SB 743 and making VMT the primary metric used to analyze transportation impacts. The final text, final statement of reasons, and related materials are posted at http://resources.ca.gov/ceqa. The changes have been approved by the Office of the Administrative Law and are now in effect. For land use and transportation projects, SB 743-compliant CEQA analysis became mandatory on July 1, 2020.

Kittelson prepared a VMT assessment (see Appendix A) utilizing the BCAG travel demand model to assess the baseline and future year average VMT per resident for the transportation analysis zones (TAZs) that comprise the Paradise planning area and Butte County. The model outputs are shown in Table 4. As shown in Table 4, the average VMT per resident in Paradise is 36 to 42 percent higher than the county average in baseline and future year conditions, respectively.

Table 4 also shows the VMT level that represents 15 percent below the countywide average, or the CEQA threshold.
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TABLE 4 BCAG TRAVEL DEMAND MODEL DAILY HOME-BASED VMT PER RESIDENT Planning Area Model Year 2020 Model Year 2045
Butte County Average 11.6 12.3
Level at 15% Below County Average 9.9 10.5
Paradise 15.8 17.5
Source: Kittelson, 2022.

As shown in Table 4, the average VMT per resident in Paradise is 60 or more percent higher than the impact threshold of 15 percent below existing regional average home-based VMT per resident. This is consistent with the findings of the RTP/SCS EIR. As previously mentioned, BCAG certified the RTP/SCS SEIR and adopted a Statement of Overriding Considerations for the significant and unavoidable impacts, including significant and unavoidable impacts related to VMT. The Town subsequently relied on the SEIR to adopt the SCS/RTP and established Mitigation Measure T-1 or the RTP/SCS as Town policy (VMT policies). The VMT policies are included in Appendix B and include the following strategies:

1. Increase diversity of land uses.

2. Provide pedestrian network improvements.

3. Provide traffic calming measures and low-stress bicycle network improvements.

4. Implement car-sharing program.

5. Increase transit service frequency and speed.

6. Implement subsidized or discounted transit program.

7. Encourage telecommuting and alternative work schedules.

8. Provide ride-sharing programs.

In developing the 2020 RTP/SCS, BCAG utilized a “medium growth” scenario shown in Table 5 based upon the best available data at the time given the disruptions posed by the Camp Fire during the RTP/SCS development process. Consistent with Government Code Section 65584.04(e), BCAG also utilized the RTP/SCS in the Regional Housing Needs Plan, which issued the RHNA allocations to all Butte County jurisdictions. Table 1 in the project description shows the Paradise allocation. Table 6 compares Paradise’s growth scenario in the RTP/SCS, the growth that would be realized with achievement of the Town’s RHNA, and the growth that would be realized with achievement of the quantified objective of the Housing Element. As shown in Table 6, the growth the Town would undergo pursuant to the Project is consistent with the growth projected in the 2020 RTP/SCS and evaluated in the RTP/SCS SEIR. 375
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TABLE 5 BCAG HOUSING FORECASTS - TOTAL DWELLING UNITS 2018-2040 Jurisdiction 2018 2020 2025 2030 2035 2040
Total
Increase
2018-
2040
Percent
Increase
2018-
2040
Paradise 13,091 1,916 6,490 9,318 10,811 11,347 -1,744 -13% Note: 2018 dwelling unit count obtained from State of California, Department of Finance, E-5 Population and Housing Estimates for Cities, Counties, and the State, 2010-2019, with 2010 Benchmark. Sacramento, California, May 2019.

Source: Kittelson, 2022 and BCAG RTP/SCS.

TABLE 6 PARADISE GROWTH PROJECTS – TOTAL DWELLING UNITS Scenario 2030
2020 RTP/SCS 9,318
Full buildout of RHNA 9,095
Full buildout of quantified objectives 4,936
Source: Kittelson, 2022, Town of Paradise, 2022, and Urban Planning Partners, 2022.

The finding that implementation of the Project would result in a significant VMT impact is consistent with the findings of the RTP/SCS SEIR. Furthermore, because the growth that could occur pursuant to the Project is within the level of growth analyzed in the RTP/SCS SEIR, the Project’s VMT impacts have already been evaluated and the VMT impacts associated with the Project are no more severe than previously identified. As mentioned above, at the time of adopting the policy, the Town has adopted a Statement of Overriding Considerations related to VMT impacts of future growth within the RTP/SCS, which is greater than the buildout anticipated under the Project. Future development pursuant to the Project would be subject to the Town’s VMT policies, including providing pedestrian network improvements, traffic calming measures, and low-stress bicycle network improvement, and therefore no additional mitigation is needed. Impacts from the Project would be less than significant.

Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Less than significant. The Project designates future feasible sites for residential development and is proposing to increase the amount and density of residential land uses. The Housing Element includes programs to rezone land within the Town’s planned Sewer Service Area. A Sewer Service Overlay Zoning District would be established with implementation of the Project that would apply only when the sewer is implemented. Most notably, the Sewer Service Overlay Zone would increase the allowed residential density in the Community Facilities (C-F) zone from 1 dwelling unit per acre to 20 dwelling units per acre. Other changes would be less substantial, 376
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and the project identifies residential development sites only where adjacent land uses are compatible. Therefore, the project would not introduce incompatible land uses.

The Safety Element also contains programs and policies related to evacuation planning, but it does not propose new roadway design features. Rather, any future residential development covered in this Project would be subject to local development review to include a review of design features and would be required to comply with all local and State design guidelines.

Consistent with the RTP/SCS Impact T-3 finding and as described in Appendix A, the Project is not anticipated to cause a substantial increase in hazards due to design features or incompatible uses and impacts would be less than significant.

Result in inadequate emergency access?
Less than significant. Development pursuant to the Project would be subject to Town review and the Town would coordinate with individual projects to ensure that emergency routes are not blocked and remain available during construction. In addition, the Safety Element includes policies to ensure future housing development has adequate emergency access, as summarized below.
 TMP Implementation. The Safety Element includes programs to execute recommended circulation improvements that will provide benefits for emergency preparedness, response, and evacuation. Through the development review process and in accordance with the Butte County Community Wildfire Protection Plan, adequate roads shall be required to be constructed and/or improved for emergency vehicle access, particularly in high wildland fire hazard areas.
 Density Discretion. The Town would continue to limit the densities of development on parcels that do not have adequate emergency access. At a minimum, the Town would not approve any discretionary permit or project that requests an increase of existing residential density on parcels that are served access by either an existing or resultant cul-de-sac exceeding a maximum length of 1,800 lineal feet. The Safety Element would require that the Town also continue to look to the TMP and Board of Forestry for guidance on potentially developing more stringent access requirements.  Response Times. New development pursuant to the Project would largely replace units lost in the Camp Fire and response times and levels of service are anticipated to be sufficient to accommodate this incremental population growth. In addition, the Town would strive to maintain an overall fire insurance (ISO) rating of three or better, and an emergency fire response within five minutes for 90 percent of all emergency incidents within the Town Limits, as specified in SP-13 of the Safety Element.

Consistent with the RTP/SCS T-4 finding and as analyzed in Appendix A, there are no other components of the Project that would have the potential to impact emergency access and impacts would be less than significant. Implementation of the Safety Element may help improve emergency access given the policies and programs described previously. 377
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18.Tribal Cultural Resources
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:

Cause a substantial adverse change in the
significance of a tribal cultural resource, defined in
Public Resources Code Section 21074 as either a site,
feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value
to a California Native American tribe, and that is:
a. Listed or eligible for listing in the California
Register of Historical Resources, or in a local
register of historical resources as defined in
Public Resources Code section 5020.1(k), or
☐ ☐ ☒ ☐
b. A resource determined by the lead agency, in its
discretion and supported by substantial evidence,
to be significant pursuant to criteria set forth in
subdivision (c) of Public Resources Code Section
5024.1. In applying the criteria set forth in
subdivision (c) of Public Resource Code Section
5024.1, the lead agency shall consider the
significance of the resource to a California Native
American tribe.
☐ ☐ ☒ ☐
Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)? Less Than Significant. The Project does not include any specific development designs or proposals, nor does it grant any entitlements for development. Also, if any historic or prehistoric artifact is discovered on the site during any future development, work shall immediately stop until a qualified professional archaeologist view the site, provides recommendations, and gives clearance to continue, per General Plan program OCEI-20. General Plan policies OCEP-36 and OCEG-9 further protect historic resources by requiring archeological surveys when applicable. Impacts from the Project would be less than significant.

A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Less Than Significant. Paradise lies within territory formerly inhabited by the Northwestern Maidu or Konkow peoples. Major villages were located atop the crests of ridges high above the 379
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rivers.15 Given the potential for tribal cultural resources in the vicinity, and pursuant to State law, written notices about the Project were sent to the following tribes: United Auburn Indian Community of the Auburn Rancheria, Mooretown Rancheria, Mechoopda Indian Tribe, Greenville Rancheria, Berry Creek Rancheria, Enterprise Rancheria, Washoe Tribe of Nevada and California, and Konkow Valley Band of Maidu (Tribes). Pursuant to AB 52 and SB 18 and according to Government Code Section 65352.3, the tribes were provided information on the Project and invited to consultation. The United Auburn Indian Community of the Auburn Rancheria responded to confirm that the Project site is outside of its geographic area of traditional and cultural affiliations. The Berry Creek Rancheria tribe requested a consultation related to the sewer system and the corresponding Sewer Service Overlay Zone, and consultation occurred between the tribe and the Town’s engineering department (the lead agency for the Town’s sewer project). The sewer project is a separate effort for this Project and currently undergoing its own environmental review. Upon further conversations with the tribe, the Berry Creek Rancheria shared that they did not have concerns with the Project, which is related to making land available for rebuilding and new construction of housing. Consistent with Government Code 21080.3.2, tribal consultation is considered concluded given the tribe’s input that no significant effect exists.

The Project does not include any specific development designs or proposals, nor does it grant any entitlements for development. Also, if any archaeological or cultural resource is discovered on the site during any future development work shall immediately stop, as described above.

Tribes did not indicate that implementation of the Project would result in impacts and impacts are therefore considered less than significant.

15 Town of Paradise, 1994. Paradise General Plan Environmental Setting Document. 380
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19.Utilities and Service Systems
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Require or result in the construction of new water
or wastewater treatment facilities or storm water
drainage, electric power, natural gas, or
telecommunication facilities the construction of
which could cause significant environmental
effects?
☐ ☐ ☒ ☐
b. Have sufficient water supplies available to serve
the project and reasonably foreseeable future
development during normal, dry and multiple dry
years?
☐ ☐ ☒ ☐
c. Result in a determination by the wastewater
treatment provider which serves or may serve the
project that it has adequate capacity to serve the
project’s projected demand in addition to the
provider’s existing commitments?
☐ ☐ ☒ ☐
d. Generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment
of solid waste reduction goals?
☐ ☐ ☒ ☐
e. Comply with federal, state, and local management
and reduction statutes and regulations related to
solid waste?
☐ ☐ ☒ ☐
a-c) Require or result in the construction of new water or wastewater treatment facilities or storm water drainage, electric power, natural gas, or telecommunication facilities the construction of which could cause significant environmental effects? Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Less Than Significant. The Paradise Irrigation District (PID) provides water to most areas of the Town of Paradise. The primary source of water supply is surface water from rainfall stored in two reservoirs, Paradise Reservoir and Magalia Reservoir. The upstream reservoir, Paradise Lake, is the main storage facility with a total storage capacity of approximately 11,500 AF. Surface water from Paradise Lake is released into Little Butte Creek and flows to Magalia Reservoir.

Magalia Dam is currently restricted to 800 AF of storage as a result of the current maximum water surface elevation dictated by the Department of Water Resources, Division of Safety of Dams (DSOD). PID’s water distribution network sustained substantial damage during the Camp 381
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Fire. According to the 2020 PID Urban Water Management Plan, to date, PID continues to repair or replace main segments that sustained leak damage or have remained off with an outlook of several years before all breaks can be addressed.

Paradise relies upon annual precipitation and runoff in the Butte Creek watershed. Depending upon trends in climate change, annual precipitation and snowpack conditions, Paradise may experience shortage in the future. However, through the PID planning horizon of 2045, there is no anticipated shortage of supply in any year type. This is partially due to the reduction in demand caused by the 2018 Camp Fire. As Paradise continues to rebuild following the disaster, trends in redevelopment and possible intensification may change the outlook of water supply through 2045. It is difficult to predict development trends after such an unprecedented community change. PID’s projections are based on data from the Town, which estimates a return to pre-fire population by 2045. The approximately 26,500 people projected to live in Paradise by 2045 is well within the 7,179 housing units for which the Project plans. Using an average of 2.19 person/household,16 the Project plans for approximately 15,720 people (7,179 housing units) through 2030. This number is within the anticipated capacity of the PID, which anticipates a Paradise population of 18,955 in 2030. In addition, the Project includes policies to require drought-resistant landscaping (SP-51) and future development would be required to comply with Title 24 requirements that reduce water usage.

Possible construction of the sites identified in the Project to satisfy the RHNA would not result in the construction of new or expanded utility or service systems. Electricity is available to all of the sites identified to satisfy the RHNA. Because Paradise does not have a wastewater treatment facility, new development would not affect the ability to provide service to a treatment facility.

At this time, all new residential development is required to provide its own wastewater treatment facilities in accordance with the Town's wastewater regulations. The Project does include a program (HI-1) to continue planning for a sewer system and Program HI-5 would create a zoning overlay to allowed increased densities in the SSA. The Paradise Sewer Project is undergoing its own CEQA review (an EIR began in fall 2020) and the Project under review in this CEQA document does not propose to construct, nor does it require the construction of, such a sewer system. Should the Sewer Project not end up being implementing, the Town would still have ample land capacity to accommodate its RHNA at the densities of 15 unit/acre currently allowed with clustered wastewater systems.

Additionally, future residential development projects would comply with General Plan policies related to utilities. Future development proposals would be reviewed by the appropriate service agencies as part of the development application review process in order to ensure that sufficient capacity in all utilities would be available on time to maintain desired service levels.

Therefore, Project implementation would have a less-than-significant impact regarding a significant increase in demand for wastewater and water services, electric power, natural gas, or telecommunication facilities.
16 Paradise Irrigation District, 2021. Urban Water Management Plan. June. 382
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d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? Less Than Significant. Solid waste generation in the town is primarily disposed of at the Neal Road Recycling and Waste Facility (NRRWF), which is owned and operated by Butte County.

According to Butte County Department of Public Works, the maximum amount accepted daily at the NRRWF is 1,500 tons, although the daily amount rarely exceeds 1,200 tons. However, due to the 2018 Camp Fire, Butte County Public Works submitted an Emergency Waiver of Standards to CalRecycle to increase the maximum tonnage from 1,500 tons per day to 15,000 tons per day, as well as increased permitted traffic volume, transfer and processing capacity, and facility operating hours to expedite disposal of fire debris. The NRRWF has a permitted capacity of approximately 25.3 million cubic yards and a remaining capacity of 20.8 million cubic yards.

The facility is estimated to operate until 2048, accommodating 2.5 to 3.5 percent annual increases in solid waste due to anticipated growth in the County.17 Future development under the Project would be within this capacity, and within the pre-Camp Fire population included in the Franchise Agreement between the County and waste management and collection services through February 2030; the Project would not result in the need for additional NRRWF staff and no impacts are expected from the Project.
18 The Butte County Department of Public Works is in
development of a Master Plan and any future facility expansion would be driven by the Master Plan’s recommendations. Impacts from the Project would be less than significant.

Comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
Less Than Significant. As mentioned above, solid waste collection and disposal for residential units would be disposed of at the NRRWF. The NRRWF operates in compliance with federal, State, regional, and local governmental statues, and regulations. The Project would not impede the NRRWF’s ability to be incompliance with applicable regulations. In addition, the program SI7 of the Project intends to facilitate waste reduction in the town, with an emphasis on hazardous waste. Impacts from the Project would be less than significant.

17 Butte County Department of Public Works, 2021. Negative Declaration Neal Road Recycling and Waste Facility Composting Project. Prepared by Dudek. March. 18 Cissell, Craig, Deputy Director, Waste Management Division, Butte County Public Works. 2021.

Personal communication with Urban Planning Partners. December 6. 383
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20.Wildfire
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Substantially impair an adopted emergency
response plan or emergency evacuation plan?
☐ ☐ ☒ ☐
b. Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks and thereby expose
project occupants to pollutant concentrations
from a wildfire or the uncontrolled spread of a
wildfire?
☐ ☐ ☒ ☐
c. Require the installation or maintenance of
associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines, or
other utilities) that may exacerbate fire risk or
that may result in temporary or ongoing impacts
to the environment?
☐ ☐ ☒ ☐
d. Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability or drainage changes?
☐ ☐ ☒ ☐
a) Substantially impair an adopted emergency response plan or emergency evacuation plan? Less Than Significant. The Town’s TMP includes a high-level capacity analysis to determine major and secondary evacuation routes, potential areas of congestion (intersections or roadway segments), and opportunities for roadway extensions/connections on dead-end streets for additional routes and increased evacuation capacity. The TMP is scheduled for review and consideration of adoption by the Town on May 10, 2022.

The Project builds off the ongoing TMP efforts by including programs and policies to implement upgrades recommended in the TMP (SI-11, SI-19); clustering development and critical services in areas near evacuation routes and discouraging development with poor evacuation access (SP-5, SP-30, SP-41); and providing education on emergency response and evacuation plans (SI-16), including evacuation simulations (SP-43, SI-19). In addition to increased density in the SSA, the Town would explore incentives such as reduced permit fees, expedited processing, a special permitting desk, CEQA streamlining, and/or density bonus programs for development in these safer areas (SI-3). Development in areas that is not as well-served by evacuation routes would be disincentivized through an impact fee or overlay zone (SP-46) and the Town would prohibit any increase of existing residential density on parcels that are served access by either an existing or resultant cul-de-sac exceeding a maximum length of 1,800 lineal feet (SI-19). Similarly, development of critical facilities in wildfire risk reduction buffers would be prohibited (SI-13). 384
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For these reasons, the Project would not impair evacuation planning and would instead work in tandem with ongoing efforts to improve emergency response and evacuation. Impacts from the Project would be less than significant.
b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
Less Than Significant. Wildland fire hazards exist in varying degrees over approximately 70 percent of Butte County. The highest wildfire risk to human health and safety occurs in the foothill communities, including in Paradise. This area is considered a wildland-urban interface (WUI). Fires that occur in the WUI affect natural resources as well as life and property. During the past decade, Butte County has experienced several large and damaging wildfires in and around the wildland-urban interface areas, including Paradise. In November 2018, Paradise and some surrounding areas in Butte County faced the Camp Fire, which resulted in the loss of 85 lives, nearly 19,000 structures, the burning of more than 150,000 acres over two weeks, and $9 billion in insurance claims. It took less than six hours for the Camp Fire to destroy over 90 percent of Paradise. The vast majority of the town is identified by CAL FIRE as a very high fire hazard severity zone (VHFHSZ).

The Project identifies parcels throughout the town as locations for potential future residential development to accommodate the RHNA, including sites that are in the VHFHSZ. Future development would expose people or structures to wildland fire risk. However, the Project includes policies and programs to reduce fire risk, including but not limited to the creation of Wildfire Risk Reduction Buffers, the clustering of development in the SSA where it is flatter and easier to evacuate, establishment and enforcement of fuels management programs and education, analysis and potential implementation of more stringent fire-resistant building requirements, and implementation of community-wide evacuation drills. Such policies and programs, which future developments would be required to implement, would reduce the risk of loss, injury, or death due to wildfire rather than exacerbate the existing wildfire risk.

As discussed above, the Project is a policy-level document that does not propose any specific development designs or proposals, nor does it grant any entitlements for development.

Potential wildland fire impacts to subsequent development projects would also be considered pursuant to CEQA on a case-by-case basis following submittal of a specific development proposal. Future development in the WUI would also be subject to applicable California Building Code and Board of Forestry requirements for development in the VHFHSZ. For these reasons, this impact is considered less than significant.
c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? Less Than Significant. The Project is a series of policy-level documents that seek to facilitate the construction and conservation of housing to meet Paradise’s housing needs and reduce 385
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exposure to hazards. The Project does include policies and programs to improve the Town’s infrastructure, such as improvements to emergency evacuation routes, installation of an early warning systems, and implementation of a sewer system. However, these suggested infrastructure improvements are in tandem with independent projects that the Town is heading separately from the Housing and Safety Element updates (e.g., Transportation Master Plan, Paradise Sewer Project) and such projects are subject to their own CEQA review. Furthermore, the infrastructure projects identified in the Project would improve wildfire risk and response.

Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability or drainage changes? Less Than Significant. The Project identifies sites for future potential housing development and encourages a range of housing types at varying affordability levels. The Town has adequate vacant land that was previously developed and destroyed in the Camp Fire to accommodate its RHNA. If development of housing were to occur in previously undeveloped areas, increased impervious surfaces and grading and vegetation removal activities could increase surface runoff and potentially contribute to the potential for localized flooding and/or erosion. However, the sites identified for development are not greenfield development.

Paradise does not have any designated flood hazard areas as depicted on the Federal Emergency Management Agency (FEMA) Digital Flood Insurance Rate Map (DFIRM). Any flooding that occurs is localized in nature, resulting from a temporary lack of capacity or blockage of a drainage basin. According to the Butte County Local Hazard Mitigation Plan, dam failure is unlikely in Paradise and limited in severity. The Paradise Dam north of the town is considered an Extremely High Hazard dam for inundation, but the inundation area is completely outside of the Town limits. Furthermore, the Project includes policies and programs to reduce the risks related to localized flooding (e.g., SI-6, SP-27).

The majority of Paradise is at a low to moderate risk of landslide. The areas surrounding the town are where the topography most dramatically changes and are at greater risk to landslide.

The northern edge of town and pockets in the southern and western edges are at moderate risk and the Town limits on the east abut and at times overlap an area of high potential landslide risk.

The Project includes policies and programs designed to facilitate the construction and conservation of housing, which could increase exposure of people and structures to landslides.

The Project includes policies to facilitate clustering development in the SSA, which is primarily contained within the area of low landslide risk. The Safety Element also includes policies and programs to minimize risk and vulnerability of the community to hazards and reduce damages.

The Town also has policies to prohibit development on steep slopes where landslide and ground failure are a greater concern; development on slopes exceeding 20 percent are required to submit erosion control plans and slope stabilization programs. Development is prohibited on slopes exceeding 30 percent. Consistency with local and State policies, including the California Building Code, would ensure future development under the Project is designed to reduce landslide risks.
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The Project, which is at the policy level, would have less than significant impacts related to exposure to landslides or floods from fires or runoff.

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21.Mandatory Findings of Significance
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Does the project have the potential to degrade
the quality of the environment, substantially
reduce the habitat of a fish or wildlife species,
cause a fish or wildlife population to drop below
self-sustaining levels, threaten to eliminate a
plant or animal community, reduce the number,
or restrict the range of a rare or endangered plant
or animal, or eliminate important examples of the
major periods of California history or prehistory?
☐ ☐ ☒ ☐
b. Does the project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively considerable” means
that the incremental effects of a project are
considerable when viewed in connection with the
effects of past projects, the effects of other
current projects, and the effects of probable
future projects.)
☐ ☐ ☒ ☐
c. Does the project have environmental effects
which will cause substantial adverse effects on
human beings, either directly or indirectly?
☐ ☐ ☒ ☐
Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory? Less Than Significant. The Project does not include any specific development designs or proposals, nor does it grant any entitlements for development. Development of the sites identified to satisfy the RHNA would not impact or degrade the quality of the environment as these sites are all located in areas that were already developed pre-fire and/or subdivided and are infill lots. Future development under the Project would be consistent with State and local policies that protect special status species and cultural resources.

Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are 388
APRIL 2022 PARADISE HOUSING AND SAFETY ELEMENTS INITIAL STUDY PUBLIC REVIEW DRAFT 81
considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.) Less Than Significant. The Project does not include any specific development designs or proposals, nor does it grant any entitlements for development. Development of the sites identified to satisfy the RHNA would not have impacts that are individually limited, but cumulatively considerable. Development under the Project would be incremental over the eightyear planning period, and so potential impacts would not occur all at once.

Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
Less Than Significant. The Project is at the policy level and encourages the provision of a range of housing types and affordability levels. The Project does not include any specific development designs or proposals, nor does it grant any entitlements for development.

Development of the sites identified to satisfy the RHNA would not have environmental effects which will cause substantial adverse effects on human beings either directly or indirectly. The proposed Housing Element could, instead, have positive impacts resulting from additional housing opportunities for the citizens of Paradise, and the proposed Safety Element could have positive impacts on the well-being and safety of the people and property of Paradise.

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IV. LIST OF PREPARERS
Town of Paradise
Susan Hartman, Community Development Director
Prime Consultant
Urban Planning Partners, Inc.

Lynette Dias, Principal
Curtis Banks, Principal Planner
Leslie Carmichael, Principal Planner
Meredith Rupp, Senior Planner
Alyssa Chung, Planner
Tabitha Tolsma, Assistant Planner
Additional Project Consultants
Transportation
W-Trans
Kittleson & Associates
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391
PARADISE HOUSING AND SAFETY ELEMENTS INITIAL STUDY APRIL 2022 84 V. REFERENCES
Butte County Department of Public Works, 2021. Negative Declaration Neal Road Recycling and Waste Facility Composting Project. Prepared by Dudek. March.

California Department of Conservation, 2021. CGS Information Warehouse: Mineral Land Classification. Available at
https://maps.conservation.ca.gov/cgs/informationwarehouse/index.html?map=mlc.

Access November 12, 2021.

California Energy Commission. Frequently Asked Questions – 2019 Building Energy Efficiency Standards. Available at https://www.energy.ca.gov/sites/default/files/2020- 06/Title24_2019_Standards_detailed_faq_ada.pdf. Accessed on November 16, 2021.

CEC, 2021. “Electricity Consumption by Entity.” Available at http://ecdms.energy.ca.gov/elecbyutil.aspx. Accessed November 16, 2021.

Cissell, Craig, Deputy Director Waste Management Division, Butte County Public Works. 2021.

Personal communication with Urban Planning Partners. December 6.

Efseaff, Dan, District Manager, Paradise Recreation & Park District. 2021. Personal communication with Urban Planning Partners. December 6.

Mason, Rick, Butte County Fire Chief, Cal Fire and Butte County Fire Department. 2021. Personal communication with Urban Planning Partners. March 31.

McCreedy, David, Assistant Superintendent, Business Services, Paradise Unified School District. 2022. Personal communication with Urban Planning Partners. April 4.

Paradise Irrigation District, 2021. Urban Water Management Plan. June.

Reinbold, Eric, Chief of Police, Paradise Police Department. 2021. Personal communication with Urban Planning Partners. November 3.

Reinbold, Eric, Chief of Police, Paradise Police Department. 2022. Personal communication with Urban Planning Partners. March 31.

Sufi Narinder. Butte County Librarian, Butte County Library. 2022. Personal Communication with Urban Planning Partners. March 30.

Town of Paradise, 1994. Paradise General Plan Environmental Setting Document.

Victoria Transport Policy Institute.2020. Land Use Impacts On Transport: How Land Use Factors Affect Travel Behavior. June 5.
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APPENDIX A
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Kittelson & Associates, Inc.

Technical Memorandum

INTRODUCTION
This memorandum presents the findings of the transportation impact analysis conducted for the Paradise Housing Element and Safety Element (herein referred to as the “project”). The proposed project will establish the proposed future zoning and planned housing development for the 14,700-acre Town of Paradise (“Town”) planning area.

The potential effects of the Housing Element component are the primary focus of this analysis, as its implementation has the potential to impact physical conditions related to transportation. The Housing Element provides a blueprint to develop up to 7,179 dwelling units (DUs) town wide, with 6,837 of those units being replacement DUs for those lost in the fire, and with an expectation that up to 3,075 DUs would be constructed by 2030. The Safety Element component of the project provides a framework of policies related to increasing resiliency against disasters and minimizing risk to hazards. Such policies will not directly impact transportation and indirect impacts will be minimal.

EXISTING CONDITIONS
The Paradise planning area encompasses 14,700 acres (see Figure 1). Land use is dominated by residential and commercial uses with a limited number of industrial activities. Constraints on development include a shortage of flat, developable land, poor soils for septic tank use, and potential water supply limitations.

Paradise can be considered low density and/or rural, which has a direct impact on transportation and mobility. There are limited options for using public transit, and in many areas, it is physically difficult to walk or bike between destinations due to limitations in the pedestrian and bicycle network such as lack of sidewalks and bicycle lanes. As a result, most people drive to their destinations.

After the 2018 Camp Fire, traffic in the impacted community decreased, while traffic levels in the primary surrounding communities increased. Weekday activity between the areas impacted by the fire and neighboring areas increased due to contractors, supplies, and people commuting to temporary housing and jobs.
155 Grand Avenue, Suite 505
Oakland, CA 94612
P 510.839.1742
April 15, 2022 Project# 26067
To: Meredith Rupp, Lynette Dias (Urban Planning Partners) From: Mike Alston, Mike Aronson, Mike Alston (Kittelson & Associates, Inc.) RE: Town of Paradise Housing Element DRAFT Transportation Analysis Memo 394
April 15, 2022 Page 2
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A description of the existing roadway, transit, bicycle, and pedestrian components of the transportation system within the Town of Paradise is provided in the following sections.

Roadway Network
The existing roadway network in the Town of Paradise is composed of a street system made up of primarily arterials and collector roads. The roadway network is also shown graphically in Figure

2. Roadway classifications provided are from the 1994 Town of Paradise General Plan.  Principal Arterials: Principal arterials are generally forty to sixty-four feet in width with eighty feet of right-of-way. The primary function of principal arterials is to expedite through traffic to major traffic generators. The generators include central business districts, community shopping centers and traffic between communities and/or between freeways and “lower” arterial systems.
 Minor arterials: Minor arterials service inter-community traffic trips between neighborhoods or trips between a neighborhood and a higher arterial. They are normally twenty-eight to forty feet wide on sixty-foot rights-of-way.
 Collectors: Collectors provide some through traffic movement, carry local traffic within the local area (neighborhood), and primarily provide access to abutting land and to higher roadway classifications (minor or principal arterials). They primarily serve local traffic of a neighborhood or a commercial/industrial area.
 Access Streets: Access streets are designed to serve traffic that is destined for and originating from abutting land. The adjacent land is most often residential, but access streets also serve industrial and commercial areas. The Town of Paradise utilizes a great number of private streets as local streets.
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Figure 1: Study Area
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Figure 2: Existing Roadway Network
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Transit Facilities
The Town of Paradise is primarily served by the B-Line (Butte Regional Transit), which is Butte County's regional public transit system. Residents can use B-Line to travel locally in and between Chico, Oroville, Paradise, or communities throughout Butte County.

B-LINE
The B-Line operates three main routes in Paradise that directly serve the area through nearby street-side bus stops. These routes run locally and are meant to connect the residents of Paradise to nearby job centers and communities in Chico, Oroville, and Magalia. They are summarized in Table 1.

Table 1: Bus Routes Serving the Area
Route Description Day Operating Times Frequency
31 Southbound direction
starts at Almond &
Birch in Paradise and
ends at Mitchell &
Spencer in Oroville
Weekday 6:45 AM 5:56 PM One bus per day
40 Westbound direction
starts at Almond &
Birch in Paradise and
ends at the Transit
Center on 2nd &
Salem in Chico
Weekday 6:00 AM 7:26 PM Every 2 hours
Saturday 7:50 AM 7:03 PM Every 2 hours
Sunday 9:50 AM 6:00 PM Every 2 hours
41 Westbound direction
starts at Skyway &
Colter in Magalia,
travels through
Paradise along
Skyway to Almond &
Birch, and ends at
the Transit Center on
2nd & Salem in Chico
Weekday 5:50 AM 6:53 PM Every 2 hours
Saturday 9:45 AM 6:03 PM Every 3 hours
Bicycle and Pedestrian Facilities
Bicycle and pedestrian facilities are important components of a transportation network. They offer non-vehicular opportunities for commute and recreational trips and provide connections to the region’s transit network.
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BICYCLE FACILTIES
Bicycle facilities are defined by the following four classes1:
 Class I – Provides a completely separated facility designed for the exclusive use of bicyclists and pedestrians with crossing points minimized.
 Class II – Provides a restricted right-of-way designated lane for the exclusive or semiexclusive use of bicycles with through travel by motor vehicles or pedestrians prohibited, but with vehicle parking and crossflows by pedestrians and motorists permitted.  Class III – Provides a right-of-way designated by signs or permanent markings and shared with pedestrians and motorists.
 Class IV – Provides a restricted right-of-way designated lane for the exclusive use of bicyclists that is separated by a vertical element to provide further separation from motor vehicle traffic.

Figure 3 displays existing and planned bikeways.

PEDESTRIAN FACILITIES
There are limited pedestrian facilities in Paradise. The Yellowstone Kelly Heritage Trailway traverses through the town as a recreational path for families, joggers, hikers, and bikers alike.

Sidewalks are present intermittently along some major roadways. Crosswalks are present intermittently at signalized and unsignalized intersections. 1 As detailed in Chapter 1000 of the Highway Design Manual (Caltrans, 2015). 399
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Figure 3: Existing and Planned Bikeways
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Vehicle Miles Traveled
Daily vehicle miles traveled (VMT) is a measure used to capture the relationship between land use and transportation and its effect on greenhouse gas emissions, since vehicle miles traveled is typically directly related to emissions. VMT is discussed in the Regulatory Setting section.

The BCAG travel demand model was referenced to assess the baseline and future year average household VMT per resident for the transportation analysis zones (TAZs) that comprise the Paradise planning area and Butte County. The BCAG Post-Camp Fire Model Update (Version

1.2) was used. Relevant to the Housing Element, the model outputs include regional household VMT per resident averages, which are shown for the County and the Town in Table 2.

Table 2: BCAG Travel Demand Model Daily Home-Based VMT per Resident Planning Area Model Year 2020 Model Year 2045
Butte County Average 11.6 12.3
Paradise 15.8 17.5
Source: BCAG
As Table 2 demonstrates, the average VMT per resident in Paradise is 36 to 42 percent higher than the county average in baseline and future year conditions, respectively. Figure 4 and Figure 5 show the low-VMT TAZs (at least 15 percent below Butte County average) within Paradise in the Model Year 2020 and 2045 (depicted as light blue polygons). Overall, a small portion of the Town is considered “low VMT,” and most of the developable area is considered a “high VMT” area in comparison with countywide averages. 401
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Figure 4: Home-Based VMT per Resident, 2020
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Figure 5: Home-Based VMT per Resident, 2045
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REGULATORY SETTING
This section summarizes applicable federal, state, regional, and local plans, laws, and regulations that are relevant to this analysis. This information provides a context for the discussion related to the project’s consistency with applicable policies, plans, laws, and regulations.

Federal
No federal plans, policies, regulations, or laws pertaining to transportation have been determined to be applicable to this project.

State
SENATE BILL 743
Senate Bill 743 (SB 743) was signed into law in September 2013. Senate Bill 743 (Steinberg, 2013) required changes to the CEQA Guidelines regarding the analysis of transportation impacts.

Historically, CEQA transportation analyses of individual projects determined impacts in the circulation system in terms of roadway delay and/or capacity at specific locations. SB 743 changes include the elimination of auto delay, level of service (LOS), and other similar measures of vehicular capacity or traffic congestion as a basis for determining significant impacts. Those proposed changes identify vehicle miles traveled (VMT) as the most appropriate metric to evaluate a project’s transportation impacts. Since the bill has gone into effect, automobile delay, as measured by “level of service” and other similar metrics, no longer constitutes a significant environmental effect under CEQA. Auto-mobility (often expressed as “level of service”) may continue to be a measure for planning purposes.2 In December 2018, the California Governor’s Office of Planning and Research (OPR) and the State Natural Resources Agency submitted updated CEQA Guidelines to the Office of Administrative Law for final approval to implement SB 743. The Office of Administrative Law approved the updated CEQA Guidelines, thus implementing SB 743 and making VMT the primary metric used to analyze transportation impacts. The final text, final statement of reasons, and related materials are posted at http://resources.ca.gov/ceqa. The changes have been approved by the Office of the Administrative Law and are now in effect. For land use and transportation projects, SB 743-compliant CEQA analysis became mandatory on July 1, 2020. 2 Governor’s Office of Planning and Research, 2016. Technical Advisory on Evaluating Transportation Impacts in CEQA, Implementing Senate Bill 743 (Steinberg, 2013)
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Regional

BUTTE COUNTY ASSOCIATION OF GOVERNMENTS
The Butte County Association of Governments (BCAG) is the federally designated Metropolitan Planning Organization (MPO) and the state designated Regional Transportation Planning Agency for Butte County. BCAG has a 10-member Board of Directors, including each of the five Butte County Supervisors and one council person from each of the five incorporated cities/town (Biggs, Chico, Gridley, Oroville, and Paradise).
6th Cycle Regional Housing Needs Plan
BCAG issued the Regional Housing Needs Allocation (RHNA) for all the jurisdictions in Butte County in its Regional Housing Needs Plan in December 2020. The allocations took into consideration the 15 factors mandated in Government Code Section 65584.04(e), including the distribution of household growth in the Regional Transportation Plan (RTP), described below, and opportunities to maximize use of transit and existing transportation infrastructure. The allocation methodology also considered the lost housing units in the Camp Fire and allocated fire rebuild units to Paradise and the Unincorporated County based on actual unit loss. The fire rebuild allocation represent 60 percent of the housing units destroyed in the Camp Fire.

Table 3 shows Paradise’s RHNA across the four income categories.

Table 3: RHNA Allocations by Income Category, Town of Paradise Income Level Regular
Growth
Fire
Rebuild
Total
Very Low Income (0-50%
AMI)
73 310 383
Low Income (51-80% AMI) 64 310 374
Moderate Income (81-
120% AMI)
32 1,287 1,319
Above Moderate Income
(over 120% AMI)
173 4,930 5,103
Total 342 6,837 7,179
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Regional Transportation Plan/Sustainable Communities Strategy As the Regional Transportation Planning Agency, BCAG published the Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) in 2020 (adopted December 10, 2020)3. BCAG also prepared and certified the 2020 Regional Transportation Plan/Sustainable Communities Strategy Supplemental Environmental Impact Report (RTP/SCS SEIR)4 and adopted a Statement of Overriding Consideration for the significant and unavoidable impacts. The RTP/SCS is a planning document that specifies the policies, projects, and programs necessary over a 20 or more-year period to maintain, manage, and improve the region’s transportation system. The RTP/SCS includes an Air Quality Conformity Analysis and a Program Environmental Impact Report (RTP/SCS EIR). The RTP/SCS is updated every four years.

During the 2020 RTP/SCS development, the 2018 Camp Fire in Butte County destroyed approximately 153,000 acres of property, 13,972 residences, 528 commercial buildings, and 4,293 other structures. It resulted in 85 fatalities. BCAG is responsible for developing and maintaining a regional travel model that includes estimates and projections of population, housing, land use, and travel through the RTP/SCS. The Camp Fire disrupted any ability to accurately forecast these items for the 2020 RTP/SCS. Therefore, BCAG chose to use the “best available” data at the time to complete the 2020 RTP/SCS and commission a “Post-Camp Fire Regional Population & Transportation Study” to analyze the related effects of the Camp Fire and inform the subsequent 2024 RTP/SCS.

The RTP/SCS included studying a “medium growth” scenario which included the forecasts for Paradise shown in Table 4. This forecast growth exceeds the growth associated with the project; therefore, the project’s effects are consistent with the findings analyzed in the RTP/SCS. 3 2020 Regional Transportation Plan/Sustainable Communities Strategy, 2020-2040. Butte County Association of Governments. December 10, 2020. http://www.bcag.org/Planning/RTP-- SCS/index.html. Accessed January 21, 2022.
4 2020 Regional Transportation Plan/Sustainable Communities Strategy. Draft Supplemental Environmental Impact Report. Rincon Consultants. October 2020, certified December 10, 2020.

Note that a Response to Comments Document or Final EIR was not prepared as no comments were submitted on the Draft SEIR.
http://www.bcag.org/documents/planning/RTP%20SCS/2020%20RTP%20SCS/SEIR/_2020%20RTP% 20-%20SCS%20SEIR.pdf. Accessed January 21, 2022.
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Table 4: Housing Forecasts - Total Dwelling Units 2018-2040 Jurisdiction 2018 2020 2025 2030 2035 2040 Total
Increase
2018-
2040
Percent
Increase
2018-
2040
Paradise 13,091 1,916 6,490 9,318 10,811 11,347 -1,744 -13% Note: 2018 dwelling unit count obtained from State of California, Department of Finance, E-5 Population and Housing Estimates for Cities, Counties, and the State, 2010-2019, with 2010 Benchmark. Sacramento, California, May 2019.

Sources: BCAG RTP/SCS
The RTP/SCS concluded that implementation of its proposed transportation improvements has the potential to interfere with achievement of VMT reductions set forth in the California Air Resource Board’s 2017 Scoping Plan; therefore, RTP/SCS impacts related to VMT would be significant and unavoidable. The RTP/SCS proposes mitigation measures that must be collaboratively developed and implemented with local agencies to achieve further VMT reductions. These include the following:

Local-Level

1. Increase diversity of land uses. This strategy focuses on the inclusion of mixed uses within projects or in consideration of the surrounding area to minimize vehicle travel in terms of both the number of trips and the length of those trips.

2. Provide pedestrian network improvements. This strategy focuses on creating a pedestrian network within the project and connecting to nearby destinations. Projects in Butte County tend to be small, so the emphasis of this strategy would likely be the construction of network improvements that connect the project site directly to nearby destinations.

Alternatively, implementation could occur through an impact fee program or benefit/assessment district targeted to various areas in the county designated for improvements through local or regional plan. Implementation of this strategy may require regional or local agency coordination and may not be applicable for all individual land use development projects.

3. Provide traffic calming measures and low-stress bicycle network improvements. This strategy combines the California Air Pollution Control Officers Association (CAPCOA) research focused on traffic calming with new research on providing a low-stress bicycle network. Traffic calming creates networks with low vehicle speeds and volumes that are more conducive to walking and bicycling. Building a low-stress bicycle network produces a similar outcome. Implementation options are similar to strategy 2 above. One potential change in this strategy over time is that e-bikes (and e-scooters) could extend the effective range of travel on the bicycle network, which could enhance the effectiveness of this strategy.

4. Implement car-sharing program. This strategy reduces the need to own a vehicle or reduces the number of vehicles owned by a household by making it convenient to access a shared vehicle for those trips where vehicle use is essential. Note that implementation of this strategy would require regional or local agency implementation 407
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and coordination and would not likely be applicable for individual development projects.

5. Increase transit service frequency and speed. This strategy focuses on improving transit service convenience and travel time competitiveness with driving. Given land use density in Butte County, this strategy may be limited to traditional commuter transit where trips can be pooled at the start and end locations or require new forms of demandresponsive transit service. The demand-responsive service could be provided as subsidized trips by contracting to private Transportation Network Companies (TNCs, such as Uber, Lyft, and Via) or taxi companies. Alternatively, a public transit operator could provide the subsidized service but would need to improve on traditional cost effectiveness by relying on TNC ride-hailing technology, using smaller vehicles sized to demand, and flexible driver employment terms where drivers are paid by trip versus by hour. Note that implementation of this strategy would require regional or local agency implementation, substantial changes to current transit practices, and would not likely be applicable for individual development projects.

6. Implement subsidized or discounted transit program. This strategy reduces the need to own a vehicle or reduces the number of vehicles owned by a household by incentivizing individuals to use transit for their daily commute. This strategy depends on the ultimate building tenants—whether residential landlords or businesses—and may require monitoring. This strategy also relies on B-Line continuing to provide similar or better service throughout the county, in terms of frequency and speed.

7. Encourage telecommuting and alternative work schedules. This strategy relies on effective internet access and speeds to individual project sites/buildings to provide the opportunity for telecommuting. The effectiveness of the strategy depends on the ultimate building tenants and the nature of work done by tenants’ employees (can the work be done remotely in the first place?); two factors that should be considered for potential VMT reduction. Effectiveness may also be limited in more rural areas of the county with limited broadband access.

8. Provide ride-sharing programs. This strategy focuses on encouraging carpooling and vanpooling by project site/building tenants, which depends on the ultimate building tenants; this should be a factor in considering the potential VMT reduction.

Regional
Implementing agencies shall require project modifications during the project design and environmental review stage of project development that would reduce VMT effects. For roadway capacity expansion projects, this would include but is not limited to demand management through transportation systems management and operations (TSMO) including the use of pricing.

The Town has subsequently adopted the RTP/SCS and implemented the recommended locallevel mitigation measures as Town policy. 408
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Local
TOWN OF PARADISE 1994 GENERAL PLAN (AS AMENDED THROUGH
OCTOBER 2010)
The Town of Paradise last adopted its General Plan in 1994, with amendments through 2010. It serves as the Town’s guide for continued development and enhancement. The following goals, objectives, policies, and implementation measures related to transportation and circulation are applicable to the project:

Circulation Goals
 CG-1 Support cooperative and coordinated transportation planning and development activities with federal, state, regional, and local agencies in order to assure maximum coordination of effort in the Paradise region.  CG-2 Provide safe, efficient, and effective traffic flow, both within Paradise and between Paradise and its environs.
 CG-3 Enhance and improve pedestrian and bicycle safety and use by establishing additional linkages between areas of town.
 CG-4 Provide adequate access, including access for emergency vehicles and evacuation, to all new parcels and to existing parcels when feasible.  CG-5 Maintain and improve local and regional air quality.  CG-6 Reduce reliance on the automobile by careful land use planning and encourage the use of non-automobile travel modes through a balanced and integrated set of land use and transportation planning policies.

Circulation Objectives
 CO-3 Assure that traffic generated by high density residential land use development will not exceed roadway capacity and level of service standards.  CO-5 Plan and complete public street improvements to accommodate projected traffic during the planning period.
 CO-6 As necessary, revise and update both the bicycle and pedestrian and the Paradise Memorial Trailway master plans.
 CO-10 Encourage efforts to significantly reduce reliance on the private automobile during the fifteen year planning period.
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Circulation Policies
 CP-1 The town shall strive to maintain a level of service (LOS) “D” or better as the standard for new and existing roadways in the Paradise planning area. LOS “D” or better should be maintained on all local streets within the town limits, and LOS “C” or better should be maintained whenever feasible.
 CP-4 New land use development shall be required to mitigate its share of the circulation impacts it creates.
 CP-5 Methods of recovering costs associated with use of roadways within the Town of Paradise by residents of the Upper Ridge should be explored, including imposition of development impact fees.
 CP-10 Safe paths for pedestrians, equestrians, and bicyclists should be provided, particularly for school children and the elderly. A sidewalk and pathway development program should be instituted for selected locations and where feasible should link with the Paradise Memorial Trailway.  CP-12 The Town shall encourage Butte County to require development applications within the secondary planning area [Sphere of Influence] to dedicate and improve streets to town standards and to provide other transportation improvements (e.g., bus stops, park-and-ride lots).
 CP-13 Automobile dependency within Paradise should be reduced for local residents and visitors by implementing congestion management and trip reduction plan programs that decrease the number of vehicle miles travelled which, in turn, reduces air pollution and congestion and saves energy.
 CP-14 As staff and funding become available, expanded transit services for seniors and the handicapped should be promoted in accordance with the results of future studies.
 CP-15 Expand public transportation services within Paradise and between Paradise and major employment centers as feasible, based on service demand and financial constraints.
 CP-17 Whenever the LOS “D” is reached on roadways within Paradise, the town shall explore all feasible alternatives for improving traffic flow, rather than automatically implementing a road widening project.
 CP-19 As staff and resources become available, the town should strive to increase the transit opportunities for children and senior citizens in the community. 410
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Circulation Implementation Measures
 CI-3 Establish a town wide development impact fee program, and review and update on an annual basis.
 CI-6 Identify locations for sidewalks and pathways along existing major collector and arterial roadways as well as standards for requiring sidewalks adjacent to new developments.
 CI-7 Require new development to provide a pedestrian pathway on at least one side of new public streets and new private roads (if feasible).  CI-8 Improve shoulders of some roads to make them safer for pedestrians and bicyclists and relocate mailboxes where feasible from sidewalks.  CI-9 Require transportation facilities such as bus stops to be incorporated into major new developments.

As listed above, the General Plan has goals, objectives, policies, and implementation measures related to maintaining mobility as measured through Level of Service (LOS). However, LOS is no longer deemed an appropriate transportation measure of environmental impact under CEQA and is therefore not relevant to this memorandum focusing on CEQA impacts.

TRANSPORTATION MASTER PLAN
The Town is currently developing its comprehensive Transportation Master Plan (TMP). The TMP will guide long-term transportation improvements. Key components of the TMP include:
 Traffic needs analysis: This analysis will recommend improvements to the roadway system serving connetions to schools, parks, shopping areas, jobs, and local homes. The recommended concepts will address traffic and circulation needs for all roadway users.  Traffic evacuation planning: This planning analyzes the Town’s transportation network to serve traffic evacuation needs and will address pinch points, improve the backbone network, identfy new connections, facilitate operations during an evacuation, and coordinate with regional partners and public safety responders.  Active Transportation Plan: This plan will evaluate opportunities for walking paths, sidewalks, and bikeways and will position the Town to pursue grant funding for implementation.

Other components of the TMP include economic/redevelopment support, new roadway standards, and major projects coordination.

As part of the evacuation planning, the Town is determining major and secondary evacuation routes, potential areas of congestion, and opportunities for roadway extensions and connections on dead-end streets for additional routes and increased evacuation capacity.

Figure 6 shows identified draft proposed roadway modifications, which include:
 Roadway widening, particularly downtown Skyway between Elliott Road and Pearson Road 411
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 Roadway widening plus a multiuse path for emergency response along segments of Skyway, Clark Road, and Pentz Road.
 Roadway extensions including Roe Road and Elliot Road  Intersection modifications
Figure 7 and Figure 8 show proposed evacuation routes and modifications to serve those routes. 412
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Figure 6: DRAFT Roadway Modifications as Part of Paradise TMP Source: Headway Transportation, Town of Paradise
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Figure 7: DRAFT Planned Evacuation Modifications
Source: Headway Transportation, Town of Paradise
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Figure 8: Paradise Major Evacuation Routes
Source: Headway Transportation, Town of Paradise
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TRANSPORTATION ANALYSIS
This transportation analysis assesses how the study area’s transportation system would operate with the implementation of the proposed project. This analysis includes effects that would result in significant impacts under the California Environmental Quality Act (CEQA) guidelines.

CEQA Significance Criteria
The project’s impact is not considered to be significant unless it would:
a. Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. b. Conflict or be inconsistent with CEQA Guideline section 15064.3, subdivision (b). c. Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). d. Result in inadequate emergency access.

Significance criteria “b” is related to the implementation of vehicle miles traveled (VMT) as the primary performance metric. The following criterion is used to assess a significant impact related to VMT consistent with considerations presented in the BCAG SB 743 Implementation study dated June 2021:5
 A proposed residential project in an area exceeding a level of 15 percent below existing regional average home-based VMT per resident (also referred to as 85 percent threshold) would result in a significant VMT impact. Home-based VMT per resident includes all automobile (i.e., passenger cars and light-duty trucks) vehicle-trips that start or end at the home but excludes non-home-based trips made by residents elsewhere in the transportation network.

The baseline for comparison is the 2020 model base year which is based on 2020 land use levels, but more “typical” pre-COVID travel patterns.

VMT Analysis
As described in the Existing Conditions section, the BCAG travel demand model was referenced to assess the baseline and future year average household VMT per resident for the TAZs that comprise the Paradise planning area and Butte County. The table demonstrating comparative 5 BCAG SB 743 Implementation, Fehr & Peers. June 2021. http://www.bcag.org/Planning/SB-743- Implementation-Study/index.html. Accessed January 21, 2022. 416
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VMT is recreated in Table 5, with the addition of the level that would represent 15 percent below the countywide average.

Table 5: BCAG Travel Demand Model Daily Home-Based VMT per Resident Planning Area Model Year 2020 Model Year 2045
Butte County Average
(Resulting 85% Threshold)

11.6 12.3
Level at 15% Below County
Average

9.9 10.5
Paradise 15.8 17.5
Source: BCAG
As Table 5 demonstrates, the average VMT per resident in Paradise is 60 or more percent higher than the impact threshold of 15 percent below existing regional average home-based VMT per resident. The SB 743 guidelines also allow for comparison of VMT values within the Town. For the project to result in VMT below the 15% reduction threshold, proposed residential development would need to be concentrated in low-VMT areas within the Town.

The approximate locations of planned dwelling units for the housing element were compared to model outputs at a screening level to assess whether the Housing Element may, in aggregate, be building in low VMT areas and therefore result in less-than-significant VMT impacts.

Figure 9, compared against Figure 4 and Figure 5, demonstrates that the proposed residential development is not concentrated in low-VMT areas and therefore would more contribute to more residential development in high VMT areas.
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Figure 9: Project Residential Locations
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CEQA PROJECT IMPACTS AND PROPOSED

MITIGATIONS
THRESHOLD: WOULD THE PROJECT CONFLICT WITH A PROGRAM, PLAN, ORDINANCE OR

POLICY ADDRESSING THE CIRCULATION SYSTEM, INCLUDING TRANSIT, ROADWAY, BICYCLE, AND PEDESTRIAN FACILITIES?
Impact TRANS-1 The proposed project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. This would be considered a less-than-significant impact.

Development associated with the proposed project would increase the residential density within the Town of Paradise, comprised largely of reconstructing dwelling units destroyed by the 2018 Camp Fire. No components of the proposed project conflict with the General Plan goals, objectives, policies, and implementation measures previously described. Similarly, no aspect of the planned increase in housing development and residential density conflicts with existing or planned bicycle facilities, rail facilities, or transit service. Additionally, development that occurs as part of the project (Housing Element implementation) will comply with the policies adopted by the Town as part of its adoption of the RTP/SCS. Policies in the RTP/SCS will promote future residential development to align with existing regional programs, plans, ordinances, and policies:
 Provide pedestrian network improvements. Network improvements that connect individual sites to existing networks and nearby destinations would improve opportunities for walking in Paradise.
 Provide traffic calming measures and low-stress bicycle network improvements. Providing low-stress bicycle infrastructure that connects areas of proposed development to existing and planned networks would improve opportunities for biking in Paradise.  Implement subsidized or discounted transit program. Whether implemented on a projectby-project basis or programmatically with applicability to future residents, subsidized transit would improve opportunities for people to take transit to, from, and within Paradise.

No mitigation measures would be required. This conclusion is consistent with the RTP/SCS Impact T-1 finding.

THRESHOLD: WOULD THE PROJECT CONFLICT OR BE INCONSISTENT WITH CEQA GUIDELINES SECTION 15064.3, SUBDIVISION (B) - A PROPOSED RESIDENTIAL PROJECT IN AN AREA EXCEEDING A LEVEL OF 15% BELOW EXISTING REGIONAL AVERAGE HOMEBASED VMT PER RESIDENT? Impact TRANS-2 Implementation of the project would conflict with or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b) - A proposed residential project in an area exceeding a level of 15% below existing regional average home-based VMT per resident. This would be considered a significant impact.
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As described in the VMT Analysis section and shown in Figure 9, the majority of proposed residential development under the project would be located in areas in which residents on average generate at least 85% of the regional daily residential vehicle miles traveled on a per resident basis (“high VMT areas”). Therefore, the project would conflict with CEQA guidelines and regional VMT reduction goals consistent with the findings of the RTP/SCS EIR.

As described above, BCAG certified the RTP/SCS SEIR and adopted a statement of overriding considerations for the significant and unavoidable impacts. The Town of Paradise subsequently relied on the BCAG’s EIR and adopted the updated RTP/SCS and also adopted findings of overriding consideration. The finding that implementation of the project would result in a significant VMT impact is consistent with the findings of the RTP/SCS EIR. As part of adopting the RTP/SCS, the Town committed to the policies in the plan as well as the local-level mitigation measures from the EIR, as a result, the following mitigation measures are applicable to the project:

1. Increase diversity of land uses.

2. Provide pedestrian network improvements.

3. Provide traffic calming measures and low-stress bicycle network improvements.

4. Implement car-sharing program.

5. Increase transit service frequency and speed.

6. Implement subsidized or discounted transit program.

7. Encourage telecommuting and alternative work schedules.

8. Provide ride-sharing programs.

On April 12, 2022, the Town adopted the VMT policies based upon the BCAG required mitigation measures for air quality and transportation as Resolution 2022-24. Therefore, some subsequent residential projects that may have resulted in an impact would be reduced to less than significant. Programmatically however, that cannot be guaranteed. Therefore, this impact would remain significant and unavoidable consistent with the findings of the RTP/SCS Impact T-2 finding and no additional mitigation is needed.

THRESHOLD: WOULD THE PROJECT SUBSTANTIALLY INCREASE HAZARDS DUE TO A GEOMETRIC DESIGN FEATURE (E.G., SHARP CURVES OR DANGEROUS INTERSECTIONS) OR INCOMPATIBLE USES (E.G., FARM EQUIPMENT)?
Impact TRANS-3 Implementation of the project would not substantially increase hazards due to a geometric design feature or incompatible uses. This would be considered a less-thansignificant impact.

The project designates future feasible sites for residential development and is proposing to increase the amount and density of residential land uses. The Housing Element includes programs to rezone land within the Town’s planned Sewer Service Area. A Sewer Service Overlay Zoning District would be established with implementation of the project that would apply only when the sewer is implemented. Most notably, the Sewer Service Overlay Zone would increase the allowed residential density in the Community Facilities (C-F) zone from 1 dwelling unit per acre to 20 dwelling units per acre. Other changes would be less substantial, and the project 420
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identifies residential development sites only where adjacent land uses are compatible.

Therefore, the project would not introduce incompatible land uses.

The Safety Element also contains programs and policies related to updating the transportation network, but it does not propose new roadway design features. Rather, any future residential development covered in this project would be subject to local development review to include a review of design features and would be required to comply with all local and state design guidelines. Two policies from the Safety Element related to emergency access are included below:
 Implement other circulation improvements in the Transportation Master Plan that will provide benefits for emergency preparedness, response, and evacuation. The Town will include emergency vehicle access requirements in the Paradise Municipal Code subdivision and zoning ordinances, Town-adopted road standards, and Town-adopted current California Fire Codes. Through the development review process and in accordance with the Butte County Community Wildfire Protection Plan, adequate roads shall be required to be constructed and/or improved for emergency vehicle access, particularly in high wildland fire hazard areas.
 Continue to limit the densities of development on parcels that do not have adequate emergency access. At a minimum, the Town will not approve any discretionary permit or project that requests an increase of existing residential density on parcels that are served access by either an existing or resultant cul-de-sac exceeding a maximum length of 1,800 lineal feet. The Town will look to the Transportation Master Plan and Board of Forestry for guidance on potentially developing more stringent access requirements. New development will be assessed on a project basis to ensure that new land uses will not cause emergency responses times to fall below acceptable levels. The Town will strive to maintain an overall fire insurance (ISO) rating of three or better, and an emergency fire response within five minutes for 90 percent of all emergency incidents within the Town Limits.

For the reasons above, the project is not anticipated to cause a substantial increase in hazards due to design features or incompatible uses. No mitigation measures would be required. This conclusion is consistent with the RTP/SCS Impact T-3 finding.

THRESHOLD: WOULD THE PROJECT RESULT IN INADEQUATE EMERGENCY ACCESS? Impact TRANS-4 Implementation of the project would not result in inadequate emergency access. This would be considered a less-than-significant impact.

As individual residential projects designated in this project come online, the Town will coordinate with individual projects to ensure that emergency routes are not blocked and remain available during construction.

There are no other components of the project that would have the potential to impact emergency access. No mitigation measures would be required. This conclusion is consistent with the RTP/SCS T-4 finding.
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Town of Paradise
Council Agenda Summary
Date: June 14, 2022
Agenda Item: 6(a)
ORIGINATED BY: Susan Hartman, Community Development
Director – Planning & Wastewater
REVIEWED BY: Kevin Phillips, Town Manager
SUBJECT: Consider Introducing an Ordinance that Amends
Paradise Municipal Code Chapter 8.08 [Solid Waste
Collection] and Adds a New Article 1 to Chapter 8.08

LONG TERM
RECOVERY PLAN:

No
COUNCIL ACTION REQUESTED:

1. Consider waiving the first reading of Town Ordinance No. ____ and read by title only [roll call vote]; AND

2. Introduce Town Ordinance No. ____, “An Ordinance of the Town Council of the Town of Paradise Amending Text Regulations within Paradise Municipal Code Chapter 8.08 [Solid Waste] and Adding Article 1 Regarding Mandatory Municipal MSW, Recyclable Material, and Organic Waste Disposal Reduction Consistent with New State Law Requirements”; OR

3. Provide alternative direction to town staff. (ROLL CALL VOTE) Background:

In 2016, SB 1383 Short-Lived Climate Pollutants (Lara) was adopted which requires the state to reduce organic waste (food waste, green waste, paper products, etc.) disposal by 75% by 2025.

Statewide that equates to a reduction of 20 million tons a year by 2025. In addition, the law also requires the state to increase edible food recovery by 20% by 2025.

SB 1383 has significant jurisdictional requirements starting in 2022 such as:
 Provide organic waste collection to all residents and businesses  Update local solid waste ordinances to meet the requirements of SB 1383  Establish an edible food recovery program that recovers edible food from the waste stream  Conduct outreach and education to all affected parties, including generators, haulers, facilities, edible food recovery organizations, and town departments  Capacity planning: evaluating the jurisdictions readiness to implement SB 1383  Procure recycled organic waste products like compost, mulch, and renewable natural gas  Inspect and enforce compliance with SB 1383
 Maintain accurate and timely records of SB 1383 compliance.

The implementation of SB 1383 aims to reduce methane gas, a contributor to climate change in California. Landfills, where organic waste is primarily disposed of, is the third largest producer of methane in the state – responsible for 21% of the state’s methane emissions (CalRecycle, 2020). 432
CalRecycle estimates that 50-100 new or expanded organic waste recycling facilities will be needed to meet the 20 million ton/year reduction in organic waste disposal needed for SB 1383 – including additional facilities in the northstate.

After being denied a low population waiver by CalRecycle, the Town filed a Notice of Intent to Comply (NOIC), as authorized by SB 619, for an extension on compliance with the organics recycling requirements of SB 1383. The application was accompanied by a resolution of the Town Council and informed CalRecycle of the following:
 An explanation of why the local jurisdiction is unable to comply (lack of organic waste recycling facilities in Butte County, the potential need to go to weekly green waste collection with the addition of food waste and the associated infrastructure needs and costs associated with that).
 Description of any impacts of COVID on compliance.
 Proposed actions the local jurisdiction will take to remedy the non-compliance and the proposed schedule for doing so (timeframe for ordinance amendments, workplan for edible food recovery, and schedule for organics recycling).

On May 16, 2022, the Town was notified that its NOIC was approved and to continue to implement the actions and schedule outlined in the approved NOIC until contacted by CalRecycle staff to discuss next steps and the potential of being issued a Corrective Action Plan due to the proposed compliance extending beyond August 30, 2022.

Analysis:

As previously discussed, one of the requirements of SB 1383 is to adopt and/or amend a solid waste ordinance that includes standards and enforcement in compliance with the Short-lived Climate Pollutants: Organic Waste Reduction requirements of Title 14 California Code of Regulations (14 CCR). Enforceable ordinances were to be in place by the beginning of 2022 with compliance monitoring and education being conducted through calendar year 2023. Beginning January 1, 2024, jurisdictions must take progressive enforcement against organic waste generators that are not in compliance – unless the Town is still under a Corrective Action Plan with CalRecycle due to deficiencies in the organic waste recycling infrastructure or edible food recovery capacity.

CalRecycle provided a model ordinance for jurisdictions to work from to ensure that the adopted ordinance would meet the minimum state requirements. This included additional definitions and terminology, enforcement standards specific to organic waste, and reporting requirements.

The Town’s existing solid waste ordinance, found in Paradise Municipal Code (PMC) Chapter

8.08, is proposed to be amended to include new definitions and in general, updated with the new terminology of “MSW, recyclable materials, and organic waste” in place of the previously used term “solid waste”. It primarily addresses waste collection and disposal. To better address the organic waste requirements of SB 1383, a new “Article 1” is proposed to be added to PMC Chapter 8.08 which addresses waste disposal reduction. New definitions are added, from the state’s model ordinance, as well as Sections detailing the following:
 Organic waste collection requirements for both residential and commercial organic waste generators.
 Potential organic waste waivers for commercial generators that meet low poundage thresholds of organic waste generation as part of their overall municipal solid waste. 433
 Requirements for Tier 1 and Tier 2 commercial edible food generators.  Collection and reporting requirements for food recovery organizations.  Standards for haulers and facility operators.
 Organic waste self-hauling requirements.
 State-mandated procurement requirements for Town Departments.  Compliance with CALGreen recycling requirements (already part of the Town’s building permit process).
 Compliance with the state’s 2015 Model Water Efficient Landscaping Ordinance (MWELO).
 Inspections by Town staff.
 Enforcement procedures and description of violations (includes compliance extensions due to lack of organic waste recycling infrastructure).

An important item to remember is that jurisdictions do not start proactively enforcing organic waste disposal violations, with violation notices and monetary penalties, until January 1, 2024 and then only if we are no longer under a Corrective Action Plan due to the lack of regional organic waste recycling infrastructure. However, the Town still needs to adopt an enforceable ordinance as required by SB 1383 and outlined in our approved Notice of Intent to Comply.

This proposed ordinance fulfills one of many jurisdictional requirements of SB 1383 and the Town’s Notice of Intent to Comply:
 Update local solid waste ordinances to meet the requirements of SB 1383   Establish an edible food recovery program that recovers edible food from the waste stream (in process regionally)
 Capacity planning: evaluating the jurisdictions readiness to implement SB 1383 (in process regionally)
 Conduct outreach and education to all affected parties, including generators, haulers, facilities, edible food recovery organizations, and town departments  Procure recycled organic waste products like compost, mulch, and renewable natural gas  Inspect and enforce compliance with SB 1383
 Maintain accurate and timely records of SB 1383 compliance.  Provide organic waste collection to all residents and businesses Financial Impact:

There is no financial impact associated with the first reading and introduction of the ordinance.

Attachment
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TOWN OF PARADISE
ORDINANCE NO.

AN ORDINANCE OF THE TOWN COUNCIL OF THE TOWN OF PARADISE AMENDING TEXT REGULATIONS WITHIN PARADISE MUNICIPAL CODE CHAPTER 8.08 [SOLID WASTE] AND ADDING ARTICLE 1 REGARDING MANDATORY MUNICIPAL

MSW, RECYCLABLE MATERIAL, AND ORGANIC WASTE DISPOSAL REDUCTION

CONSISTENT WITH NEW STATE LAW REQUIREMENTS
The Town Council of the Town of Paradise, State of California, does ORDAIN AS FOLLOWS:

SECTION 1. Paradise Municipal Code [PMC] Chapter 8.08 shall be amended to read as follows:

Chapter 8.08 – MUNICIPAL MSW, RECYCLABLE MATERIAL, AND ORGANIC SOLID WASTE

COLLECTION

8.08.010 - Title of ordinance.

8.08.020 - Findings.

8.08.030 - Purpose.

8.08.040 - Definitions.

8.08.050 - Franchises.

8.08.060 - Collection standards.

8.08.070 - Solid MSW, recyclable material, and organic waste reduction.

8.08.080 - Ownership of solid MSW, recyclable material, and organic waste—Flow control.

8.08.090 - Universal collection.

8.08.100 - Privacy.

8.08.110 - Restriction on manner of collection.

8.08.120 - Vehicle standards.

8.08.130 - Indemnification.

8.08.140 - Faithful performance.

8.08.150 - Franchise transferrable.

8.08.160 - Franchise fees.

8.08.170 - Franchisee's books and records.

8.08.180 - Compensation.

8.08.190 - Government liaison person.

8.08.200 - General provisions.

8.08.210 - Unlawful action/penalty.

8.08.010 Title of ordinance.

The ordinance codified in this chapter shall be known, and may be cited, as the "solid MSW, recyclable material, and organic waste collection and disposal ordinance." (Ord. No. 459, §§ 1, 2, 3-27-2007; Ord. 257, § 2(part), 1995) 435

8.08.020 Findings.

The town council finds that the provisions of the California Integrated Waste Management Act of 1989 require the town to develop a comprehensive program to reduce, recycle or otherwise divert the town's solid MSW, recyclable material, and organic waste stream from landfill disposal by specific amounts on certain dates.

The town council further finds that the public health, safety, and welfare require that an exclusive franchise be awarded to a qualified enterprise for the collection, transportation, recycling, composting, and disposal of all solid waste MSW in the town.

The town council also finds that the management of solid MSW, recyclable material, and organic waste within the town subject to the provisions of this chapter is in accordance with the goals and policies of the Paradise general plan.
(Ord. No. 459, §§ 1, 2, 3-27-2007; Ord. 257, § 2(part), 1995)

8.08.030 Purpose.

The purpose of this chapter is to:

A. Establish the standards and procedures for complying with the California Integrated Waste Management Act of 1989, Assembly Bills 341 and 1826, and Senate Bill 1383; B. Protect the health, safety and welfare of the general public by establishing appropriate standards governing the collection and disposal of solid MSW, recyclable material, and organic waste;
C. Provide for resource conservation which will provide long-term economic, energy and natural resource benefits to society;
D. Extend the life of the Neal Road Landfill Recycling and Waste Facility by diverting and recycling as much solid MSW, recyclable material, and organic waste as possible; E. Protect the environment by establishing proper collection and disposal programs. (Ord. No. 459, §§ 1, 2, 3-27-2007; Ord. 257, § 2(part), 1995)

8.08.040 Definitions.
"Agreement" means a solid MSW, recyclable material, and organic waste collection and disposal franchise agreement granted in accordance with the standards established in this chapter.
“Authorized Contractor” means a person, company, agency, district, or other entity authorized by the Town Council to provide service or services to collect MSW, recyclable materials, and/or organic waste from others within the Town limits in accordance with the provisions of this Chapter.
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“California Code of Regulations” or “CCR” means the State of California Code of Regulations. CCR references are preceded with a number that refers to the relevant Title of the CCR (e.g., “14 CCR” refers to Title 14 of CCR).
"Collection Services" means MSW, recyclable material, and organic waste collected by the Authorized Contractor pursuant to this Chapter, and Article 1. “Commercial Business,” “Business,” or “Businesses” means all hotels, motor courts, restaurants, offices or office buildings, stores, warehouses, factories, hospitals, assisted living facilities and all other premises used for functions other than dwelling houses, or as otherwise defined in 14 CCR Section 18982(a)(6). A Multi-Family Complex that consists of fewer than five (5) units is not a Commercial Business for purposes of implementing this Chapter. “Compost or Organic Waste” has the same meaning as in 14 CCR Section 17896.2(a)(4) and means those materials that are processed in a controlled biological decomposition process, which are source separated from the municipal MSW stream. Organic waste includes food scraps, food soiled paper products, yard trimmings and wood materials that do not contain hazardous waste.
“Construction and Demolition (C&D) Debris” includes waste building materials, packaging and rubble resulting from construction, remodeling, repair or demolition operations on pavements, houses, commercial and industrial buildings, and other structures and improvements.
“Container” or “Containers” means watertight metal or plastic objects with lids or covers, designed, and used to hold MSW, recyclable materials, organic waste, or cooking oil/grease prior to Collection, provided by the Town or Authorized Contractor. Containers include wheeled carts with lids, bins, open-top roll-off boxes, compactors, and oil/grease tanks. “Contamination” means placing materials in a container that is labeled and intended for storage of another type of material, and which would interfere with the processing of the intended material.
"County" means the County of Butte, a political subdivision of the State of California. "Designated disposal site" means the disposal facility or site to which franchisee elects or is required to transport solid waste MSW collected under the regulatory provisions of this chapter and the agreement for final disposal.
“Enclosure” means a walled structure for the storage of MSW, recyclable materials, and organic waste containers with one or more gates for access. "Franchise area" means the area within the town limits of the town on the effective date of the ordinance codified in this chapter, including any federal or state enclaves, and any areas annexed to the town or coming under the town's MSW management or planning authority after that date.
"Franchise majeure" means acts of God, fire, landslides, lightning, storms, floods, freezing, earthquakes, epidemics, volcanic eruptions, civil disturbances, strikes, lockouts or other industrial disturbances, acts of the public enemy, wars, blockages, public riots, breakage, 437
explosions or accident to machines, pipelines or materials, governmental restraint, unavailability of a disposal site and any other event which could not with reasonable diligence be controlled or prevented by the party affected by the event. "Franchise area" means the area within the town limits of the town on the effective date of the ordinance codified in this chapter, including any federal or state enclaves, and any areas annexed to the town or coming under the town's solid waste management or planning authority after that date.
"Franchisee" means an firm Authorized Contractor who has been granted an exclusive franchise to collect solid waste MSW within the town pursuant to the provisions of this chapter. "Franchisor" means the town which grants an exclusive franchise to collect solid waste MSW within the town pursuant to the provisions of this chapter. “Generate” means to bring into existence or create, or to use, maintain, or possess an item, material or product, the result of which such creation, bringing into existence, use, maintenance, or possession is that the item, material, or product first becomes, or is converted, transformed, evolved to, or deemed as MSW, recyclable material, or organic waste. “Generate” shall not mean or include any form of activity, program, service of business by which MSW, recyclable materials, or organic waste are in any manner collected or accumulated from another person, business, entity, or establishment of any kind. "Generators" means individuals, businesses, and other entities, including the town, that generate solid waste MSW, and/or recyclable and organic materials in the franchise area and are customers of franchisee's services hereunder.
"Gross receipts" means all money, cash, fees, revenues, and gross sums received by franchisee in connection with the provision of services under an agreement, minus all sales taxes and excise taxes required by law to be collected by franchisee in connection with the provision of such services. There shall be no deduction from gross receipts for any overhead or costs or expenses of operation, such as, but without limitation to salaries, wages, costs of goods, interest, debt amortization, discount, collection charges, insurance and taxes, except as specifically provided herein; provided, that gross receipts shall not include federal, state, municipal or other taxes or fees collected from generators (regardless of whether the amount thereof is stated to the generator as a separate chart) and paid periodically by franchisee to a governmental agency, accompanied by a tax return or statement. The amount of such taxes or fees shall be shown on the books and records elsewhere herein required to be maintained. "Hazardous waste" means all solid waste MSW defined or characterized as hazardous waste by the Federal Solid Waste Disposal Act, as amended, including the Resource Conservation and Recovery Act of 1976 (42 U.S.C. Section 6901, et seq.) and all future amendments thereto, or regulations promulgated thereunder; all solid waste MSW defined or characterized as hazardous waste by the principal agencies of the state (including without limitation the Department of Health Services and the California Integrated Waste Management Board) having jurisdiction over hazardous waste generated by facilities with the state, and pursuant to any applicable state or local law or ordinance, and all future amendments thereto, or regulations promulgated thereunder, including without limitation the California Integrated 438
Solid Waste Management Act of 1989; radioactive wastes; any sewage sludge or other residue from wastewater treatment facilities; those substances or items which require special or extraordinary handling or disposal due to their hazardous, harmful, toxic or dangerous character or quality; and those substances and items which are not normally disposed of by generally accepted sanitary landfill disposal methods.
"Recyclable materials" means reusable material, including but not limited to, metals, glass, plastic, and paper, which are intended for reuse, remanufacture, or reconstitution for the purpose of using the altered form. Recyclable material does not include refuse or hazardous materials.
"Solid waste" means all residential, commercial, industrial and quasi-public putrescible and nonputrescible solid and semisolid wastes, including garbage, trash, refuse, paper, rubbish, ashes, demolition and construction wastes, discarded home and industrial appliances, vegetable, or animal solid or semisolid wastes, lawn and garden refuse, such as leaves, grass cuttings, weeds, and trimming from trees and shrubs, and all wastes capable of being recycled that are commingled with other waste. The term "solid waste" shall not include biomedical waste, hazardous waste, special waste, liquid-carried industrial wastes or sewage hauled as an incidental part of a septic tank or cesspool-cleaning service, whether combustible or noncombustible, liquid wastes or sewage sludge.
"Special waste" means those solid wastes which consist of or contain pollutants which, under ambient environmental conditions at a sanitary landfill or other waste management unit could be released at concentrations in excess of applicable water quality objectives, or which could cause degradation of waters of the state, and which may only be discharged at waste management units that are designated either "Class I" or "Class II" by the California Integrated Waste Management Board, or successor agency.
“Inspection” means an action or site visit where the Town reviews records, containers, and an entity’s collection, handling, recycling, or landfill disposal of MSW, recyclable material, organic waste, or edible food handling to determine if the entity is complying with requirements set forth in this Chapter, or as otherwise defined in 14 CCR Section 18982(a)(35). “Multi-Family Complex” means a residential premises with five (5) or more dwelling units.

Multi-Family premises do not include hotels, motels, or other transient occupancy facilities, which are considered Commercial Businesses.
“Municipal MSW” or “MSW” means all fractions of discarded putrescible and nonputrescible solid, semi-solid and liquid wastes, including trash, refuse, paper, rubbish, ashes, industrial wastes, construction and demolition debris, discarded home and industrial appliances, manure, vegetable or animal solid and semi-MSWs, and other discarded substances or materials. MSW does not include:

A. Hazardous Waste, as defined in the State Public Resources Code Section 40141.

B. Low-level Radioactive waste regulated pursuant to the State Radiation Control Law (Chapter 8 (commencing with Section 114960) of Part 9 of Division 104 of the State Health and Safety Code).
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C. Untreated medical waste which is regulated pursuant to the State Medical Waste Management Act (Part 14 (commencing with Section 117600) of Division 104 of the State Health and Safety Code). Untreated medical waste shall not be disposed of in a MSW landfill, as defined in State Public Resources Code Section 40195.1. Medical waste that has been treated and deemed to be MSW shall be regulated pursuant to Division 30 of the State Public Resources Code.

D. Recyclable materials which have been source or type-separated from other waste material. “Organic Waste” means MSWs containing material originated from living organisms and their metabolic waste products, including but not limited to food, green material, landscape and pruning waste, organic textiles and carpets, lumber, wood, paper products, printing and writing paper, manure, biosolids, digestate, and sludges or as otherwise defined in 14 CCR Section 18982(a)(46). Biosolids and digestate are as defined by 14 CCR Section 18982(a). “Owner” means the legal owner of real property; and as used in this chapter the singular shall include the plural, and shall include an individual, a firm, an association, a corporation, a partnership and the lessees, trustees, agents, employees, servants and representatives of any such owner. Proof of the assessment of any real property, the subject of this chapter, to any person or legal entity on the official assessor’s rolls shall constitute prima facie evidence that such person or legal entity to whom such property is so assessed is the legal owner thereof. “Recyclable Material” means material which otherwise would become or be treated as MSW but which, by means of a process of collecting, sorting, cleansing, treating and reconstructing, may be returned to the economic mainstream in the form of finished or source material for new, reused or reconstituted products, which may be used in the marketplace. “Recyclable Materials” includes paper, books, magazines, cardboard, box board, plastic, metal, glass, and other similar materials authorized by the Town for collection by the Authorized Contractor.
"State" means the State of California.
"Town" means the Town of Paradise, a municipal corporation, and all the territory lying within the municipal boundaries of the Town as presently existing or as such boundaries may be modified during the term.
“Town Enforcement Officer” means the Town Manager, or their authorized designee(s) who is/are partially or wholly responsible for enforcing the ordinance. See also “Regional or County Agency Enforcement Officer”.
“Yard Waste” means tree trimmings, grass cuttings, leaves, branches, and similar organic materials, including vineyard clippings, sawdust, wooden chopsticks, and other clean wood items under 36 inches.
(Ord. No. 459, §§ 1, 2, 3-27-2007; Ord. 257, § 2 (part), 1995) 440
Created: 2022-05-20 13:57:13 [EST]
(Supp. No. 7-22, Update 1)