Agenda packet — Paradise City Council, November 7, 2022 (part 3 of 9)

3.13.2.2 State
California Relocation Act
The California Relocation Act requires state and local governments to provide relocation assistance and benefits to persons displaced as a result of projects undertaken by state or local governments that do not involve federal funds.

California Department of Housing and Community Development Home Investment Partnerships Program
The California Department of Housing and Community Development Home Investment Partnerships Program (HOME) was created to assist cities, counties, developers, and nonprofit Community Housing 462
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 284
Development Organizations to create and retain affordable housing. It provides grants to cities and counties and low-interest loans to developers. Eligible activities to receive the grant must benefit lowincome renters and owners.

3.13.2.3 Regional and Local
Town of Paradise General Plan
As discussed in the regulatory section of Land Use and Planning, The Town of Paradise General Plan (Town of Paradise and Quad Consultants 2008) was adopted by the Paradise Town Council on October 4, 1994. A discussion of amendments and can be found in Section 3.11.2.3 and supporting materials are in Appendix B Town of Paradise 1994 General Plan Resolution and Amendments. As previously noted, all amendments are assumed incorporated when referencing the Town of Paradise General Plan in this document. The Town of Paradise General Plan (Town of Paradise and Quad Consultants 2008) includes the following goals related to population and housing that are relevant to the Proposed Project:
 Goal HG-1: Encourage and facilitate the production of all housing types, from affordable workhorse housing to executive homes, to meet the Town’s share of regional housing needs consistent with the overall goals, objectives, and policies of the Paradise General Plan.  Goal HG-2: Improve and preserve safe, decent housing and neighborhoods for all Paradise residents.
 Goal LUG-2: Accommodate a rate of growth consistent with the physical and infrastructural limitations in Paradise.
 Objective LUO-2: Stimulate and accommodate commercial/industrial growth while maintaining the current quality of life.
 Objective LUO-4: Carefully manage and control population growth, while stimulating local economic growth.
 Goal LUG-13: Designate appropriate areas for high density residential use and for institutional and public uses in centralized and convenient locations.  Goal LUG-20: Develop a strong local economy, recognizing that this is a key element in solving service providers’ financial difficulties.
 Goal LUG-24: Encourage a sense of community in Paradise.

The Proposed Project will be held to the goals and policies in the Town of Paradise General Plan.

Butte County General Plan 2030
The Butte County General Plan 2030 (Butte County 2012) includes the following policies related to population and housing that are relevant to the Proposed Project:
 Policy H-P1.2: Focus development in the unincorporated areas of the spheres of influence of the cities to accommodate the County’s housing allocation.  Policy H-P5.1: Continue to promote housing opportunities for all persons regardless of age, race, religion, gender, marital status, national origin, disability, or other barriers that prevent choice in housing.
 Policy ED-P1.1: The County’s priority for future growth is creating sustainable jobs and providing a living wage to families to reduce poverty.
463
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 285
The Proposed Project will be held to the policies in the Butte County General Plan 2030.

Chico 2030 General Plan
The Chico 2030 General Plan (City of Chico 2017) includes the following pertinent goals related to population and housing that are relevant to the Proposed Project:
 Goal ED-1: Maintain and implement an Economic Development Strategy to enhance Chico’s long-term prosperity.
 Goal SUS-1: Balance the environment, economy and social equity, as defined in the General Plan, to create a sustainable Chico.
 Goal H1: Increase equal housing opportunities.
 Goal H2: Provide housing that is affordable to low incomes.

The Proposed Project will be held to the goals in the Chico 2030 General Plan.

3.13.3 Method of Analysis
This section describes the methods used to analyze population and housing characteristics within the study area.

3.13.3.1 CEQA Significance Criteria
For the purposes of this PEIR, the Proposed Project would result in a significant impact on population and housing if it would:
 Impact POP-1: Induce substantial unplanned population growth in an area, either directly (e.g., by proposing new homes and businesses) or indirectly (e.g., through extension of roads or other infrastructure)
 Impact POP-2: Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere

3.13.3.2 Approach to Analysis
Construction, Operation and Maintenance
Impacts on population and housing were identified qualitatively and quantitively based on the Proposed Project’s potential to induce substantial unplanned population growth or displace existing people or housing. Data was found via the DOF population and housing estimates report. The following tables were used:
 E-4 Population Estimates for Cities, Counties, and the State, 2011-2021 with 2010 Census Benchmark (DOF 2021a).
 E-5 Population and Housing Estimates for Cities, Counties, and the State – January 1, 2011- 2021 (DOF 2021b).
 E-8 Historical Population and Housing Estimates for Cities, Counties, and the State, 2000-2010 – Organized by Year (DOF 2012).

The DOF data was used over US Census Bureau American Community Survey estimates. According to the DOF (2021c), it conducted an annual housing survey that used several metrics to help determine 464
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 286
various housing characteristics, such as vacancy rate. These housing data were factored into the population estimates provided in each report above. This annual housing survey is conducted every year. Additionally, the DOF data was preferred because the DOF receives periodic population data updates from agencies such as CALFIRE and FEMA. American Community Survey methodology was not preferred because the American Community Survey uses estimates sampling, and it is assumed that American Community Survey data could not account for the 2018 Camp Fire, which is pertinent to the population and housing analysis.

Data found in BCAG’s Provisional Long-Term Regional Growth Forecasts 2018-2040 (BCAG 2019b) and the Post Camp Fire Regional Population and Transportation Study which was prepared for BCAG by Fehr and Peers (2021) were used for Town population and housing forecasts.

The analysis of environmental effects focuses on foreseeable changes to population and housing in the context of effects listed in Section 3.13.3.1, CEQA Significance Criteria. The analysis considers the Core Collection System, Export Pipeline System, and Extended Collection System, as appropriate, in the context of construction, operation, and maintenance.

3.13.4 Impact Analysis
This section describes the potential environmental impacts on population and housing as a result of implementation of the Proposed Project. It includes an analysis of the Proposed Project’s potential to induce population growth directly or indirectly, such as through the creation of jobs, or permanently displace housing and/or people.

3.13.4.1 Impact POP-1: Induce substantial unplanned population growth in an area, either directly (e.g., by proposing new homes and businesses) or indirectly (e.g., through extension of roads or other infrastructure) (Less than Significant Impact) Construction
Construction of the Core Collection System, Export Pipeline System, and Extended Collection System would generate new jobs within the study area. Section 2.5.1.3.1 Construction Crews and Equipment provides a table estimating crews for the Core Collection System and, given that the schedule is expedited, estimates how many of each crew type would be working at the same time, Section 2.5.2.3.1 provides similar estimates for the Export Pipeline System. Section 2.6 Proposed Schedule also shows construction for both components occurring at the same time. In total, more than 200 construction jobs could be generated, However, all construction jobs associated with the Proposed Project would be temporary, lasting for an estimated 2-year construction schedule (Section 2.6 Proposed Schedule).

Construction workers could be drawn from the existing workforce within Butte County; however, it is likely that some would be migrant workers from outside of the County that follow construction jobs from location to location, and there may be others that relocate to the Town for the work and decide to stay. Workers that become permanent residents would be part of the Town’s population recovery. Consequently, construction of the Proposed Project would not result in substantial or unplanned population growth and would not necessitate the construction of new roads, additional housing or business services that would be inconsistent with regrowth planned and presented in the Town of Paradise 2022-2030 Housing Element Update (Town of Paradise 2022a) and Town of Paradise General Plan (Town of Paradise and 465
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 287
Quad Consultants 2008). Therefore, construction of the Proposed Project would not induce substantial unplanned population growth in the study area, resulting in a less-than-significant impact.

Mitigation. No mitigation required.

Operation and Maintenance
The Proposed Project includes a Core Collection System, Export Pipeline System, and Extended Collection System to address the need for a municipal wastewater management solution. While the Proposed Project would not be the direct reason for any substantial housing unit development or population increases in Paradise, the Proposed Project would accommodate population increases within the Town limits in alignment with the objectives and policies set forth in the Town of Paradise 2022-2030 Housing Element Update (Town of Paradise 2022a) and Town of Paradise General Plan (Town of Paradise and Quad Consultants 2008). In fact, the intent of the Proposed Project is to induce population regrowth and repopulation toward pre-fire levels (Section 2.3 Project Need and Objectives).

However, as discussed further in Section 4.4 Growth Inducing Impacts, this population growth would still be limited, as it would be contained within the existing Town boundaries and would be controlled by the permits issued by the Town.

About 5–10 permanent employees would be required to serve the Proposed Project during operations and maintenance (Section 2.8 Proposed Operation and Maintenance). The permanent employees may be re-assigned from existing staff within the Town or may be additional new staff. The minimal increase in permanent jobs would not result in substantial or unplanned population growth and would not necessitate the construction of additional housing or business services beyond planned regrowth discussed above.

Although implementation of the Proposed Project would foster population growth, it is primarily regrowth that would be expected as part of the historic population levels in the Paradise area. Therefore, operation and maintenance of the Proposed Project would not induce substantial unplanned population growth in the study area, resulting in a less-than-significant impact.

Mitigation. No mitigation required.

3.13.4.2 Impact POP-2: Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere (No Impact) Construction, Operation, and Maintenance
The Proposed Project would not acquire or take any residential-zoned land in the area. Most of the work associated with the construction of the Core and Extended Collection Systems and the Export Pipeline System would be done within public ROW and would not cause displacement of existing residents or housing. Work that would occur on private parcels, including connecting properties to the new sewer system or installing the Export Pipeline System would be completed under easements and would not displace existing housing. Therefore, the Proposed Project would not displace substantial numbers of existing people or housing which would necessitate the construction of replacement housing. There would be no impact.

Mitigation. No mitigation required.
466
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 288

3.13.5 Impacts Summary
Table 3.13-8 summarizes the population and housing impacts of the Proposed Project.

Table 3.13-8. Population and Housing Impacts Summary
Impact
Level of
Significance
Before
Mitigation
Mitigation
Level of
Significance
with
Mitigation
Incorporated
Impact POP-1: Induce substantial unplanned population growth in an area, either directly (e.g., by proposing new homes and businesses) or indirectly (e.g., through extension of roads or other infrastructure)

LTS N/A LTS
Impact POP-2: Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere

NI N/A NI
Notes: LTS = Less than Significant Impact, NI = No Impact, N/A = Not Applicable, SI = Significant Impact, S/M = Significant Impact but Mitigable to a Less than Significant Level

3.13.6 References
Boghani, Priyanka. 2019. “Camp Fire: By the Numbers.” October 29. Accessed April 2021. https://www.pbs.org/wgbh/frontline/article/camp-fire-by-the-numbers/.

Butte County. 2012. Butte County General Plan 2030. Adopted October 26, 2010. Updated November 6, 2012. http://www.buttecounty.net/Portals/10/Planning/ButteCountyGeneralPlan2030_ May2018red.pdf?ver=2019-12-18-141822-357.

BCAG. 2019b. Provisional Long-Term Regional Growth Forecasts 2018-2040. September 2019. http://www.bcag.org/documents/demographics/pop_emp_projections/Growth_Forecasts_2018- 2040_draft_v2.pdf.

DOF. 2012. E-8 Historical Population and Housing Estimates for Cities, Counties, and the State, 2000– 2010. November 2012. Accessed June 2021. https://dof.ca.gov/forecasting/demographics/ estimates/estimates-e8-2000-2010/-.

DOF. 2021a. E-4 Population Estimates for Cities, Counties, and the State, 2011-2020, with 2010 Census Benchmark. May 2021. Accessed March 2022. https://dof.ca.gov/Forecasting/ Demographics/estimates/estimates-e4-2010-2020/.

DOF. 2021b. E-5 Population and Housing Estimates for Cities, Counties, and the State – January 1, 2011–2021. May 2021. Accessed March 2022. https://dof.ca.gov/forecasting/demographics/ estimates/estimates-e5-2010-2021/.

DOF. 2021c. Personal communication with Douglas Kuczynksi, California Department of Finance, on June 21, 2021.

City of Chico. 2017. Chico 2030 General Plan. Adopted April 2011. Amended March 2017. https://chico.ca.us/post/chico-2030-general-plan.
467
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 289
Fehr and Peers. 2021. Post Camp Fire Regional Population and Transportation Study. Prepared for Butte County Association of Governments. April 14, 2021. http://www.bcag.org/documents/ Camp%20Fire/Post-Camp-Fire-Study-Final-Report.pdf.

Finch, Michael II. 2019. “Research shows where former Paradise residents went after town was wiped out.” The Sacramento Bee. November 20. Accessed June 2021. https://www.sacbee.com/news/ california/fires/article237304364.html.

Town of Paradise. 2022a. Town of Paradise 2022-2030 Housing Element Update. HCD Revisions Draft. May 2022. https://www.townofparadise.com/sites/default/files/fileattachments/planning/ page/41461/compiled_he_cleanappendices_5-23-22.pdf.

Town of Paradise and Quad Consultants. 2008. Town of Paradise 1994 General Plan. Prepared for Town of Paradise Community Development Department. Amended January 2008. https://www.townofparadise.com/sites/default/files/fileattachments/planning/page/3251/townofp aradise-generalplan_1994.pdf.
468
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 290

3.14 Public Services
This section describes the environmental setting and regulatory framework for public services, and it identifies direct and indirect impacts of the Proposed Project during construction, and operation, and maintenance on public services. In particular, the public services analysis focuses on fire protection services, police protection services, schools, and libraries within the study area. For the purposes of this PEIR, the study area for public services refers to the areas within and directly adjacent to Paradise and areas of unincorporated Butte County and Chico where the proposed pipeline alignment runs.

Refer to Section 0, Recreation, for an analysis of the Proposed Project’s impacts on parks and recreation facilities.

3.14.1 Environmental Setting
This section describes the fire protection services, police protection services, schools, and libraries within the study area.

3.14.1.1 Fire Protection
Fire protection services in the study area are provided by the Butte County Fire Department (BCFD), Paradise Fire Department (PFD), and Chico Fire Department (CFD). The BCFD and PFD contract with the CALFIRE to provide fire protection services. Figure 3.14-1 provides an overview of the location of fire protection facilities within the study area.

Butte County Fire Department//California Department of Forestry and Fire Protection Since 1931, Butte County has contracted with CALFIRE to provide staffing to the BCFD through cooperative fire protection agreements (Butte County 2010). Under the terms of this agreement, Butte County funds CALFIRE professional command, firefighting, and administrative staff to operate the BCFD. Through this arrangement, CALFIRE and the BCFD function together as a fully consolidated fire protection agency and provide fire protection service to unincorporated Butte County.

BCFD/CALFIRE services include fire control for structural, vegetation, vehicular, and other unwanted fires; emergency medical services; technical rescue response; hazardous materials response; flood control assistance; fire prevention and public safety education; fire law enforcement/arson investigation; and vegetation management. In addition, BCFD/CALFIRE operates countywide dispatch services, coordinates major emergency response within the county, and provides training for career and volunteer fire fighters (Butte County 2010).

The BCFD/CALFIRE operates 20 fire stations throughout the entire Butte County (Butte County 2022a).

The closest BCFD/CALFIRE station to the Proposed Project is Station 44, which is located at 2334 Fair Street in Chico. Station 44 is located approximately 0.6 miles from the proposed pipeline alignment (Google Earth 2022). Station 44 houses one fire engine, which responded to 983 emergency incidents in 2019 (Butte County 2022b).

Paradise Fire Department/California Department of Forestry and Fire Protection The Town has contracted with CALFIRE to provide firefighting personnel to the PFD through a cooperative agreement (Town of Paradise 2022e). The PFD/CALFIRE responds to all emergencies including fires, emergency medical services, hazardous materials, and public assists within the 469
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 291
Paradise Town limits. The average response time within the Town is less than four minutes (Rick Manson, email communication, 2022)
The current minimum staffing for the PFD/CALFIRE is three personnel assigned to each engine (Town of Paradise 2022e). Typical engine staffing includes a captain, an engineer, and a firefighter. The PFD/CALFIRE is currently staffed with 19 employees, with four of those positions being grant funded through March 2023 (Rick Manson, email communication, 2022). 470
hdrinc.com
Final Program Environmental Impact Report 292
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
Figure 3.14-1. Fire Protection Facilities within the Study Area 471
hdrinc.com
Final Program Environmental Impact Report 293
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
The PFD/CALFIRE operates two fire stations (Town of Paradise 2022e). The closest PFD/CALFIRE station to the Proposed Project is Station 81, which is located at 767 Birch Street in Paradise. Station 81 is located within the boundaries of the Core Collection System (Google Earth 2022). Station 81 houses the administrative offices of the Fire Chief, Battalion Chief, Fire Prevention Inspector, and Administrative Assistant (Town of Paradise 2022e).

Chico Fire Department
The CFD, as known as the City of Chico Fire-Rescue, provides fire protection and emergency medical services in Chico. The CFD also provides first response to emergencies in the surrounding unincorporated Butte County through the Chico Urban Area Fire and Rescue Agreement. The CFD operates under the command of the Fire Chief and staffs 60 full-time personnel, 57 of which are uniformed positions (City of Chico 2022a). There are currently eight active volunteer firefighters in the CFD (City of Chico 2022a). In 2018, CFD units arrived on scene within 8 minutes and 20 seconds 90 percent of the time and met its benchmark response time of 6 minutes and 30 seconds 68.7 percent of the time (CFD 2018).

The Chico FD currently operates out of four stations (City of Chico 2022b). The closest CFD fire station to the Proposed Project is Station 4, which is located at 2405 Notre Dame Boulevard in Chico. Station 4 is located approximately 0.9 miles from the proposed pipeline alignment (Google Earth 2022). Station 4 houses a type 3 engine that is specifically designed to fight fires in the urban wildland interface (City of Chico 2022b).

3.14.1.2 Police Protection
Police protection and law enforcement services in the study area are provided by the Butte County Sheriff’s Office (BCSO), CHP, Paradise Police Department (PPD), and Chico Police Department (CPD).

Figure 3.14-2 provides an overview of the location of police protection facilities within the study area.

Butte County Sheriff’s Office
The BSCO serves all citizens of Butte County by providing a mix of public safety and public service functions, including coroner services, civil services, court security, and corrections. The BCSO maintains mutual aid agreements with the CHP and the municipal police departments of Oroville, Chico, Gridley, Biggs, and Paradise (Butte County 2010). The BSCO is responsible for operating the Butte County Jail, which is utilized by all law enforcement agencies within the county (Butte County 2010).

The BSCO has its main office in Oroville, with substations in Chico and Magalia (Butte County 2022c).

The closest BSCO station to the Proposed Project is the Chico substation, which is located at 479 East Park Avenue. The Chico substation is located approximately 0.4 miles from the proposed pipeline alignment (Google Earth 2022).

California Highway Patrol
The CHP provides law enforcement services, primarily traffic control, for State roads and roads in the unincorporated portions of the county. These services include traffic control, accident investigation, and licensing of vehicles. The CHP has a mutual aid agreement with the BCSO and will respond when requested by the Sheriff.
472
hdrinc.com
Final Program Environmental Impact Report 294
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
Figure 3.14-2. Police Protection Facilities within the Study Area 473
hdrinc.com
Final Program Environmental Impact Report 295
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
The CHP has two offices that serve Butte County: one in Chico and one in Oroville. The closest CHP office to the Proposed Project is the Chico office, which is located at 413 Southgate Avenue. The Chico office is located approximately 1 mile from the proposed pipeline alignment (Google Earth 2022). The Chico office is comprised of 29 sworn officers, 23 public safety dispatchers, and five civilian members (CHP 2022).

Paradise Police Department
The PPD has provided law enforcement services to the Town of Paradise since 1980, when it took law enforcement responsibility for the area from BCSO (Town of Paradise and Quad Consultants 2008).

The PPD includes five units: Administration, Patrol, Investigations, Communication/Records, and Animal Control. The PPD currently has 23 employees (Town of Paradise 2022f). The PPD’s station is located at 5595 Black Olive Drive in Paradise, which is located within the boundaries of the Core Collection System (Google Earth 2022).

Chico Police Department
The CPD provides law enforcement services to the City of Chico. If requested by the BCSO or the CHP, the CPD may provide assistance in the surrounding unincorporated areas on a case-by-case basis. The CPD is comprised of 168 employees, 108 of which are sworn officers (CPD 2021).

Additionally, the CPD is served by 100 police volunteers (CPD 2021). CPD personnel are organized into two divisions: Operations and Support. The Operation Division comprises of the Patrol Section and Animal Shelter/Control Section. The Support Division comprises of the Criminal Investigations Section, Communications and Support Operations Section, and Administration Section.

The CPD headquarters are located at 1460 Humboldt Road in Chico, which is located approximately

1.9 miles from the proposed pipeline alignment (Google Earth 2022).

3.14.1.3 Schools
Within Butte County, 14 local school districts provide elementary and secondary education (Butte County 2010). The study area is served by the Paradise Unified School District (PUSD) and Chico Unified School District (CUSD). Figure 3.14-3 provides an overview of the location of schools within the study area.

Paradise Unified School District
PUSD serves students in Paradise and Magalia. PUSD operates seven schools: three elementary schools (transitional kindergarten through grade six), one junior high school (grades seven and eight), two high schools (grades nine through 12), and one online learning academy (grades nine through 12) (PUSD 2022). PUSD enrollment in 2018-19 was 3,401 (PUSD 2021). Enrollment at PUSD has declined since then due to the 2018 Camp Fire. As of November 2021, enrollment at PUSD is 1,484 (PUSD 2021).

The closest PUSD schools to the Proposed Project are Paradise Junior High School, which is located at 5657 Recreation Drive, and Paradise High School, which is located at 5911 Maxwell Drive. The Paradise Junior High School and Paradise High School are located within the boundaries of the Core Collection System (Google Earth 2022).
474
hdrinc.com
Final Program Environmental Impact Report 296
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
Figure 3.14-3. Schools within the Study Area
475
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 297
Chico Unified School District
The City of Chico is served by the CUSD, which serves students from preschool through grade 12.

CUSD encompasses 23 schools: 12 elementary schools, three junior high schools, two high schools, one continuation school, one community day school, one opportunity school one independent study school one special services school, one online learning academy, and four preschool programs (CUSD 2022). Total enrollment across CUSD schools in 2018-19 was 11,854 (CUSD 2019). After the 2018 Camp Fire, CUSD absorbed 229 additional students displaced from Paradise (CUSD 2019).

The closest CUSD school to the Proposed Project is the Chapman Elementary School, which is located at 1071 East 16th Street in Chico. The Chapman Elementary School is located approximately 1.2 miles from the proposed pipeline alignment (Google Earth 2022).

3.14.1.4 Libraries
The study area is served by the Butte County Library.

Butte County Library
The Butte County Library provides public library services in the county. The Butte County Library provides library services to all county residents through a consolidated operation from its headquarters in Oroville and branches in Biggs, Chico, Durham, Gridley and Paradise (Butte County 2022d). The closest Butte County Library branch to the Proposed Project is the Paradise branch, which is located at 5922 Clark Road. The Paradise branch is located within the boundaries of the Core Collection System (Google Earth 2022).

3.14.2 Regulatory Framework
This section summarizes the federal, state, regional, and local laws, regulations, policies, and plans relevant to evaluation of the Proposed Project’s impacts on public services. Additional information on the relevant regulations, laws, and plans is provided in Appendix C, Regulatory Framework.

3.14.2.1 Federal
No identified federal laws, regulations, orders, policies, or plans regarding public services are relevant to the Proposed Project.

3.14.2.2 State
California Occupational Safety and Health Administration In accordance with the California Code of Regulations, Title 8, Sections 1270 “Fire Prevention” and 6773 “Fire Protection and Fire Fighting Equipment,” the California Occupational Safety and Health Administration has established minimum standards for fire suppression and emergency medical services. The standards include guidelines on the handling of highly combustible materials, fire hose sizing requirements, restrictions on the use of compressed air, access roads, and the testing, maintenance, and use of all firefighting and emergency medical equipment.

The Proposed Project will be held to the standards established by the California Occupational Safety and Health Administration.
476
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 298
Uniform Fire Code
The Uniform Fire Code (California Code of Regulations, Title 24, Part 9) contains regulations relating to construction, maintenance, and use of buildings. Topics addressed in the code include fire department access, fire hydrants, automatic sprinkler systems, fire alarm systems, fire and explosion hazards safety, hazardous materials storage and use, provisions intended to protect and assist fire responders, industrial processes, and many other general and specialized fire-safety requirements for new and existing buildings and the surrounding premises. The Uniform Fire Code also contains specialized technical regulations related to fire and life safety.

The Proposed Project will be held to the regulations set forth in the Uniform Fire Code.

California Health and Safety Code
State fire regulations are set forth in Sections 13000 et seq. of the California Health and Safety Code.

Regulations address building standards, fire protection and notification systems, fire protection devices such as extinguishers, smoke alarms, high-rise buildings, childcare facility standards, and fire suppression training, among other topics.

The Proposed Project will be held to the regulations set forth in the Health and Safety Code.

3.14.2.3 Regional and Local
Town of Paradise General Plan
The Town of Paradise General Plan (Town of Paradise and Quad Consultants 2008) includes the following policies related to public services that are relevant to the Proposed Project:
 Policy LUP-12: The character of future development should be compatible with the Town’s service delivery abilities and will not result in service level declines.  Policy LUP-13: The Town will attempt to assure that the rate and character of growth is commensurate with, or does not exceed the current levels of public services, and will attempt to assure that municipal services can be provided to areas planned for annexation and development.
 Policy LUP-14: Growth and land use development should be linked to the availability of public services and facilities, and to the degree of overall infrastructure and environmental constraints affecting property in the Town.
 Policy LUP-20: New land use development will not cause the levels of police and fire protection to fall below the service levels established by this plan.

The Proposed Project will be held to the policies in the Town of Paradise General Plan.

Butte County General Plan 2030
The Butte County General Plan 2030 (Butte County 2012) includes the following policies related to public services that are relevant to the Proposed Project:
 Policy PUB-P4.1: Review of development proposals will be coordinated with school districts to determine and plan for capacity issues over time.
 Policy PUB-P4.2: Review of development proposals will be coordinated with school districts regarding the location and design of new schools.
477
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 299
 Policy PUB-P4.4: Infrastructure development projects will be coordinated to minimize the cost to the public of building needed schools.
 Policy PUB-P4.5: Information on projected population growth and development patterns will be provided to school districts to facilitate adequate school facilities.  Policy PUB-P4.7: New development projects will be approved only if the County and the applicable School District finds that existing or planned schools will be adequate to serve it.

The Proposed Project will be held to the policies in the Butte County General Plan 2030.

Chico 2030 General Plan
The Chico 2030 General Plan (City of Chico 2017) includes the following policies related to public services that are relevant to the Proposed Project.
 Policy S-4.1, Fire Safety Staffing: Maintain adequate fire suppression and prevention staffing levels.
 Policy S-4.2, Interagency Coordination: Continue to maintain interagency relationships to maximize fire protection services and support programs that reduce fire hazards.  Policy S-5.1, Police Services: Continue to provide fundamental police services based upon rapid response to emergencies and response, control and intervention in conduct that threatens life and property.
 Policy S-5.4, Collaboration and Coordination: Maintain strong relationships with local and state law enforcement agencies and participate in joint disaster preparedness planning.  Policy PPFS-3.1, CUSD Coordination: Support Chico Unified School District’s efforts to provide school sites and facilities that meet the educational needs of the community.

The Proposed Project will be held to the policies in the Chico 2030 General Plan.

3.14.3 Method of Analysis
This section describes the methods used to analyze impact on public services within the study area.

3.14.3.1 CEQA Significance Criteria
For the purposes of this PEIR, the Proposed Project would result in a significant impact on public services if it would:
 Impact PS-1: Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically 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 following public services:
(a) Fire Protection
(b) Police Protection
(c) Schools
(d) Other Public Facilities
478
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 300

3.14.3.2 Approach to Analysis
Construction, Operation, and Maintenance
Impacts on public services were identified qualitatively based on the Proposed Project’s potential to cause increased use or expansion of available public facilities, such as fire protection facilities, police protection facilities, schools, and libraries. For the purposes of this analysis, information was collected on public services using the following sources:
 Butte County General Plan 2030 EIR (Butte County 2010)  Town of Paradise website (Town of Paradise 2022e, 2022f)  Butte County website (Butte County 2022a, 2022b, 2022c, 2022d)  City of Chico website (City of Chico 2022a, 2022b)
 CFD Bi-Annual Report (CFD 2018)
 CHP website (CHP 2022)
 CPD Policy Manual (CPD 2021)
 PUSD website and fiscal year 2021-22 budget (PUSD 2021, 2022)  CUSD website and facilities master plan (CUSD 2019, 2022) The analysis of environmental effects focuses on foreseeable changes to public services in the context of effects listed in Section 3.14.3.1, CEQA Significance Criteria. The analysis considers the Core Collection System, Export Pipeline System, and Extended Collection System, as appropriate, in the context of construction, operation, and maintenance.

The following methods were used to evaluate the potential impacts from construction, operation, and maintenance of the Proposed Project on public services:
 Use of GIS data to locate the existing public facilities (i.e., fire protection facilities, police protection facilities, schools, and libraries) within the study area.  Use of Google Earth and GIS data to measure the distance of public facilities from the Proposed Project.
 Analysis of construction methods, ROW, and staging areas.  Analysis of the Project’s consistency with the requirements of all plans, policies, and regulations listed in Section 0, Regulatory Framework.

3.14.4 Impact Analysis
This section includes an analysis of the Proposed Project’s potential to result in adverse physical impacts associated with the provision of new or physically altered governmental facilities; or result in the need for new or physically altered governmental facilities in order to maintain acceptable service ratios, response times or other performance objectives.

3.14.4.1 Impact PS-1: Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, 479
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 301
response times or other performance objectives for any of the following public services:
(a) Fire Protection (Less than Significant Impact with Mitigation Incorporated) As presented in Section 3.14.1, Environmental Setting, fire protection services in the study area are provided by the BCFD/CALFIRE, PFD/CALFIRE, and CFD. The nearest fire station to the Proposed Project is PFD/CALFIRE’s Station 8, which is located at 767 Birch Street in Paradise, within the boundaries of the Core Collection System.

Construction
As described in Section 0, Population and Housing, construction workers would likely be drawn from the existing workforce within Butte County but would also likely draw from outside of the Town and County. It is anticipated that some of the construction workers might choose to permanently relocate to the Town, which would be in support of the Town’s planned regrowth. Fire protection services within the Town were sized to meet the demand for services by the Town pre-fire and would be anticipated to rebuild to previous conditions on par with the returning population. Growth beyond pre-fire conditions would be consistent with the Town of Paradise General Plan assumptions for future growth (Town of Paradise and Quad Consultants 2008).

Although PFD/CALFIRE’s Station 8 would not be directly impacted during construction, impacts may occur related to emergency vehicle access that may be impeded during construction due to nearby temporary lane closures and movement of construction equipment on local roads. This is considered a potentially significant impact.

Mitigation. To minimize potentially significant impacts related to emergency vehicle access during construction of the Proposed Project to a less than significant level, mitigation measure MM-HAZ-6 will be implemented.

MM-HAZ-6: Traffic Management Plan (see section 3.9, Hazards and Hazardous Materials, for description)
Significance after Mitigation. With the implementation of mitigation measure MM-HAZ-6, impacts related to emergency vehicle access during construction would be less than significant.

Operation and Maintenance
The Proposed Project would be designed and constructed in compliance with all applicable fire codes and public safety standards. During operation and maintenance, the Proposed Project would not result in any permanent impacts to the fire stations within the study area. Increases in housing and businesses that would be supported by operation of the Proposed Project would primarily consist of regrowth and repopulation toward pre-fire levels. As mentioned above, growth beyond pre-fire conditions would be in alignment with the Town of Paradise General Plan assumptions for future growth (Town of Paradise and Quad Consultants 2008). Therefore, operation and maintenance of the Proposed Project would have a less-than-significant impact on fire protection services.

Mitigation. No mitigation required.
480
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 302
(b) Police Protection (Less than Significant Impact with Mitigation Incorporated) As presented in Section 3.14.1, Environmental Setting, police protection services in the study area are provided by the BCSO, CHP, PPD, and CPD. The nearest police station to the Proposed Project is PPD’s station, which is located at 5595 Black Olive Drive in Paradise, within the boundaries of the Core Collection System.

Construction
As described in Section 0, Population and Housing, construction workers would likely be drawn from the existing workforce within Butte County but would also likely draw from outside of the Town and County. It is anticipated that some of the construction workers might choose to permanently relocate to the Town, which would be in support of the Town’s planned regrowth. Police protection services within the Town were sized to meet the demand for services by the Town pre-fire and would be anticipated to rebuild to previous conditions on par with the returning population. Growth beyond pre-fire conditions would be consistent with the Town of Paradise General Plan assumptions for future growth (Town of Paradise and Quad Consultants 2008).

Although PPD’s station would not be directly impacted during construction, impacts may occur related to emergency vehicle access that may be impeded during construction due to nearby temporary lane closures and movement of construction equipment on local roads. This is considered a potentially significant impact.

MM-HAZ-6: Traffic Management Plan (see Section 0, Hazards and Hazardous Materials, for description)
Significance after Mitigation. With the implementation of mitigation measure MM-HAZ-6, impacts related to emergency vehicle access during construction would be less than significant.

Operation and Maintenance
The Proposed Project would be designed and constructed in compliance with all applicable public safety standards. During operation and maintenance, the Proposed Project would not result in any permanent impacts to the police stations within the study area. Increases in housing and businesses that would be supported by operation of the Proposed Project would primarily consist of regrowth and repopulation toward pre-fire levels. As mentioned above, growth beyond pre-fire conditions would be in alignment with the Town of Paradise General Plan assumptions for future growth (Town of Paradise and Quad Consultants 2008). Therefore, operation and maintenance of the Proposed Project would have a less-than-significant impact on police protection services.

Mitigation. No mitigation required.
(c) Schools (Less than Significant Impact with Mitigation Incorporated) 481
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 303
As presented in Section 3.14.1, Environmental Setting, the study area is served by the PUSD and CUSD. The nearest schools to the Proposed Project are PUSD’s schools: Paradise Junior High School (located at 5657 Recreation Drive) and Paradise High School (located at 5911 Maxwell Drive). Both schools are located within the boundaries of the Core Collection System.

Construction
As described in Section 0, Population and Housing, construction workers would likely be drawn from the existing workforce within Butte County but would also likely draw from outside of the Town and County. It is anticipated that some of the construction workers might choose to permanently relocate to the Town, which would be in support of the Town’s planned regrowth. The school district within the Town was sized to meet the demand for services by the Town pre-fire and would be anticipated to rebuild to previous conditions on par with the returning population. Growth beyond pre-fire conditions would be consistent with the Town of Paradise General Plan assumptions for future growth (Town of Paradise and Quad Consultants 2008).

Although the Paradise Junior High School and Paradise High School would not be directly impacted during construction, impacts may occur related to emergency vehicle access to the schools due to temporary lane closures and movement of construction equipment on local roads. This is considered a potentially significant impact.

MM-HAZ-6: Traffic Management Plan (see Section 0, Hazards and Hazardous Materials for description)
Significance after Mitigation. With the implementation of mitigation measure MM-HAZ-6, impacts related to emergency vehicle access to schools during construction would be less than significant.

Operation and Maintenance
During operation and maintenance, the Proposed Project would not result in any permanent impacts to the schools within the study area. Increases in population that would be supported by operation of the Proposed Project would primarily consist of regrowth and repopulation toward pre-fire levels. As mentioned above, growth beyond pre-fire conditions would be in alignment with the Town of Paradise General Plan assumptions for future growth (Town of Paradise and Quad Consultants 2008).

Therefore, operation and maintenance of the Proposed Project would have a less-than-significant impact on schools.

Mitigation. No mitigation required.
(d) Other Public Facilities (Less than Significant Impact with Mitigation Incorporated) As presented in Section 3.14.1, Environmental Setting, library services in the study area are provided by the Butte County Library. The nearest Butte County Library branch to the Proposed Project is the Paradise branch, which is located at 5922 Clark Road, within the boundaries of the Core Collection System.
482
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 304
Construction
As described in Section 0, Population and Housing, construction workers would likely be drawn from the existing workforce within Butte County but would also likely draw from outside of the Town and County. It is anticipated that some of the construction workers might choose to permanently relocate to the Town, which would be in support of the Town’s planned regrowth. Other public facilities within the Town were able to meet the demand for services by the Town pre-fire and would be anticipated to rebuild to previous conditions on par with the returning population. Growth beyond pre-fire conditions would be consistent with the Town of Paradise General Plan assumptions for future growth (Town of Paradise and Quad Consultants 2008).

Although the Butte County Library’s Paradise Branch would not be directly impacted during construction, impacts may occur related to emergency vehicle access to the library due to temporary lane closures and movement of construction equipment on local roads. This is considered a potentially significant impact.

MM-HAZ-6: Traffic Management Plan (see Section 0, Hazards and Hazardous Materials, for description)
Significance after Mitigation. With the implementation of mitigation measure MM-HAZ-6, impacts related to emergency vehicle access to other public facilities, such as libraries, during construction would be less than significant.

Operation and Maintenance
During operation and maintenance, the Proposed Project would not result in any permanent impacts to other public facilities, such as libraries, within the study area. Increases in population that would be supported by operation of the Proposed Project would primarily consist of regrowth and repopulation toward pre-fire levels. As mentioned above, growth beyond pre-fire conditions would be in alignment with the Town of Paradise General Plan assumptions for future growth (Town of Paradise and Quad Consultants 2008). Therefore, operation and maintenance of the Proposed Project would have a lessthan-significant impact on other public facilities.

Mitigation. No mitigation required.

3.14.5 Impacts Summary
Table 3.14-1 summarizes the public services impacts of the Proposed Project. 483
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 305
Table 3.14-1. Public Services Impacts Summary
Impact
Level of
Significance
Before
Mitigation
Mitigation
Level of
Significance
with Mitigation
Incorporated
Impact PS-1(a): Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically 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 following public services: Fire Protection
SI MM-HAZ-6 S/M
Impact PS-1(b): Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically 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 following public services: Police Protection
SI MM-HAZ-6 S/M
Impact PS-1(c): Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically 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 following public services: Schools SI MM-HAZ-6 S/M
Impact PS-1(d): Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically 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 following public services: Other Public Facilities
SI MM-HAZ-6 S/M
Notes: LTS = Less than Significant Impact, NI = No Impact, N/A = Not Applicable, SI = Significant Impact, S/M = Significant Impact but Mitigable to a Less than Significant Level

3.14.6 References
Butte County. 2010. Butte County General Plan 2030 Draft EIR. April 8, 2010. https://www.buttecounty.net/Portals/10/Docs/GP2030/ButteCountyGP_PublicReview_ EIR.pdf?ver=2019-07-25-160952-113.

Butte County. 2022a. “Fire Stations.” Accessed March 15, 2022. https://www.buttecounty.net/fire/ FireFacilities/FireStations#Contact-Fire-Dept-61.

Butte County. 2022b. “Station 44.” Accessed March 15, 2022. https://www.buttecounty.net/fire/ FireFacilities/FireStations/Station44.
484
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 306
Butte County. 2022c. “Butte County Sheriff’s Office.” Accessed March 15, 2022. https://www.buttecounty.net/sheriffcoroner/.

Butte County. 2022d. “About the library.” Accessed March 16, 2022. https://www.buttecounty.net/ bclibrary/aboutthelibrary.

California Highway Patrol (CHP). 2022. “(241) Chico.” Accessed March 16, 2022. https://www.chp.ca.gov/find-an-office/valley-division/offices/(241)-chico.

Chico Fire Department (CFD). 2018. Bi-Annual Report. July 2018. https://chico.ca.us/sites/main/files/ file-attachments/bi-annualreportjan-june2018finalwgoodlink.pdf?1577086381.

Chico Police Department (CPD). 2021. Chico Police Department Policy Manual. June 2021. https://chico.ca.us/sites/main/files/file-attachments/chico_pd_ca_policy_ manual.pdf?1627430674.

Chico Unified School District (CUSD). 2019. 2019 Facilities Master Plan Update. Accessed March 29, 2022. http://www.chicousd.org/documents/Business%20Services/Master_Plan_Docs/ Chico%20Booklet%20-%20update%202019v2%20Print%20091120.pdf.

CUSD. 2022. “Our District.” Accessed March 29, 2022. http://www.chicousd.org/Our-District/index.html.

City of Chico. 2017. Chico 2030 General Plan. Adopted April 2011. Amended March 2017. https://chico.ca.us/post/chico-2030-general-plan.

City of Chico. 2022a. “Chico Fire-Rescue Operations.” Accessed March 15, 2022. https://chico.ca.us/ operations.

City of Chico. 2022b. “Fire Stations and Apparatus.” Accessed March 15, 2022. https://chico.ca.us/post/ fire-stations-and-apparatus.

Google Earth. 2022. Aerial imagery and street view of the study area. Accessed March 20, 2022. https://earth.google.com/web/.

Manson, Rick. 2022. Email communication with Rick Manson, Battalion Chief, Town of Paradise on March 16, 2022.

Paradise Unified School District (PUSD). 2021. Fiscal Year 2021-22 First Interim Budget. December 2021. Accessed March 17, 2022. https://www.pusdk12.org/documents/Financial/PUSD-FY2021-22-1I-Budget.pdf.

PUSD. 2022. “Schools/Programs.” Accessed March 17, 2022. https://www.pusdk12.org/ SchoolsPrograms/index.html.

Town of Paradise. 2022e. “Fire Department Operations.” Accessed March 15, 2022. https://www.townofparadise.com/fire/page/operations.
485
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 307
Town of Paradise. 2022f. “Police Department About.” Accessed March 16, 2022. https://www.townofparadise.com/police/page/about.

Town of Paradise and Quad Consultants. 2008. Town of Paradise 1994 General Plan. Prepared for Town of Paradise Community Development Department. Amended January 2008. https://www.townofparadise.com/sites/default/files/fileattachments/planning/page/3251/townofp aradise-generalplan_1994.pdf.
486
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 308

3.15 Recreation
This section describes the environmental setting and regulatory framework for recreational activities in the study area, including land and water based recreational activities such as hiking, camping, picnicking, fishing, wildlife viewing, bicycling, and powered and non-powered boating. This section also identifies direct and indirect impacts of the Proposed Project during construction, operation, and maintenance on recreational facilities. The study area for recreation includes parks, trails, and other recreational facilities in Butte County because recreation is managed on a regional level; however, particular focus was given to those recreational facilities within a 2-mile radius of the Proposed Project.

A 2-mile radius was chosen to consider other recreational facilities available for use in the event of disturbance to recreation from the Proposed Project and was determined to be a reasonable distance to travel for alternative recreation options considering travel time and convenience for the local public.

3.15.1 Environmental Setting
Recreational facilities within a 2-mile radius of the study area are presented in Table 3.15-1 and shown in Figure 3.15-1. As shown in Figure 3.15-1, recreational zonings are adjacent to the ROW where the Core Collection System, Extended Collection System, and Export Pipeline System would be constructed. Within the Town, The Terry Ashe Recreation Center and Paradise Community Park (also referred to as Paradise Park) adjoin the Core Collection System construction footprint. The Tuscan Ridge Club adjoins the Export Pipeline System along Skyway.

3.15.1.1 Recreation and Park Districts
There are 618 acres of parkland in unincorporated Butte County, which serves a population of approximately 83,900 people. The five Butte County municipalities (Chico, Paradise, Oroville, Briggs, and Gridley) and five recreation and park districts maintain many of the parks in Butte County. The five recreation and park districts include Chico Area Recreation and Park District (CARD), Durham Recreation and Park District, Feather River Recreation and Park District, Paradise Recreation and Park District (PRPD), and Richvale Recreation and Park District. These recreation and park districts encompass most of Butte County’s land area and operate as independent districts, which means that the districts are governed by a board of directors elected by voters in that district (Butte County 2012).

Other agencies and municipalities with jurisdiction over the parks and recreational facilities within 10 miles of the study area include California Department of Parks and Recreation, City of Sacramento, and Glenn County.
487
hdrinc.com
Final Program Environmental Impact Report 308
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
Table 3.15-1. Parks and Recreation Centers within 2 miles of the Study Area Facility Name Distance and Direction to Study Area Jurisdiction or Owner Features Activities/Uses Baroni Park 1.75 miles northeast CARD 7.3-acre neighborhood park including a multi-use open turf play field, playground, basketball court, walking path, picnic tables, and practice disc golf baskets.

Playground, sports and recreation, walking, jogging, picnicking Dorothy F. Johnson Center

1.30 miles northwest CARD 6,375-square foot facility including an indoor gym, computer center, meeting rooms, toddler classrooms, office space, and kitchen.

Recreational programming and facility rentals
Billie Park 0.70 miles northeast PRPD Redwood grove, the Counselor’s Circle, and group barbeque area.

Park and outdoor event space
The Terry Ashe Recreation Center
Adjoining PRPD Recreation center including a gazebo, large room, kitchen, dance floor, sound system, and lighting.

Recreation and events center
Paradise Park Adjoining Town of
Paradise
Accessible playground, splash pad, beach volleyball courts, community stage, and dog parks.

Accessible playground, volleyball, dog park, community stage Paradise Aquatic Park (Paul Bryne Aquatic Park)

0.05 mile southeast PRPD Kid’s fishing pond, playground, family picnic area, arbor, public pool, rotary grove picnic area for up to 150 people, and sand volleyball court.

General recreation, swimming and barbeque area
Butte Creek Country Club

1.31 mile south Private owner 18-hole golf course, driving range, putting green, and restaurant.

Golf course
Tuscan Ridge Club Adjoining Semi-private
owner
18-hole golf course Golf course
Lava Creek Golf Course

0.03 mile southeast Public
(Paradise)
9-hole and 18-basket disc golf course. Golf course
Lassen National Forest

1.11 mile northeast USDA Forest
Service
Campgrounds, RV dump stations, day use areas, trails, picnic areas, and lookout areas.

Camping, picnicking, hiking, kayaking, fishing, RVing
Source: Butte County 2022e; Butte Creek Country Club 2022; USDA Forest Service 2022; CARD 2022; PRPD 2021; Golf Pass 2022 488
hdrinc.com
Final Program Environmental Impact Report 309
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
Figure 3.15-1. Recreation in the Study Area
489
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 310
The majority of recreational resources within a 2-mile radius of the study area are managed by private owners, CARD and PRPD. CARD provides recreation opportunities to the greater Chico community and maintains several parks. CARD is in the northern portion of the Sacramento River Valley, approximately 15 miles east of the Sacramento River and 90 miles north of Sacramento. The boundaries of CARD encompass approximately 225 square miles and extend from the Butte-Tehama County line on the north to the intersection of Dayton Road and Chico Street on the south; and from Muir Avenue on the west to approximately the east side of Upper Bidwell Park. Parks maintained by CARD include facilities such as playgrounds, softball fields, baseball fields, soccer fields, basketball and tennis courts, and gentle walking trails (CARD 2021).

PRPD is an independent special district that serves more than 50,000 people in Northern California’s Sierra Nevada foothills. PRPD covers approximately 165 square miles and encompasses the Paradise, Paradise Pines, Butte Creek Canyon, and Concow areas. PRPD maintains approximately 358 acres of natural open space and 73 acres of developed park land. Park facilities maintained by PRPD include swimming pools, a fishing pond, play fields, horse arena, archery range, walking trails, ropes course, tennis courts, playgrounds, picnic areas, open use areas, and a recreation center (PRPD 2021).

3.15.1.2 Water-Based Recreation
The study area is located within the California Department of Parks and Recreation Northern Buttes District. The west branch of the Feather River, located east of the study area, is connected to Lake Oroville State Recreation Area, which is approximately 1.27 miles southeast of the Proposed Project(see Figure 3.15-1). Recreational facilities in the west branch of the Feather River include Nelson Bar, Lime Saddle Campground, and Lake Oroville Lime Saddle Marina. Lime Saddle Campground consists of 44 car/tent campsites and 16 RV campsites with hook-ups. The campground also features showers, several gray water sumps, and an RV dump station. The Lime Saddle Day Use Area and Boat Ramp features a picnic area and boat ramp with approximately 367 parking spaces. The Lake Oroville Lime Saddle Marina offers houseboat rentals, watercraft rentals, and camping (DWR 2021). The features, activities and uses of Lake Oroville State Recreation Area are summarized in Error! Not a valid bookmark self-reference..

Table 3.15-2. Water-Based Recreation within 2 miles of the Study Area Facility Name
Distance and
Direction to
Study Area
Jurisdiction
or Owner Features Activities/Uses
Lake Oroville 1.27 miles California Bidwell Marina, Bidwell Canyon Sail and power boating, water State southeast Department Campground, Lime Saddle skiing, camping, boat-in Recreation of Parks and Campground, Lime Saddle Marina, camping, floating campsites, Area Recreation Lime Saddle Day Use/Lake Oroville horse camping, fishing, biking, Marina, Loafer Creek Campground, hiking, horseback riding, boating ramps and rentals, overnight picnicking, scuba diving, facilities, bike trails, hiking trails, snorkeling, swimming, nature horseback riding trails, picnic areas, and wildlife viewing, museums, learning/visitor center, beach area,
restrooms, showers, campsites, RV
family programs
sites and hookups, museums.

Source: California Department of Parks and Recreation 2022; DWR 2021 490
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 311

3.15.1.3 Bike and Recreational Trails in Butte County
Butte County does not have a formal or organized system of trails; however, federal and state agencies and park and recreation districts maintain a number of developed recreational trails in the county.

Recreational trails in Butte County are provided in Table 3.15-3. Butte County also operates a system of multi-use trails and Class I, II, and III bike routes. Within the study area there is a bike trail along Midway. Hegan Lane is also considered a bicycle-friendly road.

Table 3.15-3. Recreational Trails within 2 miles of the Study Area Trail Description
Comanche Creek Greenway The greenway is located approximately 0.34 mile west of the study area. The greenway is owned by the City of Chico and is located at the intersection of Hegan Lane and Midway.

Comanche Creek Greenway consists of 20 acres along Comanche Creek between Midway and the Union Pacific Railroad line. Currently, the land is undeveloped and public access to the site is restricted.

Chico Recreation and Park District
Trail System
The CRPD manages a system of trails that serve the Chico area.

Yellowstone Kelly Heritage Trailway The Town of Paradise owns and maintains a five-mile Class I pathway which primarily parallels Skyway between Neal Road and Pentz Road. This trailway is open to pedestrians and bicyclists alike.

Source: Butte County 2012

3.15.2 Regulatory Framework
This section summarizes the federal, state, regional, and local laws, regulations, policies, and plans relevant to evaluation of the Proposed Project’s impacts on recreation. Additional information on the relevant regulations, laws, and plans is provided in Appendix C, Regulatory Framework.

3.15.2.1 Federal
No identified federal laws, regulations, orders, policies, or plans regarding recreation are relevant to the Proposed Project.

3.15.2.2 State
California Department of Parks and Recreation Rules and Regulations The California Department of Parks and Recreation has established rules and regulations to protect park areas for the enjoyment of future generations and to keep park visitors safe. Topics covered in the rules and regulations include protection of natural scenery, plants and animal life; loaded firearms and hunting; dead and down wood; fires; animals; noise (engine driven electric generators); all vehicle travel; campsite use; refuse; smoking; drones; and cleanup responsibilities. Recreation within the study area is under the jurisdiction of the California Department of Parks and Recreation and is therefore subject to these regulations.

3.15.2.3 Regional and Local
Vegetative Fuels Management Plan
The Final Vegetative Fuels Management Plan for Parks, Greenways, Preserves, and Open Spaces (City of Chico Parks Department 2021) is intended to protect lives and property and enhance the 491
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 312
natural resources in Chico and covers all land owned and managed by the City of Chico, including parks, greenways, and open spaces. A key component of the plan is the identification of high fire hazard areas in greatest need of treatment, description of how fires can be managed, and development of policies and actions focused on reducing harmful impacts of wildfire in the community (City of Chico Parks Department 2021).

The Proposed Project will be subject to compliance with the Vegetative Fuels Management Plan for any work within applicable recreational areas of Chico.

Butte County Bikeway Master Plan
The 2011 Butte County Bikeway Master Plan (Butte County 2011) updates the Countywide Bikeway Master Plan originally adopted in 1998. The plan is intended to address safety and connectivity between the local communities and within rural areas of Butte County. The plan will also assist Butte County in its efforts to safely and equitably provide contiguous bicycle facilities in the future and implement roadway projects that are bicycle friendly throughout the unincorporated areas. The Bikeway Master Plan encompasses bikeways that are within the study area.

The Proposed Project will be held to the standards in this plan.

Town of Paradise General Plan
The Town of Paradise General Plan (Town of Paradise and Quad Consultants 2008) does not include any recreational goals or policies that are relevant to the Proposed Project.

Butte County General Plan 2030
The Butte County General Plan 2030 (Butte County 2012) includes the following policies related to recreation that are relevant to the Proposed Project:
 Policy PUB-P6.1: Review of development proposals shall be coordinated with public agencies in order to designate sites for new parks and recreation facilities.  Policy PUB-P8.7: New development projects should incorporate multi-use trails and connections to existing trail networks.

The Proposed Project will be held to the policies in the Butte County General Plan 2030.

Chico 2030 General Plan
The Chico 2030 General Plan (City of Chico 2017) does not include any recreational goals or policies that are relevant to the Proposed Project.

3.15.3 Method of Analysis
This section describes the methods used to analyze recreation within the study area.

3.15.3.1 CEQA Significance Criteria
For the purposes of this PEIR, the Proposed Project would result in a significant impact on recreation if it would:
492
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 313
 Impact REC-1: 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
 Impact REC-2: Include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment

3.15.3.2 Approach to Analysis
Construction, Operation and Maintenance
Impacts on recreation were identified qualitatively based on the Proposed Project’s potential to cause increased use or expansion of available recreation facilities to the extent at which substantial physical deterioration could occur.

For the purposes of this analysis, information was collected on recreation facilities using the following sources:
 CARD website (CARD 2021)
 PRPD website (PRPD 2021)
 California Department of Parks and Recreation website (California Department of Parks and Recreation 2022)
 City of Chico website (City of Chico 2022c)
 Butte County General Plan 2030 (Butte County 2012)
The analysis of environmental effects focuses on foreseeable changes to recreation facilities in the context of effects listed in Section 3.15.3.1, CEQA Significance Criteria. The analysis considers the Core Collection System, Export Pipeline System, and Extended Collection System, as appropriate, in the context of construction, operation, and maintenance.

The following methods were used to evaluate the potential impacts from construction, operation, and maintenance of the Proposed Project on recreation:
 Use of GIS data to locate the existing parks, recreational facilities, trails, and streams within the study area.
 Use of Google Earth and GIS data to measure the distance of parks and recreational facilities from the Proposed Project.
 Analysis of construction methods, ROW, and staging areas.  Analysis of the Project’s consistency with the requirements of all plans, policies, and regulations listed in Section 3.15.2, Regulatory Framework.
 Analysis of operations and maintenance methods including periodic inspection of the Core Collection System, Extended Collection System, Export Pipeline System and associated instrumentation, and flow data sampling.

3.15.4 Impact Analysis
This section describes the potential environmental impacts on recreation facilities that could result from implementing the Proposed Project. Because construction of the Proposed Project will primarily occur 493
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 314
within the ROW, the impact analysis for recreation focuses on the potential for temporarily impeding access to recreational facilities or trails in the study area during construction.

Disturbed areas would be restored to their original conditions and operations and maintenance efforts would be limited to proposed above-ground features which would not be located within a recreational facility. As discussed in Section 2.8 Proposed Operation and Maintenance, while the Core Collection System, Extended Collection System, and Export Pipeline System pipelines are designed to maintain their integrity during operations, it is always possible that a segment of pipeline could break.

Procedures to address a pipeline break are addressed in Section 2.8 and these activities could temporarily impede access to recreational facilities.

3.15.4.1 Impact REC-1: 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 Impact)
Construction
As shown in Figure 3.15-1, recreational zonings are adjacent to the Core Collection System, Extended Collection System, and Export Pipeline System. The Terry Ashe Recreation Center and Paradise Community Park are also adjacent to the Core Collection System construction footprint. The Tuscan Ridge Club is adjacent to the Export Pipeline System along Skyway. Within the study area there is a bike trail along Midway, and Hegan Lane is also considered a bicycle friendly road. Recreational activities and facilities are not present at Comanche Creek, Butte Creek, or Little Chico Creek.

Therefore, no water-based recreation would be affected by the Proposed Project.

Construction work would be short-term in any one location and construction would occur primarily within the existing ROW on previously disturbed land. Further, as shown in Figure 2-19, Potential Project Staging Areas, staging areas would be in various locations along the Export Pipeline System alignment, but would not be within a 2-mile radius of recreational areas.

Given that most work would occur in the public ROW, there is potential for bike paths or access to recreation to be temporarily closed or impeded during construction. Full road closures would not occur except during movement of large equipment (Section 2.7.2, Traffic Management and Temporary Construction Road Closures); single lane, temporary closures are proposed during construction. Any road and bike path closures would also be temporary.

Minor increases in recreational use at other available facilities may occur on a short-term basis, but substantial physical deterioration of these facilities is not expected to occur or to be accelerated.

Therefore, construction of the Proposed Project would have no impact on other recreational facilities.

Mitigation. No mitigation required.

Operation and Maintenance
Section 2.8, Proposed Operation and Maintenance, describes activities, such as periodic inspections, that would occur during operation and maintenance. These activities would have no influence on the use of parks and recreational facilities in the study area. 494
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 315
Recreational facilities within the Town were sized to meet the pre-fire demand for services by the Town and would be anticipated to rebuild to previous conditions on par with the returning population.

Increases in population that would be supported by operation of the Proposed Project would primarily consist of regrowth and repopulation toward pre-fire levels. Growth beyond pre-fire conditions would be in alignment with the Town of Paradise General Plan assumptions for future growth (Town of Paradise and Quad Consultants 2008). Impacts would, therefore, be less than significant.

Mitigation. No mitigation required.

3.15.4.2 Impact REC-2: 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 Impact)
Construction
New recreational facilities are not proposed as part of the Project, nor would construction of the Proposed Project cause construction or expansion of existing recreational facilities where it might have an adverse physical effect on the environment. Therefore, there would be no impact to recreational facilities during construction.

Mitigation. No mitigation required.

Recreational facilities within the Town were sized to meet the demand for services by the Town pre-fire and would be anticipated to rebuild to previous conditions on par with the returning population.

Increases in population that would be supported by operation of the Proposed Project would primarily consist of regrowth and repopulation toward pre-fire levels. Growth beyond pre-fire conditions would be in alignment with the Town of Paradise General Plan assumptions for future growth (Town of Paradise and Quad Consultants 2008). Therefore, recreational impacts during operations and maintenance would be less than significant.

Mitigation. No mitigation required.
495
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 316

3.15.5 Impacts Summary
Table 3.15-4 summarizes the recreation impacts of the Proposed Project.

Table 3.15-4. Recreation Impacts Summary
Impact
Level of
Significance
Before Mitigation
Mitigation
Level of
Significance
with Mitigation
Incorporated
Impact REC-1: 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

LTS N/A LTS
Impact REC-2: Include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment

LTS N/A LTS
Notes: LTS = Less than Significant Impact, NI = No Impact, N/A = Not Applicable, SI = Significant Impact, S/M = Significant Impact but Mitigable to a Less than Significant Level

3.15.6 References
Butte County. 2011. 2011 Butte County Bicycle Plan. June 2011. https://www.buttecounty.net/Portals/ 22/downloads/BikewayMastserPlan/5-23-11%20FINAL%20Draft_County_Bike_ Plan%20June%2014%202011%20with%20Table%20of%20Contents.pdf.

Butte County. 2022e. “Paradise Aquatic Park.” Accessed April 28, 2022. https://www.explorebuttecounty.com/places/paradise-aquatic-park.

Butte Creek Country Club. 2022. “Butte Creek.” Accessed April 28, 2022. https://www.buttecreekcountryclub.com/.

California Department of Parks and Recreation. 2022. “Find a California State Park.” Accessed April 13, 2022. https://www.parks.ca.gov/ParkIndex.

Chico Area Recreation and Park District (CARD). 2021. “About the District.” Accessed May 28, 2021. https://www.chicorec.com/about-the-district.

CARD. 2022. “Parks and Facilities.” Accessed April 28, 2022. https://www.chicorec.com/parks-facilities.

City of Chico. 2017. Chico 2030 General Plan. Adopted April 2011. Amended March 2017. https://chico.ca.us/post/chico-2030-general-plan.

City of Chico. 2022c. “Parks and Outdoors.” Accessed April 13, 2022. https://chico.ca.us/parksoutdoors. 496
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 317
City of Chico Parks Department. 2008. Bidwell Park Master Management Plan Update. June 2008. https://chico.ca.us/post/bidwell-park-master-management-plan.

City of Chico Parks Department. 2021. Final Vegetative Fuels Management Plan for Parks, Greenways, Preserves, and Open Spaces. February 2021. https://chico.ca.us/sites/main/files/fileattachments/final_vfmp_april_2021.pdf?1618334835.

DWR. 2021. “Lake Oroville Recreation.” Accessed May 28, 2021. https://water.ca.gov/Programs/StateWater-Project/SWP-Facilities/Oroville/Lake-Oroville-Recreation.

Golf Pass. 2022. “Lava Creek Golf Course.” Accessed April 28, 2022. https://www.golfpass.com/traveladvisor/courses/22118-lava-creek-golf-course.

Paradise Recreation and Park District (PRPD). 2021. “About Us.” Accessed May 28, 2021. https://www.paradiseprpd.com/about-us.

U.S. Department of Agriculture (USDA) Forest Service. 2022. “Recreation.” Accessed April 28, 2022. https://www.fs.usda.gov/recmain/lassen/recreation.
497
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 318

3.16 Transportation
This section describes the environmental setting and regulatory framework for transportation in the study area, and includes a discussion of the circulation system, including transit, roadway, bicycle, and pedestrian facilities; VMT; and emergency access. This section also identifies the direct and indirect impacts of the Proposed Project on transportation during construction, operation, and maintenance. For the purposes of this PEIR, the study area for transportation refers to the areas within and directly adjacent to Paradise and areas of unincorporated Butte County and Chico where the proposed pipeline alignment runs.

3.16.1 Environmental Setting

3.16.1.1 Roadway System
A network of local roadways and highways form the roadway system within the study area. The primary entrances to Paradise are Skyway and SR 191 (Clark Road). Paradise is connected to Chico via Skyway and to Oroville via SR 191, which is known as Clark Road upon entering Paradise.

The proposed pipeline route to connect the collection system in Paradise to the Chico WPCP follows Skyway (between Neal Road and Butte Creek), a road that runs southwest from Paradise toward the southern end of Chico. The pipeline leaves Skyway to cross Butte Creek, SR 99, and the Union Pacific Railroad. The pipeline would then follow Midway (between Marybill Ranch Road to Hegan Lane), Hegan Lane (between Midway to Dayton Road), Elk Avenue (between Dayton Road to Lone Pine Avenue), Lone Pine Avenue (between Elk Avenue to Crouch Avenue), Crouch Avenue (between Lone Pine Avenue to Chico Avenue), Chico Avenue (between Crouch Avenue to Taffee Avenue), Taffee Avenue (between Chico Avenue to Chico River Road) and Chico River Road (between Taffee Avenue to the Chico WPCP). Figure 3.16-1 shows the proposed Export Pipeline System routes.

Based on the Chico 2030 General Plan (City of Chico 2017), Skyway (between Neal Road and Bute Creek) is a four-lane divided freeway/expressway. Midway (between Marybill Ranch Road to Hegan Lane) is a two-lane arterial. Hegan Lane (between Midway to Dayton Road) is a two-lane minor collector. Chico River Road (between Taffee Avenue to the Chico WPCP) is a two-lane arterial. Elk Avenue (between Dayton Road to Lone Pine Avenue), Lone Pine Avenue (between Elk Avenue to Crouch Avenue), Crouch Avenue (between Lone Pine Avenue to Chico Avenue), Chico Avenue (between Crouch Avenue to Taffee Avenue) and Taffee Avenue (between Chico Avenue to Chico River Road) are all classified as two-lane local roads.

3.16.1.2 Bicycle Facilities
The following types of bicycle facilities exist within the study area:
 Class I: A Class I facility, commonly referred to as a bikeway or bike path, is a facility separated from automobile traffic for the exclusive use of bicyclists. Class I facilities can be designed to accommodate pedestrians, in which case they are referred to as shared or multi-use paths.  Class III: Class III facilities, commonly referred to as bike routes, are on-street routes where bicyclists and automobiles share the road. They are identified with pavement markings and signage, and are typically assigned to low-volume and/or low-speed streets. 498
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 319
Skyway is a Class III bike route between Potter Road and Spanish Garden Drive. Midway and Park Avenue in Chico are classified as Class I bike paths.

3.16.1.3 Pedestrian System
Within Paradise, there are discontinuous sidewalks along Skyway between Neal Road and Wagstaff Road. Discontinuous sidewalks also exist along Clark Road between Pearson Road and Wagstaff Road. There are no sidewalks south of the Clark Road and Pearson Road intersection.

Within Chico, there are discontinuous sidewalks along Entler Avenue.

3.16.1.4 Transit Service
Although the automobile is the primary mode of travel within Butte County, there are other modes of travel available, such as mass transit, paratransit, and private bus operators (Butte County 2010). Butte Regional Transit (or B-Line) is Butte County’s regional public transit system. B-Line provides fixed route transit services to Biggs, Chico, Gridley, Oroville, Paradise, and communities within unincorporated Butte County (Butte County 2010).

Prior to the 2018 Camp Fire, B-Line service to and from Paradise included three fixed routes: Route 41 (between Magalia and Chico via Paradise), Route 40 (between Paradise and Chico), and Route 31 (between Paradise and Oroville) (Butte Regional Transit 2019). The 2018 Camp Fire caused several changes to the B-Line service in Paradise, including a reduction in the number of trips on Routes 40 and 41 and suspension of Route 31 until further notice (Butte Regional Transit 2019). Several bus stops served by Routes 40 and 41 are located along Skyway within the boundaries of the Core Collection System (Google Earth 2022).

3.16.2 Regulatory Framework
This section summarizes the federal, state, regional, and local laws, regulations, policies, and plans relevant to evaluation of the Proposed Project’s impacts on transportation. Additional information on the relevant regulations, laws, and plans is provided in Appendix C, Regulatory Framework. 499
hdrinc.com
Final Program Environmental Impact Report 320
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
Figure 3.16-1. Paradise Export Pipeline System Routes
500
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 321

3.16.2.1 Federal
No identified federal laws, regulations, orders, policies, or plans regarding land use and planning are relevant to the Proposed Project.

3.16.2.2 State
Senate Bill 743
SB 743 was signed into law in September 2013. SB 743, which added PRC Section 21099 to CEQA, proposed a change in how transportation impacts are analyzed in transit priority areas to better align local environmental review with statewide objectives. These alignment considerations include reductions to GHG emissions, encouragement of infill mixed-use development in designated priority development areas, reductions of regional sprawl land development, and reductions in mobile source VMT.

In November 2017, the Governor’s Office of Planning and Research released the final proposed update to CEQA Guidelines consistent with SB 743, recommending VMT, both within and outside of transit priority areas, as the most appropriate metric of transportation impact. This metric will align with local environmental review under CEQA and with California’s long-term GHG emissions reduction goals.

The Proposed Project will be held to the principles set forth by SB 743.

3.16.2.3 Regional and Local
Butte County 2020 Regional Transportation Plan/Sustainable Communities Strategy The Butte County 2020 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) (BCAG 2020b) specifies the policies, projects, and programs necessary over a 20-year period between 2020 and 2040 to maintain, manage, and improve the region’s transportation system. BCAG is the federally designated Metropolitan Planning Organization and the state-designated Regional Transportation Planning Agency for Butte County. The RTP/SCS provides a foundation for transportation decisions by local, regional, and state officials. This foundation is based on a vision of an efficient and environmentally sound multi-modal system.

The RTP/SCS is the region’s long-range plan to meet the requirements of California’s Sustainable Communities and Climate Change Act of 2008 (SB 375), which calls on regions throughout California to develop a Sustainable Communities Strategy that demonstrates the integration of land use, housing, and transportation for the purpose of reducing GHG emissions from passenger vehicles. The RTP/SCS is intended to be consistent with the California Transportation Plan developed by Caltrans.

The Proposed Project will be held to the policies and programs of the RTP/SCS. 2011 Butte County Bicycle Plan
The 2011 Butte County Bicycle Plan (Butte County 2011) provides Butte County’s vision for making bicycling an integral part of the transportation system with its unincorporated limits. The plan includes emphasis on regional connectivity between the local cities of Biggs, Chico, Gridley, Oroville and the Town of Paradise, in addition to the various rural communities and recreational opportunities that exist within Butte County. The plan will also assist Butte County in its efforts to safely and equitably provide 501
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 322
contiguous bicycle facilities in the future as well as implement roadway projects that are bicycle friendly throughout the unincorporated areas.

The Proposed Project will be held to the policies of this plan.

Town of Paradise General Plan
The Town of Paradise General Plan (Town of Paradise and Quad Consultants 2008) includes the following policies related to transportation that are relevant to the Proposed Project:
 Goal CG-2: Provide safe, efficient and effective traffic flow, both within Paradise and between Paradise and its environs.
 Goal CG-4: Provide adequate access, including access for emergency vehicles and evacuation, to all new parcels and to existing parcels when feasible.  Policy CP-1: The Town will 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 will be maintained on all local streets within the Town limits, and LOS “C” or better will be maintained whenever feasible.
 Policy CP-8: The Town should continue to designate and regulate truck routes in order to protect residential areas from unwanted noise and traffic.  Policy 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 tum, reduces air pollution and congestion and saves energy.
 Policy CP-15: Expand public transportation services within Paradise and between Paradise and major employment centers as feasible, based on service demand and financial constraints.

The Proposed Project will be held to the policies in the Town of Paradise General Plan.

Town of Paradise VMT Policies
The Town adopted VMT Policies on April 12, 2022. The policies will be implemented, as applicable, in public and private projects in order to try to reach compliance with BCAG goals and with statewide VMT requirements. The City Council Agenda, which includes more detail on each policy, is included in Appendix B. The Town also adopted The Town of Paradise Transportation Management Plan in April 2022 that plans for increasing the active transportation network (that is bicycle and pedestrian pathways) to 39.3 miles of paths of which 88 percent would be along of the Towns’ major roadways (Town of Paradise 2022g). In addition to growth of the pathways, other improvements in the pedestrian network include making all intersections ADA compliant, closing gaps in the existing sidewalk network, and improving sidewalk visibility; improvements beyond growth recommended for the bicycle network include new bicycle parking, as well as a rest areas and signage (Town of Paradise 2022g). As possible, based on schedule and availability of funding, the Town will implement the improvements outlined in The Town of Paradise Transportation Management Plan (Town of Paradise 2022g) in coordination with implementation of Proposed Project where locations overlap. This would maximize cost efficiencies and minimize disturbances from roadway construction. 502
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 323
Policies include:
 Increase diversity of land uses
 Provide pedestrian network improvements
 Provide traffic calming measures and low-stress bicycle network improvements  Implement car-sharing program
 Increase transit service frequency and speed
 Implement subsidized or discounted transit program
 Encourage telecommuting and alternative work schedules  Provide ride-sharing programs
The Proposed Project will be held to the policies in the Town of Paradise VMT Policies.

Butte County General Plan 2030
The Butte County General Plan 2030 (Butte County 2012) includes the following policies related to transportation that are relevant to the Proposed Project:
 Policy CIR-P1.3: Transportation planning within the municipalities’ spheres of influence will consider the municipalities’ land use and circulation plans, as appropriate, and will be consistent with Policy CIR-P6.1 pertaining to County Levels of Service.  Policy CIR-P2.1: Carpooling will be encouraged by providing additional carpool pickup and park-and-ride locations near transit centers and at freeway interchanges.  Policy CIR-P2.2: Trip reduction among County employees will be encouraged. Specific measures to encourage trip reduction could include providing subsidies, bicycle facilities, alternative work schedules, ridesharing, telecommuting and work-at-home programs, employee education and preferential parking for carpools/vanpools.  Policy CIR-P2.4: Employers will be encouraged to provide transit subsidies, bicycle facilities, alternative work schedules, ridesharing, telecommuting and work-at-home programs, employee education and preferential parking for carpools/vanpools.  Policy CIR-P3.10: Trees located along urban streets will be protected. If maintenance or upgrading requires tree removal, the trees will be replaced.  Policy CIR-P6.1: The level of service for County-maintained roads within the unincorporated areas of the county but outside municipalities’ sphere of influences (SOIs) will be LOS C or better during the PM peak hour. Within a municipality’s SOI, the level of service will meet the municipality’s level of service policy.
 Policy CIR-P6.3: Project approval will be conditioned on the provision of roadway improvements to meet the level of service standards in policies CIR-P6.1 and CIR-P6.2.

Exceptions to satisfying the level of service standards and/or constructing transportation facilities to the County’s design standards may be allowed on a case-by-case basis, where reducing level of service or not constructing a transportation facility to County standards would result in a clear public benefit. Such circumstances may include, but are not limited to the following:
o Conserving agricultural or open space land.
o Enhancing the agricultural economy.
503
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 324
o Protecting scenic roadways or highways.
o Preserving downtown community environments.
 Policy CIR-P6.5: Street improvements within the sphere of influence of an incorporated municipality will conform to the street standards of that municipality.  Policy CIR-P7.2: Existing road capacity available within the County road system will be used to serve future development unless construction of a new road will enhance circulation opportunities.

The Proposed Project will be held to the policies in the Butte County General Plan 2030.

Chico 2030 General Plan
The Chico 2030 General Plan (City of Chico 2017) includes the following policies related to transportation that are relevant to the Proposed Project:
 Policy CIRC-1.4, Level of Service Standards: Maintain LOS D or better for roadways and intersections at the peak PM period, except as specified below:
o LOS E is acceptable for City streets and intersections under the following circumstances:

Downtown streets, arterials served by scheduled transit, and arterials not served by scheduled transit, if bicycle and pedestrian facilities are provided within or adjacent to the roadway.
o Utilize Caltrans LOS standards for Caltrans’ facilities. o There are no LOS standards for private roads.
o If improvements necessary to achieve the LOS standard results in impacts to a unique historical resource, a highly sensitive environmental area, requires infeasible right-of-way acquisition, or some other unusual physical constraint exists. o If the intersection is located within a corridor that utilizes coordinated signal timing, in which case, the operation of the corridor as a whole should be considered.  Policy CIRC-1.5, Vehicle Miles Travelled Analysis: Consistent with State law, implement VMT assessments as part of the environmental review process under CEQA.  Policy CIRC-1.7, Goods Movement: Provide clear routes for goods delivery  Policy CIRC-2.2, Circulation Connectivity and Efficiency: Provide greater street connectivity and efficiency for all transportation modes.
 Policy CIRC-9.1, Reduce Peak-Hour Trips: Strive to reduce single occupant vehicle trips through the use of travel demand management strategies.  Policy CIRC-9.3, Emphasize Trip Reduction: Emphasize automotive trip reduction in the design, review, and approval of public and private development.

The Proposed Project will be held to the policies in the Chico 2030 General Plan.

3.16.3 Method of Analysis
This section describes the methods used to analyze transportation impacts within the study area. 504
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 325

3.16.3.1 CEQA Significance Criteria
For the purposes of this PEIR, the Proposed Project would result in a significant impact on transportation if it would:
 Impact TRA-1: Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities  Impact TRA-2: Conflict with or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)
 Impact TRA-3: Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)  Impact TRA-4: Result in inadequate emergency access

3.16.3.2 Approach to Analysis
Qualitative and quantitative analyses were performed to evaluate potential impacts on transportation using publicly available traffic data.

The analysis of environmental effects focuses on foreseeable changes to transportation in the context of effects listed in Section 3.16.3.1, CEQA Significance Criteria. The analysis considers the Core Collection System, Export Pipeline System, and Extended Collection System, as appropriate, in the context of construction, operation, and maintenance.

The analysis year for transportation was considered 2026 because that is the expected year the Proposed Project would be in operation and would be the last year of construction. The Butte County General Plan 2030 presents peak hour service volumes as acceptable measures of roadway segment operations (Butte County 2012). The Butte County General Plan 2030 classified the study area roadways as the same as the Chico 2030 General Plan (City of Chico 2017). Table 3.16-1 summarizes the peak hour service volume thresholds of Level of Service (LOS) C, D, and E for expressway, arterial, and collector. The Butte County General Plan 2030 does not provide peak hour service volume thresholds of LOS for local roads, and therefore, will not be included in this analysis. The Butte County General Plan 2030 specifies LOS D or better as an acceptable LOS (Butte County 2012).

Table 3.16-1. Butte County Peak Hour LOS Thresholds by Facility Type Traffic Volume Type
4-Lane
Freeway/Expressway 2-Lane Arterial 2-Lane Collector

LOS C LOS D LOS E LOS C LOS D LOS E LOS C LOS D LOS E
Peak Hour Service
Volume
2,530 3,280 3,650 970 1,760 1,870 550 1,180 1,520
Source: Butte County 2012
Note: All threshold volumes as specified in Butte County General Plan 2030 While the construction activity would only be temporary, an analysis was conducted to evaluate the magnitude of temporary traffic impacts. The three specific roadways that will be used to provide key access are the following:
 Skyway
505
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 326
 Midway
 Hegan Lane
The above roadways were used as there was recent enough traffic data that could be used in the analysis. In order to evaluate using a conservative approach, traffic operations during the last year of construction was analyzed (which was 2026) with the peak construction activity. The BCAG traffic counts webpage provides 2014 and 2018 roadway volumes for Skyway and Midway (BCAG 2018b, 2018c). The Chico 2030 General Plan, Appendix B, Traffic Model Data, provides 2010 roadway volumes for Hegan Lane (City of Chico 2017). Based on these available historic roadway volume data provided by BCAG, Skyway and Midway both have negative growth rates. However, based on BCAG’s Provisional Long-Term Regional Growth Forecasts 2018-2040 (BCAG 2019b), the forecasts show a compound annual growth rate of 0.88 percent. The 2018 roadway volumes were grown using a growth rate of 0.88 percent to get the volumes to 2021 for existing and 2026 for the future year analysis.

Table 3.16-2 summarizes the 2021 existing afternoon (PM) peak hour and 2026 future PM peak hour traffic volumes.

Table 3.16-2. Existing and Future PM Peak Hour Traffic Volume Roadway Segment Existing (2021) No Construction (2026)
Skyway 2,018 2,109
Midway 749 783
Hegan Lane 617 644
Source: BCAG 2018c
The BCAG 2020 RTP Travel Demand Model: Model Development Report has VMT for 2020 and projection growth rates for the future year (BCAG 2020a). A 1.2 percent annual growth rate was used to grow the VMT to the construction year. Table 3.16-3 presents the BCAG VMT projections from 2020 to 2026 and the increase due to the construction trips.

Table 3.16-3. Butte County VMT
Existing (2020) No Construction (2026)
VMT 4,343,919 4,660,038
Source: BCAG 2020a

3.16.4 Impact Analysis
This section describes the potential environmental effects on transportation as a result of implementation of the Proposed Project. It includes an analysis of the Proposed Project’s potential to conflict with a program, ordinance, or policy addressing the circulation system; conflict with CEQA Guidelines section 15064.3, subdivision (b); increase hazards due to a geometric design feature or incompatible uses; and result in inadequate emergency access. 506
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 327

3.16.4.1 Impact TRA-1: Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities (Less than Significant with Mitigation Incorporated)
Construction
It is estimated that approximately 121 worker trips per day and 1,500 truck trips per day would be used for the construction work related to the Core Collection System (HDR 2022). It is estimated that approximately 81 worker trips per day and 639 trucks trips per day would be used for the construction work related to the Export Pipeline System (HDR 2022). Both the Core Collection System and the Export Pipeline System construction work will occur simultaneously. Therefore, it is estimated that a total of 202 worker trips per day and 2,139 truck trips per day would be needed for the construction of the Core Collection System and the Export Pipeline System. The Proposed Project is anticipated to be constructed during typical construction work hours—8 hours per day, Monday through Friday. The activity is expected to last approximately 18 months.

It is assumed that 80 percent of the workers will be commuting during the PM peak hour due to the construction activity ending before the typical PM peak hour of 5 p.m. Therefore, the construction related trips generated by workers during PM peak hour is estimated to be 162 trips per peak hour. The 2,139 daily truck trips were divided by 8 (construction hours per day) to estimate 268 truck trips per peak hour. The total construction trips per peak hour (workers + trucks) was estimated to be 430 per peak hour.

Table 3.16-4 summarizes the no construction and construction conditions PM peak hour volume results on the study road segments in 2026.

Table 3.16-4. 2026 No Construction and Construction Traffic Volumes Roadway Segment
PM Peak Hour Volume
LOS D Threshold No Construction
(2026) Construction Trips Construction (2026)
Skyway 3,280 2,109 430 2,539
Midway 1,760 783 430 1,213
Hegan Lane 1,180 644 430 1,074
Source: Butte County 2012, BCAG 2018c
As shown in Table 3.16-4, the Skyway and Midway segments operate below the LOS D threshold under future 2026 conditions and the Project construction trips are not expected to cause LOS degradation or lead to larger delays. As shown in Table 3.16-4, Hegan Lane operates at LOS D under future 2026 conditions, which shows that the roadway segment is near capacity. The additional construction trips are minimal compared to the typical volume and does not cause a degradation of LOS.

Similar to the Core Collection System, construction of the Extended Collection System would add trips to the roadways segments. The Extended Collection System is expected to generate similar vehicle trip volumes as estimated for the Core Collection System, though likely for a shorter timeframe. Similar to the Core Collection System, the additional construction trips would be minimal compared to the typical volume and would not cause a degradation of LOS.
507
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 328
As presented in Section 3.16.2, Regulatory Framework, LOS D or better is an acceptable LOS in Paradise, Butte County, and Chico. Therefore, the roadway segments would operate at an acceptable LOS with the addition of construction traffic associated with the Proposed Project.

Installation of the pipeline within the ROW would temporarily affect traffic flow. Pipeline installation within the ROW would require temporary lane closures. Construction of the Export Pipeline System within or across streets could obstruct access and cause delays for pedestrians, bicyclists, and transit buses. Therefore, the impact related to potential conflicts with a program, plan, ordinance, or policy addressing the circulation system would be significant.

Mitigation. To minimize potentially significant impacts on pedestrian, bicycle, and transit facilities during construction of the Proposed Project to a less than significant level, mitigation measure MM-HAZ-6 will be implemented.

MM-HAZ-6: Traffic Management Plan (see Section 0, Hazards and Hazardous Materials, for description)
Significance after Mitigation. With the implementation of mitigation measure MM-HAZ-6, impacts on pedestrian, bicycle, and transit facilities during construction would be less than significant.

Operation and Maintenance
As discussed in Section 2.8 Proposed Operations and Maintenance, while the Core Collection System, Export Pipeline System, and Extended Collection System pipelines are designed to maintain their integrity during operations, it is always possible that a segment of pipeline could break, for example during excavations near a pipeline by others. Procedures to address a pipeline break are discussed in Section 2.8. During any excavations or other work on the pipeline by Town Public Works, the same procedures and standards would apply. Operation and maintenance activities will be performed periodically according to the schedule discussed in Section 2.8.

Operation and maintenance activities, as described in Section 2.8, would result in minimal increased traffic volumes on the roadways in the study area. Relative to existing traffic volumes on roadways in the study area, the addition of traffic associated with operation and maintenance of the Proposed Project would not affect roadway operations. Therefore, impacts related to conflict with a program, plan, ordinance, or policy addressing the circulation system during operation and maintenance of the Proposed Project would be less than significant.

Mitigation. No mitigation required.

3.16.4.2 Impact TRA-2: Conflict with or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)? (Less than Significant Impact) CEQA Guidelines Section 15064.3, subdivision (b) provides the following criteria for analyzing transportation impacts, although only criteria 3 and 4 apply to this Project:

1. Land Use Projects. VMT exceeding an applicable threshold of significance may indicate a significant impact. Generally, projects within one-half mile of either an existing major transit stop or a stop along an existing high quality transit corridor should be presumed to cause a less than 508
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 329
significant transportation impact. Projects that decrease VMT in the project area compared to existing conditions should be presumed to have a less than significant transportation impact.

2. Transportation Projects. Transportation projects that reduce, or have no impact on, VMT should be presumed to cause a less than significant transportation impact. For roadway capacity projects, agencies have discretion to determine the appropriate measure of transportation impact consistent with CEQA and other applicable requirements. To the extent that such impacts have already been adequately addressed at a programmatic level, such as in a regional transportation plan EIR, a lead agency may tier from that analysis as provided in Section 15152.

3. Qualitative Analysis. If existing models or methods are not available to estimate the VMT for the particular project being considered, a lead agency may analyze the project's VMT qualitatively. Such a qualitative analysis would evaluate factors such as the availability of transit, proximity to other destinations, etc. For many projects, a qualitative analysis of construction traffic may be appropriate.

4. Methodology. A lead agency has discretion to choose the most appropriate methodology to evaluate a project's VMT, including whether to express the change in absolute terms, per capita, per household or in any other measure. A lead agency may use models to estimate a project's VMT and may revise those estimates to reflect professional judgment based on substantial evidence. Any assumptions used to estimate VMT and any revisions to model outputs should be documented and explained in the environmental document prepared for the project. The standard of adequacy in Section 15151 shall apply to the analysis described in this section.

Construction
Construction of the Proposed Project would cause a temporary increase in VMT due to the worker and truck trips. As described under Impact TRA-1, a total of 202 workers per day and 2,139 truck trips per day would be needed for the construction of the proposed Core Collection System and the Export Pipeline System. The worker trips are assumed to have a 15-mile average trip length, while the trucks trips are assumed to have a 50-mile average trip length. The BCAG 2020 RTP Travel Demand Model:

Model Development Report has VMT for 2020 and projection growth rates for the future year (BCAG 2020a). A 1.2 percent annual growth rate was used to grow the VMT to the construction year.

Table 3.16-5 presents the BCAG VMT projections from 2020 to 2026 and the increase due to the construction trips. The 2020 VMT projections represent the existing conditions while the 2026 VMT projections represent the opening year and final year of construction.

Table 3.16-5. Butte County VMT
2020 2026 No Construction 2026 Construction Percent Increase VMT 4,343,919 4,660,038 4,770,018 2.3
Source: BCAG 2020a
As shown in Table 3.16-5, the percentage increase due to the construction trips associated with the Core Collection System and Export Pipeline System is 2.3 percent of Butte County’s VMT. While the construction traffic would cause an increase in VMT, the increase would be temporary and short-term.

Likewise, while construction of the Extended Collection System would continue in future years after the Core Collection System and Export Pipeline System is installed, similar traffic volumes and approaches 509
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 330
would be assumed resulting in comparable if not fewer intensive impacts on VMT. Therefore, impacts related to conflict with or inconsistency with CEQA Guidelines Section 15064.3(b) during construction of the Proposed Project would be less than significant.

Mitigation. No mitigation required.

Operation and maintenance activities, as described in Section 2.8, would not cause an increase in VMT in the study area due to the infrequency of these activities. Therefore, operation and maintenance of the Proposed Project would not conflict with or be inconsistent with CEQA Guidelines Section 15064.3(b), resulting in no impact.

Mitigation. No mitigation required.

3.16.4.3 Impact TRA-3: Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) (No Impact)
Construction, Operation, and Maintenance
The Proposed Project elements would not change geometric design features or require incompatible uses. Neither permanent nor temporary geometric design changes are anticipated as all street legal trucks and vehicles would use the existing roadways to enter and exit the Project site. Additionally, construction of the Core Collection System, the Export Pipeline System, and the Extended Collection System would largely occur within the existing ROW and conditions would be restored once construction is complete. Therefore, the Proposed Project would have no impact on hazards due to a geometric design feature or incompatible uses.

Mitigation. No mitigation required.

3.16.4.4 Impact TRA-4: Result in inadequate emergency access (Less than Significant with Mitigation Incorporated)
Construction
Construction activities associated with the Proposed Project would require the temporary closure of traffic lanes on public roadways. Construction of the Proposed Project would add truck and vehicle traffic to roadways in the study area. Construction-related trucks and vehicles could interfere with emergency response to the Project site or evacuation procedures in the event of an emergency.

Therefore, construction of the Proposed Project could result in inadequate emergency access, resulting in a potentially significant impact.
510
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 331
Mitigation. To minimize potentially significant impacts related to emergency access during construction of the Proposed Project to a less than significant level, mitigation measure MM-HAZ-6 will be implemented.

MM-HAZ-6: Traffic Management Plan (see Section 0, Hazards and Hazardous Materials, for description)
Significance after Mitigation. With the implementation of mitigation measure MM-HAZ-6, impacts related to emergency access during construction would be less than significant.

Operation and maintenance activities, as described in Section 2.8, would result in increased traffic volumes on the roadways in the study area. Relative to existing traffic volumes on roadways in the study area, the addition of traffic associated with operation and maintenance of the Proposed Project would not affect roadway operations in the study area. As a result, emergency access would remain similar to existing conditions during operations and maintenance. Therefore, impacts on emergency access during operation and maintenance of the Proposed Project would be less than significant.

Mitigation. No mitigation required.

3.16.5 Impacts Summary
Table 3.16-6 summarizes the transportation impacts of the Proposed Project.

Table 3.16-6. Transportation Impacts Summary
Impact
Level of
Significance
Before Mitigation
Mitigation
Level of
Significance
with Mitigation
Incorporated
Impact TRA-1: Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities
SI MM-HAZ-6 S/M
Impact TRA-2: Conflict with or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)

LTS N/A LTS
Impact TRA-3: Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)

NI N/A NI
Impact TRA-4: Result in inadequate emergency access SI MM-HAZ-6 S/M Notes: LTS = Less than Significant Impact, NI = No Impact, N/A = Not Applicable, SI = Significant Impact, S/M = Significant Impact but Mitigable to a Less than Significant Level
511
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 332

3.16.6 References
Butte County. 2010. Butte County General Plan 2030 Draft EIR. April 8, 2010. https://www.buttecounty.net/Portals/10/Docs/GP2030/ButteCountyGP_PublicReview_ EIR.pdf?ver=2019-07-25-160952-113.

Butte County. 2011. 2011 Butte County Bicycle Plan. June 14, 2011. https://www.buttecounty.net/ Portals/22/downloads/BikewayMastserPlan/5-23-11%20FINAL%20Draft_County_Bike_ Plan%20June%2014%202011%20with%20Table%20of%20Contents.pdf.

BCAG. 2018b. “2013/14 Traffic Counts.” Accessed July 15, 2021. http://www.bcag.org/documents/ demographics/traffic_counts/Traffic_Counts_2013-14_web.pdf.

BCAG. 2018c. “2017/18 Traffic Counts.” Accessed July 15, 2021. http://www.bcag.org/documents/ demographics/traffic_counts/BCAG_Traffic_Counts_2018_final_web.pdf.

BCAG. 2019b. Provisional Long-Term Regional Growth Forecasts 2018-2040. September 2019. http://www.bcag.org/documents/demographics/pop_emp_projections/Growth_Forecasts_2018- 2040_draft_v2.pdf.

BCAG. 2020a. BCAG 2020 RTP Travel Demand Model: Model Development Report. Final. Prepared for Butte County Association of Governments. Prepared by Fehr and Peers. September 2020. http://www.bcag.org/documents/planning/traffic%20model/BCAG_ModelDevelopmentReport_2 020.pdf.

BCAG. 2020b. Butte County 2020 Regional Transportation Plan/Sustainable Communities Strategy.

December 10, 2020. http://www.bcag.org/documents/planning/RTP%20SCS/ 2020%20RTP%20SCS/Document%20Chapters/2020%20RTP%20SCS%20DocumentALL%20REVISED.pdf.

Butte Regional Transit. 2019. Schedules and System Maps. September 1, 2019. http://www.blinetransit.com/documents/B-LineWeb2019.pdf.

City of Chico. 2017. Chico 2030 General Plan. Adopted April 2011. Amended March 2017. https://chico.ca.us/post/chico-2030-general-plan.

Google Earth. 2022. Aerial imagery and street view of the study area. Accessed March 20, 2022. https://earth.google.com/web/.

HDR. 2022. EIR Construction Analysis. Technical Memorandum #9, Paradise Sewer Project. February 18, 2022. https://paradisesewer.com/wp-content/uploads/2022/06/2022-HDR-Technical-Memo9-EIR-Construction-Analysis.pdf.

Town of Paradise. 2022g. The Town of Paradise Transportation Management Plan. March 2022. 512
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 333
Town of Paradise and Quad Consultants. 2008. Town of Paradise 1994 General Plan. Prepared for Town of Paradise Community Development Department. Amended January 2008. https://www.townofparadise.com/sites/default/files/fileattachments/planning/page/3251/townofp aradise-generalplan_1994.pdf.
513
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 334

3.17 Tribal Cultural Resources
This section describes the environmental setting and regulatory framework for TCR in the study area and includes a summary and discussion of the consultation held with Native American tribes, which is a necessary step to identifying TCRs that may be affected by the Proposed Project. This section also identifies the direct and indirect impacts of the Proposed Project on TCRs during construction, operation, and maintenance. The study area to identify TCRs is defined as the geographical extent of the proposed project, inclusive of the Export Pipeline System, Core Collection System, and Extended Collection System.

3.17.1 Environmental Setting
Knowledge of current environmental conditions is critical to the assessment of potential environmental impacts on TCR because TCRs may include components of the environment that comprise sites, features, places, cultural landscapes, or sacred places with cultural importance to California Native American tribes. Knowledge of current environmental conditions with regard to TCRs is reliant on the values of Indigenous groups and individuals for whom such resources embody and reflect culturally defined perspectives, values, traditions, and relationships with the environment.

The study area is situated within the ancestral territory of the Konkow people that have lived—and continue to live—in the region since 3,000-2,000 B.P. The historical homeland of the foothill Konkow are the foothills region of the northern Sierra, centered on the river drainages of the North Fork of the Feather River, and roughly encompasses the present political boundaries of Butte County.

Archaeological, ethnographic, and historic-era context presented in Section 0, Cultural Resources, provides relevant information to the understanding of TCRs as cultural resources; this section provides additional information within the framework of tribal cultural values held by California Native American tribes that define the significance of TCRs within the Proposed Project area. The records search and pedestrian survey discussed in Section 0 identified several cultural resources that may also hold significance to California Native American tribes outside of the archaeological significance discussed above as the tribes are cultural stewards in the study area, and which are currently unevaluated for such significance in relation to their eligibility for listing in the CRHR.

As summarized and discussed above in Section 0, Indigenous people have undergone centuries of racial, ethnic, and cultural adversity in their homelands, and still maintain traditional, religious, and cultural connections with the environment. Today, many Konkow tribal organizations and culturally affiliated groups maintain connections with the surrounding area of the study area including Berry Creek Rancheria of Maidu Indians (Tyme Maidu Tribe), Enterprise Rancheria of Maidu Indians of California (Enterprise Rancheria Estom Yumeka Maidu), Konkow Valley Band of Maidu, Mechoopda Indian Tribe of Chico Rancheria, Mooretown Rancheria of Maidu Indians, and Round Valley Indian Tribes of the Round Valley Reservation. These Indigenous organizations and others maintain stewardship of their culture—inclusive of its language, epistemologies, histories, and traditions—in the vicinity of the study area through cultural educational programs, public education programs, cultural ceremonies, religious practices, ecological heritage, consultation with local, state, and federal agencies, among other actions.
514
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 335
The Konkow Valley Band of Maidu is actively engaged in cultural endurance and stewardship in their ancestral lands which includes a majority of the proposed project area. TCRs with significance to the Konkow Valley Band of Maidu include components of the environment that comprise sites, features, places, cultural landscapes, or sacred places with cultural importance. As part of ongoing stewardship, Konkow Valley Band of Maidu maintains a monitoring program through Konkow Valley Cultural Preservation to protect and prevent disturbances to resources of importance. The Mechoopda Indian Tribe of Chico Rancheria has successfully reestablished residency in Chico through many efforts, including development of the Chico Rancheria Housing Corporation; land purchases and construction of a tribal office complex and community building; development of the Mechoopda Economic Development Corporation, acquisition of 650 acres of “restored lands” south of Chico; among other successful efforts in the political, economic, and social rebuilding and restoration of the Mechoopda people (Mechoopda Indian Tribe of Chico Rancheria 2021). Resources of cultural importance are likely to include those that provide the Mechoopda people with a connection to their heritage within the vicinity of the Proposed Project area in various ways, including sites, features, places, cultural landscapes, or sacred places with cultural importance connected to previous ancestral habitation, burial sites, ritual performance sites, and places and spaces that support traditional and cultural activities.

Through consultation with Konkow Valley Band of Maidu and Mechoopda Indian Tribe of Chico Rancheria, further discussed below, the Town has been made aware that the study area is near several areas that are culturally sensitive for these tribes. Appropriate mitigation measures have been established for the Proposed Project in coordination with Konkow Valley Band of Maidu and Mechoopda Indian Tribe of Chico Rancheria to appropriately avoid significant impacts on culturally sensitive areas (see Section 3.17.4).

3.17.2 Regulatory Framework
This section summarizes the federal, state, regional, and local laws, regulations, policies, and plans relevant to evaluation of the Proposed Project’s impacts on tribal cultural resources. Additional information on the relevant regulations, laws, and plans is provided in Appendix C, Regulatory Framework.

3.17.2.1 Federal
Indian Trust Assets
Indian Trust Assets are legal interests in property held in trust by the United States for Native American tribes or individuals. Examples of potential Indian Trust Assets are lands, minerals, fishing rights, and water rights. Management of Indian Trust Assets is based on the following orders, agreements, and regulations: EO 13175, Memorandum on Government-to-Government Relations with Native American Tribal Governments, Secretarial Order No. 3175, Secretarial Order No. 3206, Secretarial Order No. 3215, Secretarial Order No. 3342, and Secretarial Order No. 3335.

The Proposed Project will be held to the management principles of Indian Trust Assets.

American Indian Religious Freedom Act
The American Indian Religious Freedom Act of 1978 (42 USC Section 1996) protects the rights of Native Americans to exercise their traditional religions by ensuring access to sites, use and possession of sacred objects, and the freedom to worship through ceremonials and traditional rites. 515
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 336
The Proposed Project will be held to the principles set forth by this act.

Historic Sites Act
The Historic Sites Act of 1935 (54 USC Sections 320101–320106, formerly 16 USC 461–467) declares “…that it is a national policy to preserve for public use historic sites, buildings, and objects of national significance…,” asserting historic preservation as a government duty under jurisdiction of the United States Secretary of the Interior.

The Proposed Project will be held to the requirements of this act.

National Historic Preservation Act
Section 106 of the National Historic Preservation Act requires federal agencies to take into account the effects of their undertakings on historic properties. It is important to note that historic properties include properties of traditional religious and cultural importance to an Indian tribe or Native Hawaiian organization that meet the National Register criteria (36 CFR Section 800.16[I]).

The Proposed Project will be held to the requirements of the National Historic Preservation Act.

Traditional Cultural Properties and Traditional Cultural Landscapes Traditional cultural properties are properties associated with cultural practices or beliefs of a living community that are: (1) rooted in that community’s history; and (2) important in maintaining the continuing cultural identity of a community. Traditional cultural properties can refer to properties of importance to any community, including indigenous communities.

Traditional cultural landscapes encompass the same meaning and utility, as well as inclusivity of indigenous communities. The Secretary of the Interior’s Guidelines for the treatment of cultural landscapes define a cultural landscape as “a geographic area (including both cultural and natural resources and the wildlife or domestic animals therein), associated with a historic event, activity, or person or exhibiting other cultural or aesthetic values” (Birnbaum and Peters 1996).

If a property is determined to be a traditional cultural property, it becomes the responsibility of the lead agency to assess whether the proposed project would have an effect on the property, and should the effect be adverse, would it alter or destroy the elements that make the property significant and eligible.

If a proposed project is determined to have an adverse effect, the lead agency is responsible for seeking measures that would mitigate the adverse effects to traditional cultural properties.

The Proposed Project will be held to the principles of traditional cultural properties and traditional cultural landscapes.

3.17.2.2 State
Tribal Cultural Resources
As defined at PRC Section 21074, a TCR is a site, feature, place, cultural landscape, sacred place or object that is of cultural value to a California Native American tribe and is either: (1) on or eligible for the CRHR or a local historic register; or (2) the lead agency, at its discretion, chooses to treat the resource as a TCR. TCRs are similar to traditional cultural properties in terms of their characteristics, identification, and treatment, and may include a cultural landscape to the extent that the landscape is geographically defined in terms of the size and scope of the landscape. Additionally, as defined at PRC 516
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 337
Section 21074, a historical resource, a unique archaeological resource, or a non-unique archaeological resource may also be a TCR if it conforms to the criteria of a TCR in PRC Section 21074(a). CEQA mandates that lead agencies determine whether a project will have a significant impact on TCRs that are eligible for listing on the CRHR (i.e., a historical resource), or are determined to be significant by the lead agency in order to appropriately mitigate any such impacts.

In accordance with CEQA guidelines, cultural resources investigations are necessary to identify TCRs that may have significant impacts as a result of a project (14 CCR Section 15064.5). The following steps are routinely implemented in a cultural resources investigation for CEQA compliance:

5. Identify cultural resources in the proposed project area

6. Evaluate against the CRHR criteria of significance (listed below)

7. Evaluate the impacts of the proposed project on all cultural/tribal resources

8. Develop and implement measures to mitigate proposed project impacts on historical resources or resources deemed significant by the lead agency
As TCRs hold cultural value to a California Native American tribe, consultation with local Native American tribes is an integral component of each of the cultural resources investigation steps described above.

The Proposed Project will be held to the regulatory requirements imposed by CEQA Statutes and further explained in CEQA Guidelines.

Assembly Bill 52 and Consultation
The lead agency for CEQA is responsible for consultation with Native American tribes regarding the potential for a project to impact TCRs, pursuant to AB 52 and PRC Sections 21073, 21074, 21080.3.1, 21080.3.2, 21082.3, 21083.09, 21084.2, 21084.3, and 5097.94(m). AB 52 recognizes that “…tribes may have expertise with regard to their tribal history and practices, which concern the tribal cultural resources with which they are traditionally and culturally affiliated…” and that consultation will occur between a lead agency and Native American tribes for covered projects.

As described in Section 0, Cultural Resources, a proposed project may induce a significant impact to a historical resource, unique archaeological resource, or a TCR if it causes a substantial adverse change (i.e., physical demolition, destruction, relocation, or alteration) to the resource or immediate surroundings (14 CCR Section 15064.5[b]), thereby demolishing or significantly altering the physical characteristics that qualify it for listing on the CRHR or local registers (PRC Sections 5020.01[k] and 5024.1[g]). A project that may cause a substantial adverse change in the significance of a TCR is a project that may have a significant effect on the environment (PRC Section 21084.2). A lead agency will establish measures to avoid impacts that would alter significant characteristics of a TCR, when feasible (PRC Section 21084.3).

As such, the Town is committed to working together with tribes and consultation efforts with California Native American tribes are described below.

The Proposed Project will be held to the requirements set forth by AB 52. 517
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 338
Native American Historical, Cultural, and Sacred Sites
Pursuant to PRC Section 5097.94 the NAHC has authority and duty to “identify and catalog places of special religious or social significance to Native Americans and known graves and cemeteries of Native Americans on private lands” and has the power and duty to make recommendations for acquisition by the state or other public agencies regarding Native American sacred places that are located on private lands, are inaccessible to Native Americans, and have cultural significance to Native Americans.

The Proposed Project will be held to the requirements set forth by PRC Section 5097.94.

California Native American Graves Protection and Repatriation Act The California Native American Graves Protection and Repatriation Act of 2001 requires all state agencies and museums that receive state funding and that have possession or control over collections of human remains or cultural items to provide a process for the identification and repatriation of these items to the appropriate tribes.

The Proposed Project will be held to the requirements set forth by this act.

Senate Bill 18
SB 18 provides California Native American tribes an opportunity to participate in local land use decisions at an early planning stage for the purpose of protecting or mitigating impacts to cultural places. SB 18 requires local governments to consult with tribes prior to making certain planning decisions, including the adoption and amendment of general plans.

The Proposed Project will be held to the requirements set forth by SB 18.

3.17.2.3 Regional and Local
Town of Paradise General Plan
The Town of Paradise General Plan (Town of Paradise and Quad Consultants 2008) includes the following goals and policies related to TCRs that are relevant to the Proposed Project:
 Goal OCEG-9: Identify, record, preserve, and protect historical and archaeological resources.  Policy OCEP-36: The Land Use Constraints Diagram identifies areas of potential archaeological sensitivity. Proposed development or public works projects within this area will be required to undertake an archaeological survey prior to project approval. Proposed projects outside this area, in locations that have not been significantly disturbed, will be referred to the California Archaeological Inventory, Northeast Information Center, California State University, Chico to undertake an archaeological survey prior to project approval upon recommendation by the Center.
 Implementation Measure OCEI-18: Require compliance of all development projects with Appendix K (archeological impacts) of the Guidelines for Implementation of the California Environmental Quality Act.
 Implementation Measure OCEI-19: When an archaeological survey is required by the Town or recommended by the California Archaeological Inventory, Northeast Information Center, the survey will be undertaken by a qualified professional archaeologist who is certified by the Society of Professional Archaeologists or has equivalent qualifications. 518
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 339
 Implementation Measure OCEI-20: Should any historic or pre-historic artifacts be discovered during construction, all work will cease until a qualified professional archaeologist views the site, provides recommendations and gives clearance to continue.

The Proposed Project will be held to the goals, policies, and implementation measures in the Town of Paradise General Plan.

Butte County General Plan 2030
The Butte County General Plan 2030 (Butte County 2012) includes the following policies related to TCRs that are relevant to the Proposed Project:
 Policy COS-P14.1: Historic and cultural resources management will be coordinated with nearby jurisdictions, including the five incorporated municipalities, the Lassen and Plumas National Forests, other planning and regulatory agencies, and local tribes.  Policy COS-P14.2: As part of CEQA and NEPA projects, evaluations of surface and subsurface cultural resources in the county will be conducted. Such evaluations should involve consultation with the Northeast Information Center.
 Policy COS-P14.3: The Northeast Information Center and appropriate historic and preservation professionals will be consulted when considering reuse of historic sites.  Policy COS-P15.1: Areas found during construction to contain significant historic or prehistoric archaeological artifacts will be examined by a qualified consulting archaeologist or historian for appropriate protection and preservation. Historic or prehistoric artifacts found during construction will be examined by a qualified consulting archaeologist or historian to determine their significance and develop appropriate protection and preservation measures.  Policy COS-P15.2: Any archaeological or paleontological resources on a development project site will be either preserved in their sites or adequately documented as a condition of removal.

When a development project has sufficient flexibility, avoidance and preservation of the resource will be the primary mitigation measure.
 Policy COS-P15.3: Demolition permit application on potentially important historic sites will be subject to discretionary review.
 Policy COS-P16.2: Impacts to the traditional Native American landscape will be considered during California Environmental Quality Act or National Environmental Protection Act review of development proposals.
 Policy COS-P16.3: Human remains discovered during implementation of public and private development projects will be treated with dignity and respect. Such treatment will fully comply with the federal Native American Graves Protection and Repatriation Act and other appropriate laws.
 Policy COS-P16.4: If human remains are located during any ground disturbing activity, work will stop until the County Coroner has been contacted, and, if the human remains are determined to be of Native American origin, the NAHC and most likely descendant have been consulted.
 Policy COS-P16.5: Consistent with State local and tribal intergovernmental consultation requirements such as SB18, the County will consult with Native American tribes that may be interested in proposed new development projects and land use policy changes. 519
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 340
The Proposed Project will be held to the policies in the Butte County General Plan 2030.

Memorandum of Understanding between the City of Chico and Mechoopda Indian Tribe A Memorandum of Understanding has been established between the City of Chico and Mechoopda Indian Tribe of Chico Rancheria, describing the original relationship to the land. The Memorandum of Understanding establishes framework for consultation between the City of Chico and Mechoopda Indian Tribe prior to development of new open space or land use plans, per SB 18, to best protect cultural resources in the City of Chico and all of its open spaces through government-to-government communication.

The Proposed Project will be held to the principles set forth by this memorandum of understanding.

Chico 2030 General Plan
The Chico 2030 General Plan (City of Chico 2017) includes the following policies related to cultural resources that are relevant to the Proposed Project:
 Policy CRHP-1.1, Historic Preservation Program: Maintain a comprehensive Historic Preservation Program that includes policies and regulations which protect and preserve the archeological, historical, and cultural resources of Chico.  Policy CRHP-2.3, Demolition as Last Resort: Limit the demolition of historic resources to an act of last resort, to be permitted only if: 1) rehabilitation of the resource is not feasible; 2) demolition is necessary to protect the health, safety, and welfare of its residents; or 3) the public benefits outweigh the loss of the historic resource.
 Policy CRHP-3.1, Partnerships to Preserve Heritage Resources: Foster partnerships with interested parties to preserve heritage resources.

The Proposed Project will be held to the policies in the Chico 2030 General Plan.

City of Chico Historic Preservation Ordinance
The Historic Preservation Ordinance of the City of Chico’s Municipal Code (Chapter 19.37) specifically affords protection for properties listed on the City of Chico’s Historic Resources Inventory and provides a mechanism to add historic properties to the Inventory through Landmark Overlay zoning districts. The ordinance also provides development incentives to owners of designated historic property and establishes a number of exempt activities such as ordinary maintenance and repair.

The Proposed Project will be held to the requirements of the City of Chico’s Historic Preservation Ordinance.

California State University, Chico Research Foundation Ecological Reserves Management Plan, Memorandums of Understanding and Agreement
California State University, Chico has implemented a management plan for the Butte Creek Canyon Ecological Reserve, which consists of a 287-acre property comprising two units, the Virgin Valley and Canyon Units, located along Butte Creek. According to the management plan, a number of cultural resources indicative of historical and pre-contact occupation are likely to occur on Butte Creek Canyon Ecological Reserve lands based on cultural resource inventories conducted on adjoining lands with similar landscape and habitat.
520
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 341
The Mechoopda Indian Tribe is a partner with California State University, Chico to the Memorandum of Agreement Regarding Guiding Principles for CSU, Chico Consultation with the Mechoopda Indian Tribe of Chico Rancheria (2018) with commitments for consultation and development of a cultural resources plan regarding the recognized ancestral lands of the Mechoopda Indian Tribe that encompass the California State University, Chico campus. The Mechoopda Indian Tribe is also partner with Chico State Enterprises to the Memorandum of Understanding between the Mechoopda Indian Tribe of Chico Rancheria and Chico State Enterprises (2020) for Chico State Enterprises-administered lands, which include the Big Chico Creek Ecological Reserve and the Butte Creek Ecological Preserve. The Proposed Project intersects with the Butte Creek Ecological Preserve.

The Proposed Project will be held to the principles of the management plan and memorandum of agreement implemented by California State University, Chico.

3.17.3 Method of Analysis
This section describes the methods used to analyze impacts on TCRs within the study area.

3.17.3.1 CEQA Significance Criteria
For the purposes of this PEIR, the Proposed Project would result in a significant impact on TCRs if it would:
 Impact TCR-1: Cause a substantial adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, or 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:
o Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k), or o 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 PRC Section 5024.1. In applying the criteria set forth in subdivision (c) of PRC Section 5024.1, the lead agency will consider the significance of the resource to a California Native American tribe.

3.17.3.2 Approach to Analysis
Identification of Tribal Cultural Resources
As discussed above, a TCR is a site, feature, place, cultural landscape, sacred place, or object that is of cultural value to a California Native American tribe and is either: (1) on or eligible for listing in the CRHR or a local historic register; or (2) the lead agency, at its discretion, chooses to treat the resource as a TCR (PRC Section 21074). Under CEQA Guidelines, even if a resource is not included on any local, state, or federal register, or identified in a qualifying historical resources survey, a lead agency may still determine that any resource is a historical resource (i.e., TCR) for the purposes of CEQA, if there is substantial evidence supporting such a determination (CEQA Guidelines Section 15064.5[a]). A lead agency must consider a resource to be historically significant if it finds that the resource meets the criteria for listing in the CRHR.
521
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 342
For the Proposed Project, the evaluation of archaeological sites identified in Section 3.5.1.5 has considered the archaeological significance of the resources currently identified, as well as cultural value significance to Native American tribes. Consideration of significance by the communities for which the resources hold value is especially critical when historic properties are evaluated under Criterion D, as mainstream archaeological notions of “information potential” do not account for tribal perspectives, values, and practices associated with traditional knowledge and their indelible connections to historic properties and heritage and cultural resources. National Register Bulletin 38 states that “[p]roperties that have traditional cultural significance often have already yielded, or have the potential to yield, important information through ethnographic, archeological, sociological, folkloric, or other studies” (Parker and King 1998:14). While information potential may align with and/or be supported by Western scientific methods and criteria, such as those applied and pursued by archaeology, ethnography, folk studies, history/ethnohistory, geography, or other cognate disciplines, for Indigenous communities, Criterion D information potential eligibility must include the events, lessons, figures, and processes associated with the cosmology and Tribally defined protocols, standards, and approaches to information and knowledge production.

The Butte County General Plan 2030 indicates that there “are a number of Native American sacred sites located throughout the county” and also recognizes the importance of viewshed areas with particular importance noted for the Butte Creek Canyon, which is immediately adjacent to the Proposed Project area (Butte County 2012). According to the Butte County General Plan 2030, “the Skyway provides views to a dramatic and panoramic display of the topographic and geologic features of Butte Creek Canyon. A portion of this canyon is protected as an ecological reserve by the State Department of Fish and Game” (Butte County 2012). The ecological reserve is the above-mentioned Butte Creek Canyon Ecological Reserve, which consists of a 287-acre property comprising two units, the Virgin Valley and Canyon Units, located along Butte Creek.

Based on background research, archaeological analysis discussed above in Section 0, and consultation efforts discussed below, including a search of the NAHC’s Sacred Lands File, there is potential for TCRs to be located within the Proposed Project area. To date, no CRHR-eligible or listed TCRs have been identified within the Proposed Project area; however, it is important to acknowledge that absence of identification in these efforts does not correlate with an absence of TCRs.

Tribal Consultation
To help determine whether a project may have a significant effect on TCRs, PRC Section 21080.3.1 requires a lead agency to consult with any California Native American tribe that requests consultation and is traditionally and culturally affiliated with the geographic area of a proposed project. As such, Native American tribes were consulted to determine the presence of TCR in the study area.

Pursuant to PRC Section 21080.3.1 and in support of AB 52, consultation efforts with Native American tribal contacts have been incorporated in the cultural resources’ investigation of the study area, as “California Native American tribes traditionally and culturally affiliated with a geographic area may have expertise concerning their tribal cultural resources” (PRC Section 21080.3.1[a]). Pursuant to PRC Section 21080.3.1(b), lead agencies are required to send notifications of proposed projects to California Native American tribes that have requested in writing to be informed of proposed projects for consultation.
522
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 343
To date, no tribes have requested notification of the opportunity to consult with the Town on the Proposed Projects pursuant to the PRC; however, the Town seeks to engage with potentially interested tribal contacts for current consultation efforts and as such contacted the NAHC on June 29, 2020, and April 26, 2021, to request a list of California Native American tribes and organizations that may have an interest in the Proposed Project pursuant to PRC Section 21080.3.1(c), as well as to request a search of the Sacred Lands File. The NAHC responded on July 1, 2020, and April 27, 2021, providing a list of tribes that have cultural and traditional affiliation to the Proposed Project area, shown in Table 3.17-1.

The NAHC also reported that their search of the Sacred Lands File yielded negative results, although that does not mean there are not significant resources within the Proposed Project area. The NAHC’s letter is provided in Appendix G Tribal Consultation.

The Town subsequently mailed courtesy letters on May 10, 2021, to potentially interested tribes listed in Table 3.17-1 in order to provide an opportunity to request such notification from the Town (Appendix G Tribal Consultation). As a result of these courtesy correspondence efforts, Chairperson Jessica Lopez of the Konkow Valley Band of Maidu responded via phone call on May 14, 2021, indicating that the tribe would like to consult on the Proposed Project pursuant to AB 52. Kyle McHenry, THPO for the Mechoopda Indian Tribe, responded to the letter via phone call and email on May 25, 2021, to initiate consultation regarding the Proposed Project. To date, no response has been received from the Mooretown Rancheria of Maidu Indians regarding consultation for the Proposed Project.

Table 3.17-1. Tribes and Tribal Representatives Identified by the Native American Heritage Commission Who May Have an Interest in the Project
Tribe Tribal Representative
Konkow Valley Band of Maidu Jessica Lopez, Chairperson
Mechoopda Indian Tribe of Chico Rancheria Dennis Ramirez, Chairperson Kyle McHenry, Tribal Historic Preservation Officer (THPO) Mooretown Rancheria of Maidu Indians Benjamin Clark, Chairperson Guy Taylor, Representative
The Town and its consultant, HDR, coordinated with the Konkow Valley Band of Maidu and Mechoopda Indian Tribe via emails and phone calls for an initial consultation meeting held on August 10, 2021, via web meeting. Both Konkow Valley Band of Maidu and Mechoopda Indian Tribe agreed to a joint consultation meeting as the Tribes have a collaborative and cooperative relationship for the management of projects that fall within their adjacent and overlapping geographic and cultural areas of interest. During the initial consultation meeting, the Proposed Project overview was discussed, and conversations were held in response to questions from both tribes. The Town and HDR provided confidential meeting notes to all participants of this meeting, as well as materials requested for further review by the Tribes. A subsequent joint-consultation meeting was coordinated via email and phone calls, and held on September 9, 2021, via web meeting. Both tribes indicated that they had each reviewed the materials provided by the Town. Kyle McHenry identified a concern for potential Projectrelated impacts in sensitive areas and requested incorporation of measures for the Proposed Project to retain Tribal Cultural Monitors during construction activities in sensitive areas designated by the tribes.

Chairperson Jessica Lopez stated a concern for sensitive plant species that may be considered TCR and requested relevant biological assessment information for review, in order to provide any necessary 523
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 344
information related to TCR identification or impact avoidance. The Town agreed to provide the biological assessment information, as well as the draft TCR section language to both Tribes for review.

Additional phone calls and emails were exchanged, and as a result, updates were made to the cultural resources report to address concerns regarding the potential for rediscovery of cultural resources that had been previously recorded but not relocated during survey. Matthew Gramps-Williford, Vice Chair and Cultural Resources Director of the Konkow Valley Maidu Band, requested an in-person consultation meeting with the Town and HDR. The meeting was held on December 20, 2021, at the Town’s offices. Chairperson Lopez concluded AB 52 consultation on January 13, 2022, and THPO Kyle McHenry concluded AB 52 consultation on January 14, 2022, with the understanding that communication between the Town and the respective Konkow Valley Band of Maidu and Mechoopda Indian Tribe will continue with regard to the commitments made in this report, which include coordination with both Tribes for identifying sensitive areas and Tribal Cultural Monitoring during construction.

As part of continued communication, the Town reached out to the Tribes on April 7, 2022, via email from HDR, to solicit input and hear concerns regarding potential impacts to TCRs caused by a change to the pipeline alignment for the Proposed Project (Appendix G Tribal Consultation).

3.17.4 Impact Analysis

3.17.4.1 Impact TCR-1: Cause a substantial adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, or 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:
 Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k), or  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 PRC Section 5024.1. In applying the criteria set forth in subdivision (c) of PRC Section 5024.1, the lead agency will consider the significance of the resource to a California Native American tribe (Less than Significant Impact with Mitigation Incorporated)
Construction
Under CEQA, a project with an impact that may cause a substantial adverse change in the significance of a TCR is a project that may have a significant effect on the environment. Substantial adverse change in the significance of a TCR is defined as physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of a TCR would be materially impaired. The significance of a TCR would be significantly impaired when a project demolishes or materially alters in an adverse manner those physical characteristics of a TCR that convey its significance and that justify its eligibility for inclusion in the NRHP, the CRHR, a local register of historical resources pursuant to PRC Section 5020.1(k), or historical resources surveys meeting the requirements of PRC Section 5024.1(g).
524
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 345
Impacts on a TCR are likely to be associated with construction of the Core Collection System, Export Pipeline System, and the Extended Collection System. Excavation and ground disturbing activities as a result of these construction activities have the potential to impact newly identified and previously unknown TCRs in the study area.

Although no CRHR-eligible TCRs have been identified within the Proposed Project area, it has been made clear by the Tribes that there is the potential for TCRs to exist within the Proposed Project area.

This is considered a potentially significant impact.

Mitigation. To minimize potentially significant impacts on TCRs during construction of the Proposed Project to a less than significant level, mitigation measures MM-TCR-1 and MM-TCR-2 will be implemented.

MM-TCR-1: Coordination with Konkow Valley Band of Maidu and Mechoopda Indian Tribe.

During final design, the Town will continue to consult and coordinate with the Konkow Valley Band of Maidu and Mechoopda Indian Tribe to identify sensitive areas to be protected during construction work and appropriate methods to protect those areas.

MM-TRC-2: Tribal Cultural Monitoring. Prior to construction, the Town will coordinate with the Konkow Valley Band of Maidu and Mechoopda Indian Tribe to identify a Tribal Cultural Monitor, as deemed necessary by either/both Tribes, to be present during ground disturbance work within areas designated as sensitive for tribal cultural resources.

Significance after Mitigation. Implementation of MM-TRC-1 and MM-TRC-2 would reduce potentially significant impacts on TCRs resulting from inadvertent damage or destruction of unknown TCRs during construction to a less than significant level because appropriate procedures would be followed to ensure that any unanticipated cultural resources discovered during Project-related ground-disturbing activities are appropriately handled and documented in consultation and coordination with the Tribes.

Operation and maintenance activities, as described in Section 2.8, would not include ground disturbing activities except if there were a pipe break and a section of pipeline needed to be replaced. Operation and maintenance activities would mostly occur in previously disturbed areas (within paved roads), resulting in no potential to impact TCRs. In the case of a pipe break, the section would be repaired and returned to previous conditions as expeditiously as possible so as to limit impacts to the public and sewer service. Therefore, operation and maintenance of the Proposed Project would result in a less than significant impact on TCRs.
525
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 346
Mitigation. No mitigation required.

3.17.5 Impacts Summary
Table 3.17-2 summarizes the tribal cultural resources impacts of the Proposed Project.

Table 3.17-2. Tribal Cultural Resources Impacts Summary Impact Level of Significance
Before Mitigation Mitigation
Level of Significance
with Mitigation
Incorporated
Impact TCR-1: Cause a substantial adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, or 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:
 Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k), or
 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 PRC Section 5024.1. In applying the
criteria set forth in subdivision (c) of PRC Section
5024.1, the lead agency will consider the significance
of the resource to a California Native American tribe
SI MM-TCR-1
MM-TCR-2
S/M
Notes: LTS = Less than Significant Impact, NI = No Impact, N/A = Not Applicable, SI = Significant Impact, S/M = Significant Impact but Mitigable to a Less-than-Significant Level

3.17.6 References
Birnbaum, Charles and Peters, Christine. 1996. The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for the Treatment of Cultural Landscapes. US Department of the Interior, National Park Service, Cultural Resource Stewardship and Partnerships, Heritage Preservation Services, Historic Landscape Initiative: Washington D.C.

City of Chico. 2017. Chico 2030 General Plan. Adopted April 2011. Amended March 2017. https://chico.ca.us/post/chico-2030-general-plan.

Konkow Maidu Cultural Preservation Association. 2021. “About Us.” Accessed September 20, 2021. http://maidu.org/about.html.

Mechoopda Indian Tribe of Chico Rancheria. 2021. “Culture.” Accessed September 20, 2021. https://www.mechoopda-nsn.gov/culture/.
526
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 347
Parker, Patricia L., and Thomas F. King. 1998. Guidelines for Evaluating and Documenting Traditional Cultural Properties. National Register Bulletin 38. US Department of the Interior, National Park Service. https://www.nps.gov/subjects/nationalregister/upload/NRB38-Completeweb.pdf.

Town of Paradise and Quad Consultants. 2008. Town of Paradise 1994 General Plan. Prepared for Town of Paradise Community Development Department. Amended January 2008. https://www.townofparadise.com/sites/default/files/fileattachments/planning/page/3251/townofp aradise-generalplan_1994.pdf.
527
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 348

3.18 Utilities and Service Systems
This section describes the environmental setting and regulatory framework for utilities and service systems, and it identifies direct and indirect impacts of the Proposed Project during construction, operation, and maintenance on utilities and service systems. In particular, the utilities and service systems analysis focuses on energy and electric infrastructure (electric substations and transmission lines), telecommunications (cable, telephone or broadcasting infrastructure), water supply and services, wastewater facilities, and solid waste services (waste facilities and disposal sites) within the study area.

For the purposes of this PEIR, the study area for utilities and service systems refers to the areas within and directly adjacent to the Town and areas of unincorporated Butte County and the City where the proposed pipeline alignment runs, and the utility service areas within these jurisdictions.

3.18.1 Environmental Setting
This section describes the utilities in the County as a whole, followed by the existing utilities in the Town and the City. Utilities and service systems within the study area are discussed and organized by jurisdiction (Butte County, Town of Paradise, and City of Chico). Electric infrastructure is discussed regionally, as the transmission lines span these respective jurisdictions. Landfills are also discussed regionally given that many are available for use by multiple jurisdictions. Telecommunication and fiber optic services are provided by private companies in the County. Table 3.18-1 summarizes utility providers in the County, the Town, and the City. These services are described in further detail in the following sections.

Table 3.18-1. Summary of Utility Providers in the Study Area Utility Service Butte County Town of Paradise City of Chico Water Paradise Irrigation District California Water Service Wastewater Septic Systems Chico WPCP
Energy PG&E
Western Area Power
Administration
Western Electricity Coordinating
Council

PG&E PG&E
Solid Waste and
Recycling
Neal Road Recycling and Waste
Facility
Northern Recycling and Waste
Services (residential waste
services)
North Valley Waste
Management (residential waste
services)
Household
Hazardous Waste
Butte Regional Household
Hazardous Waste Facility
Recology
Paradise Household Hazardous
Waste Collection Facility
Butte Regional Household
Hazardous Waste Facility
Fiber Optic Private Companies Private Companies Private Companies Telecommunication Private Companies Private Companies Private Companies

3.18.1.1 Butte County Utilities and Service Systems
The proposed Export Pipeline System would follow several Western Electricity Coordinating Council transmission lines, a 60 kilovolt (kV) PG&E transmission line, 115kV PG&E transmission line, 500kV PG&E transmission line, and Western Area Power Administration 203kV transmission line. The 528
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 349
Western Electricity Coordinating Council is a non-profit corporation that exists to assure a reliable Bulk Electric System in the geographic area known as the Western Interconnection, which includes 2 Canadian provinces, 14 western states, and Northern Baja Mexico (Western Electricity Coordinating Council 2015). PG&E is one of the largest combined natural gas and electricity energy companies in the United States. The company provides natural gas and electric service to approximately 16 million people throughout a 70,000-square-mile service area in northern and central California (PG&E 2021).

Western Area Power Administration is one of four power marketing administrations within the US Department of Energy. Their role is to market and transmit wholesale electricity from multi-use water projects. Their service area includes a 15-state region of the central and western United States (Western Area Power Administration 2021).

The County and the City have entered into a Joint Powers agreement, which intends to provide residents of the unincorporated area of the County, as well as the City, the ability to choose where they purchase their energy.

The Butte County Department of Public Works provides solid waste disposal services at the Neal Road Recycling and Waste Facility. For household hazardous waste, the County also uses the Butte Regional Household Hazardous Waste Facility in the City, as well as the Recology facility in Oroville (Butte County 2021f). Table 3.18-2 provides the capacity information for the Neal Road Recycling and Waste Facility.

Table 3.18-2. Butte County Solid Waste Landfill and Capacity Information Landfill Max. Permitted
Throughput
Remaining
Capacity
Max. Permit
Capacity
Remaining Capacity
Date
Unit of
Measure
Neal Road Recycling
and Waste Facility
1,500 20,847,970 25,271,900 7/1/2009 Tons (per day)
Source: CalRecycle 2022

3.18.1.2 Town of Paradise Utilities and Service Systems Paradise receives a safe, dependable supply of potable water through PID. Prior to the Camp Fire, PID delivered water to approximately 11,500 municipal and residential/commercial parcels within Paradise.

Paradise’s current wastewater system consists of individual, privately owned septic tanks and leach fields, together with several engineered subsurface disposal systems to serve commercial and institutional facilities. There are currently no existing connections to a centralized wastewater management facility. As discussed in Section 0, Hydrology and Water Quality, the Town operates under a NPDES Small MS4 Permit for stormwater discharges.

The Town uses Northern Recycling and Waste Services for weekly residential waste collection services and bi-weekly recycling and yard waste services (Northern Recycling and Waste Services 2010).

Northern Recycling and Waste Services provides its services throughout the County, which also includes weekly commercial refuse and recycling services. In addition, the Town has a Household Hazardous Waste Collection Facility to dispose unusable hazardous products as well as a vegetative waste yard. Northern Recycling and Waste Services provides commercial and residential debris box services for recycling, yard waste, construction and demolition and solid waste. However, due to 529
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 350
unforeseen circumstances, the service center and Household Hazardous Waste Facilities operations are closed until further notice.

PG&E is the service provider for natural gas and electricity for the Town. PG&E is currently in the process of relocating their power lines underground in the Town to create an underground utility district.

3.18.1.3 City of Chico Utilities and Service Systems
The City receives its supply of water through California Water Service (Cal Water). For the City, Cal Water uses 68 wells to pump an average of 27 million gallons of groundwater per day. The water is then delivered to residents through 373 miles of pipeline, eight storage tanks, and nine booster pumps (Cal Water 2021).

Wastewater in the City is treated at the Chico WPCP. The Chico WPCP is a 12 mgd capacity, secondary treatment, activated sludge, wastewater plant with future expandability of up to 15 mgd (City of Chico 2021a). The Chico WPCP operates and maintains 15 sewer life pump stations that pump wastewater from areas in the City that do not have the ability to gravity flow through the wastewater collection system. For sewer water maintenance, the City currently uses a three-step program that abides by the City of Chico’s Sanitary System Management Plan (City of Chico 2021e). This includes zone maintenance, camera inspection of pipelines, and regular interval maintenance. These steps will be conducted and maintained by the Chico Public Works department.

The City uses the North Valley Waste Management to provide residential solid waste and recycling services within the City limits. Household hazardous waste is accommodated by the Butte Regional Household Hazardous Waste Facility in Chico (City of Chico 2021f).

PG&E is the service provider for natural gas and electricity for the City.

3.18.2 Regulatory Framework
This section summarizes the federal, state, regional, and local laws, regulations, policies, and plans relevant to evaluation of the Proposed Project’s impacts on utilities and service systems. Additional information on the relevant regulations, laws, and plans is provided in Appendix C, Regulatory Framework.

3.18.2.1 Federal
Clean Water Act
The CWA establishes the basic structure for regulating discharges of pollutants into the waters of the United States and regulating quality standards for surface waters. The USEPA implemented pollution control programs under the CWA that sets wastewater standards for the industry.

The Proposed Project will be subject to surface water quality and wastewater standards under the CWA.
530
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 351

3.18.2.2 State
California Integrated Waste Management Act
The California Integrated Waste Management Act (AB 939, Sher, Chapter 1095, Statutes of 1989 as amended) made all California cities, counties, and approved regional solid waste management agencies responsible for enacting plans and implementing programs to divert 25 percent of their solid waste by 1995 and 50 percent by the year 2000. Later legislation mandates the 50 percent diversion requirement be achieved every year. In September 2016, the State Legislature set short-lived climate pollutant reduction targets for California in SB 1383. SB 1383 establishes statewide targets to reduce the amount of organic waste disposal in landfills (that is, 50% reduction by 2020 and 75% reduction by 2025).

Waste generated by the Proposed Project will be subject to the California Integrated Waste Management Act and associated targets.

3.18.2.3 Regional and Local
Town of Paradise General Plan
The Proposed Project is subject to policies, goals and actions outlined in the Town of Paradise General Plan. The Town of Paradise General Plan (Town of Paradise and Quad Consultants 2008) includes the following policies related to utilities and service systems that are relevant to the Proposed Project:
 Policy LUP-12: The character of future development should be compatible with the Town’s service delivery abilities and will not result in service level declines.  Policy LUP-13: The Town will attempt to assure that the rate and character of growth is commensurate with, or does not exceed the current levels of public services, and will attempt to assure that municipal services can be provided to areas planned for annexation and development.

Butte County General Plan 2030
The Proposed Project is subject to policies, goals and actions outlined in the Butte County General Plan 2030. The Butte County General Plan 2030 (Butte County 2012) includes the following goals and policies related to utilities and service systems that are relevant to the Proposed Project:
 Goal PUB-9: Provide safe, sanitary and environmentally acceptable solid waste management.  Goal PUB-11: Increase recycling among Butte County residents, businesses, and public agencies.
 Goal PUB-12: Manage wastewater treatment facilities at every scale to protect the public health and safety of Butte County residents and the natural environment.  Policy PUB-P11.2: Construction sites will provide for the salvage, reuse, or recycling of construction and demolition materials.
 Policy W-P1.8: The County supports conversion from septic systems to public sewer service, where feasible.
 Policy PUB-P12.4: New sewer collection and transmission systems will be designed and constructed to minimize potential inflow and infiltration. 531
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 352
 Policy PUB-P13.4: Installation of sewer lines will occur concurrently with construction of new roadways to maximize efficiency and minimize disturbance from construction activity.  Policy HS-P15.2: Critical emergency response facilities such as fire, police, emergency service facilities and utilities will be sited to minimize their exposure to flooding, seismic effects, fire, or explosion.

Chico 2030 General Plan
The Proposed Project is subject to policies, goals and actions outlined in the Chico 2030 General Plan.

The Chico 2030 General Plan (City of Chico 2017) includes the following policies related to utilities and service systems that are relevant to the Proposed Project:
 Goal PPFS-4: Maintain a sanitary sewer system that meets the City’s existing and future needs, complies with all applicable regulations, and protects the underlying aquifer.  Goal PPFS-8: Ensure that solid waste and recyclable collection services are available to City residents.
 Policy SUS-3.3, Municipal Waste Reduction: Reduce consumption and increase recycling and reuse of materials in City operations.
 Policy PPFS-4.1, Sanitary Sewer System: Improve and expand the sanitary sewer system as necessary to accommodate the needs of existing and future development.  Policy PPFS-4.3, Capacity of Water Pollution Control Plant: Increase system capacity by reducing wet weather infiltration into the sanitary sewer system.  Policy PPFS-4.4, Wastewater Flows: Ensure that total flows are effectively managed within the overall capacity of the Water Pollution Control Plant.

3.18.3 Method of Analysis
This section describes the methods used to analyze utilities and service systems within the study area.

3.18.3.1 CEQA Significance Criteria
For the purposes of this PEIR, the Proposed Project would result in a significant impact on utilities and service systems if it would:
 Impact UTIL-1: Require or result in the relocation or construction of new or expanded water, wastewater treatment, storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects  Impact UTIL-2: Have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry years  Impact UTIL-3: Result in a determination by the wastewater treatment provider, which serves or may serve the Project, that it has inadequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments
 Impact UTIL-4: 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  Impact UTIL-5: Comply with federal, state, and local management and reduction statutes and regulations related to solid waste
532
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 353

3.18.3.2 Approach to Analysis
Construction, Operation and Maintenance
Impacts on utilities and service systems were identified qualitatively based on the Proposed Project’s potential to disturb or stress the capacity of existing utility/service infrastructure such as, water supply, wastewater, storm water, electric power, natural gas, and solid waste. For the purposes of this resource analysis, information was collected on utility providers and service systems and using the following sources:
 Butte County and City of Chico websites (Butte County 2013; City of Chico 2021a, 2021e)  PID website (PID 2021)
 Northern Recycling Waste Services website (Northern Recycling and Waste Services 2010)  CEC’s California Electric Infrastructure interactive GIS map (CEC 2021c)  Butte County General Plan 2030 (Butte County 2012)
 Town of Paradise General Plan (Town of Paradise and Quad Consultants 2008)  Chico 2030 General Plan (City of Chico 2017)
The analysis of environmental effects focuses on foreseeable changes to utilities and service systems in the context of effects listed in Section 3.18.3.1, CEQA Significance Criteria. The analysis considers the Core Collection System, Export Pipeline System, and Extended Collection System, as appropriate, in the context of construction, operation, and maintenance.

The following methods were used to evaluate the potential impacts from construction, operation, and maintenance of the Proposed Project on utilities and service systems:
 Use of GIS data provided by CEC, which shows the location of electric substations, transmission lines, and electric transmission lines, to pinpoint the location of electric infrastructure within the study area.
 Analysis of construction methods, ROW, and staging areas.  Analysis of the Project’s consistency with the requirements of all plans, policies, and regulations listed in Section 3.18.2, Regulatory Framework.

3.18.4 Impact Analysis
This section describes the environmental impacts on utilities and service systems as a result of implementation of the Proposed Project. The impact analysis for utilities and service systems focuses on construction of the Proposed Project because the components have the potential to disturb existing utility infrastructure during ground disturbing activities, require the use of water supplies, and generate solid waste and wastewater.

3.18.4.1 Impact UTIL-1: Require or result in the relocation or construction of new or expanded water, wastewater treatment, storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause 533
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 354
significant environmental effects (Less than Significant Impact with Mitigation Incorporated)
Construction
The Chico WPCP is an established secondary treatment, activated sludge, wastewater plant that has an existing capacity of 12 mgd with future expandability of up to 15 mgd (Section 2.4.2 Chico Water Pollution Control Plant; City of Chico 2021a). The annual average flow coming into the Chico WPCP currently is 6.3 mgd (Chico WPCP monitoring data, RWQCB 2021). The Proposed Project would add an additional 0.109 mgd of wastewater to the Chico WPCP influent at the time of initial connection (estimated for 2026) and a maximum of 0.464 mgd at full build-out (estimated for 2057) and would not increase or decrease the availability of sewer service within the City or County. The Regionalization Planning Report for the Paradise Sewer Project determined that the Chico WPCP has adequate capacity to serve the Proposed Project’s projected demand and commitments, in addition to serving the City’s service area within its jurisdictional boundaries (Carollo Engineers 2022). This would include the remaining approximately 3,000 parcels that are not currently connected to the City’s sewer infrastructure but fall under the Chico Urban Area Nitrate Compliance Plan which calls for the termination of all on-site septic systems as a contributor to ground water nitrate contamination (http://www.buttecounty.net/administration/Nitrate-Compliance-ProgramButte County 2000). Based on these factors, the Proposed Project would not stress the capacity of the current system. Therefore, the Proposed Project would not require the construction or relocation of wastewater facilities, nor would it require expansion of the existing Chico WPCP facility.

The proposed Export Pipeline System would follow several Western Electricity Coordinating Council transmission lines, 60kV PG&E transmission line, 115kV PG&E transmission line, 500kV PG&E transmission line, and Western Area Power Administration 203kV transmission line. The proposed pipeline alignment would generally offset powerlines when in parallel to them and when crossing, would cross at a right angle and in between the powerline poles to avoid physical disruptions. Relocation of transmission lines would therefore not be required.

The Proposed Project also involves a fiber-optic conduit as a part of the Export Pipeline System. The Proposed Project would have two below-ground structures along the Export Pipeline System, namely the transition chamber and the flow control and metering structure. These structures would have electrical instruments that will monitor various items, such as water levels, valve positions, and wastewater flow rate. To reliably communicate the signals from those electrical instruments to Paradise and the Chico WPCP, the Proposed Project would install a 2-inch-diameter metal fiber-optic conduit in the same trench as excavated for the Export Pipeline System. The conduit would be placed above the pipelines and would not require additional ground disturbance. The fiber optic cable would be owned and operated by the Town of Paradise and would not interfere with existing fiber optic cables.

There is potential that groundwater would be encountered during construction of the Core Collection System, the Export Pipeline System, and the Extended Collection System. Construction work would also occur around waterbodies. The Proposed Project would involve trenchless crossings underneath Butte Creek, Comanche Creek, and Little Chico Creek via HDD methods. The crossings would be required to have a minimum depth of 20 feet below the waterbody with a launching and receiving pit on either end of the crossing. As discussed in Section 2.5.2 Export Pipeline System, and shown in 534
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 355
Figure 2-12 Typical HDD Installation, there would be an approximate 10- by 5-foot launching and receiving pit and additional protected space on either end of the waterbody. As discussed in Section 0 Hydrology and Water Quality, a SWPPP that includes water quality BMPs will be implemented to prevent water quality degradation and environmental impacts during construction.

Nevertheless, because utilities could be affected during construction of the Proposed Project, with the potential for disruption of utility service, this impact would be significant.

Mitigation. To minimize potentially significant impacts on utility infrastructure during construction of the Proposed Project to a less than significant level, mitigation measure MM-UTIL-1 will be implemented.

MM-UTIL-1: Minimize Utility and Service System Disruptions. During final design, to minimize disruptions to utility services, the Town will prepare a Utility Conflict and Coordination Plan that identifies outages that could affect residents and businesses, including fiber-optic/communications, water, power, and gas. As part of that plan, the public and stakeholders will be notified by signage and on Town’s website of any potential service interruptions at least 2 weeks prior to construction work.

Significance after Mitigation. With implementation of MM-UTIL-1, impacts on utility infrastructure during construction would be less than significant.

Operation and Maintenance
Long-term utility usage would be expected to be similar to pre-Camp Fire levels and within the approved capacities for these services. This would not be a displacement or relocation of utilities, but rather part of the Town’s recovery efforts.

Operations and maintenance activities such as the inspection of the Core Collection System, Extended Collection System, Export Pipeline System, and associated instrumentation would occur periodically throughout the year and would be minimally invasive. As required, the pipelines would be flushed to push deposited material farther down the pipelines and ultimately into the Chico WPCP, which is within the permitted capacity for the Chico WPCP. As discussed under Construction, above, the fiber optic cable would be owned and operated by the Town and would not interfere with existing fiber optic cables during operations and maintenance. Flow measurement data would be transmitted via radio or fiberoptic lines; therefore, visits would not be required to obtain data.

Based on these factors, there would be no relocation or construction of new or expanded water, wastewater treatment, storm water drainage, electric power, natural gas, or telecommunications facilities during operation and maintenance and thus, no impact.

Mitigation. No mitigation required.

3.18.4.2 Impact UTIL-2: Have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years (No Impact)
Construction, Operation, and Maintenance
Potable water in the Town is provided by PID. Water supply required during construction of the Proposed Project will be the responsibility of the construction contractor and would only be required 535
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 356
temporarily for the duration of the construction period. Water would be required for such activities as dust suppression, equipment washing, or contractor potable and non-potable water needs. Water use during operations and maintenance would periodically involve flushing activities, flow monitoring, and flow data and wastewater sampling, as described in Section 2.8, Proposed Operation and Maintenance. No potable water would be required during operation and maintenance of the Proposed Project. There would be no impact on water supply.

Mitigation. No mitigation required.

3.18.4.3 Impact UTIL-3: Result in a determination by the wastewater treatment provider, which serves or may serve the Project, that it has inadequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments (No Impact) Construction
Wastewater would be generated during the construction of the Export Pipeline System, Core Collection System, and Extended Collection System. Water encountered during pit excavation would be placed into a settling tank before being trucked to a nearby sewer main for discharge. Perched water and nuisance water encountered in trenches during construction of the Core Collection System and Extended Collection System would be collected via sump pump to a Baker Tank for settling and reused for truck dust control. As a result, there would be no impact during construction.

Mitigation. No mitigation required.

Operation and Maintenance
Once operational, the Proposed Project would not include changes to the Chico WPCP service area other than the addition of the Core and Extended Collection Systems in the Town. For the purpose of this analysis, both the Core and Extended Collection System would be within the current capacity of the Chico WPCP. The annual average flow coming into the Chico WPCP is 6.3 mgd (Chico WPCP monitoring data, RWQCB 2021); the facility is licensed to treat 12 mgd with future expandability of up to 15 mgd (City of Chico 2021a). The Proposed Project would add an additional 0.464 mgd of wastewater over the 30-year planning horizon to the system during operations; therefore, the Chico WPCP can accommodate current and future estimated growth (Section 2.4.2 Chico Water Pollution Control Plant).

Additionally, during the initial years of the project when fewer connections have been made to the system and wastewater flows are low, the pipelines may be periodically flushed to push deposited material farther down the pipelines and ultimately into the Chico WPCP. The quantity of flushing water would be kept within the allowable discharge to the Chico WPCP (2.8 Proposed Operation and Maintenance). Therefore, the Chico WPCP has adequate capacity to serve the Proposed Project needs and there would be no impact on existing wastewater commitments.

Mitigation. No mitigation required.
536
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 357

3.18.4.4 Impact UTIL-4: 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? (No Impact)
Construction
Solid waste including construction debris, soil and asphalt would be generated during construction of the Core Collection system, Extended Collection System, and the Export Pipeline System. About 169,400 cubic yards of soil would be exported during construction of the Core Collection System. The Export Pipeline System would produce an anticipated 60,800 cubic yards of soil to be exported. Solid waste and construction debris would be transported to a local landfill or another approved location.

Waste could be accommodated by the Neal Road Recycling and Waste Facility in Section 3.18.1. The Proposed Project will comply with both State and local solid waste standards during construction and there would be no impact from solid waste generation.

Mitigation. No mitigation required.

Operation and Maintenance
Project operation and maintenance would not generate additional solid waste. The Proposed Project has the potential to foster population regrowth as a result of Camp Fire recovery efforts; long-term landfill usage would be similar to pre-Camp Fire levels and within the approved capacities.

Under existing conditions, the majority of the 11,500 parcels in the Town use septic tanks. Individual septic tanks in the Town hold approximately 3,000 gallons of septage, and they are pumped out approximately once every 5 years. Septage from the Town is currently hauled to a receiving station at the Neal Road Recycling and Waste Facility and NorCal Environmental Solutions. Once the Proposed Project is operational, the 1,500 parcels connecting to the Core Collection System would no longer require septage disposal at these landfills, which could result in beneficial impacts on solid waste generation in the Town. Chico WPCP produces biosolids, however, these biosolids are not transported to a landfill for disposal. Rather, they are placed back into the environment and recycled in land use applications. Therefore, the Proposed Project would comply with both State and local solid waste standards during operation, and maintenance. There would be no impact as it relates to solid waste generation 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.

Mitigation. No mitigation required.

3.18.4.5 Impact UTIL-5: Comply with federal, state, and local management and reduction statutes and regulations related to solid waste? (No Impact) Construction, Operation, and Maintenance
The Proposed Project complies with federal, state, and local management and reduction statutes and regulations related to solid waste that have been identified in the Section 3.18.2, Regulatory Framework. Additionally, all construction-generated solid waste would be transported to an approved landfill or other approved location, such as a compost facility licensed for biosolids. Table 3.18-3 provides a consistency analysis of these local management and reduction statues and regulations.

Therefore, there would be no impact during construction, operation and maintenance and no mitigation required.
537
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 358
Table 3.18-3. Consistency with State and Local Plans, Policies, and Regulations Goals and Policies Project Consistency
California Integrated Waste Management
Act (AB 939)
Consistent. The Proposed Project will follow all relevant County and local solid waste management programs and regulations. These include Butte County General Plan 2030, Town of Paradise General Plan, Chico 2030 General Plan, and City of Chico Sanitary System Management Plan.

Butte County General Plan 2030
Goal PUB-9: Provide safe, sanitary and
environmentally acceptable solid waste
management.

Consistent. The Proposed Project intends to construct a new sewer collection system that would reduce public health and environmental concerns caused by the existing failed septic system. Additionally, waste could be accommodated by Butte County landfills listed in Section 3.12.1. All solid waste and construction debris will be transported to a local landfill or another approved location. Project operations would not generate additional solid waste.

Goal PUB-11: Increase recycling among Butte
County residents, businesses, and public
agencies.

Consistent. The Proposed Project intends to construct a new a sewer collection system that is more efficient and safer for Paradise residents.

Existing recycling services and practices would not be impacted and would remain the same as existing conditions in Butte County.

Policy PUB-P11.2: Construction sites will
provide for the salvage, reuse, or recycling of
construction and demolition materials.

Consistent. Waste could be accommodated by Butte County landfills listed in Section 3.12.1. All solid waste and construction debris will be transported to a local landfill or another approved location. Where possible, construction and demolition materials will be recycled, reused or salvaged. Project operations would not generate additional solid waste.

Town of Paradise General Plan
Policy LUP-12: The character of future
development should be compatible with the
Town’s service delivery abilities and will not
result in service level declines.

Consistent. The new sewer collection system would not result in service level decline, rather it would provide improved sewer services for 1,500 parcels in Paradise. Once the Proposed Project is operational, the 1,500 parcels connecting to the Core Collection System would no longer require septage disposal at local landfills, which could result in beneficial impacts on solid waste generation and sewer service levels in the Town.

Policy LUP-13: The Town will attempt to
assure that the rate and character of growth is
commensurate with or does not exceed the
current levels of public services, and will
attempt to assure that municipal services can
be provided to areas planned for annexation
and development.

Consistent. The Proposed Project has the potential to foster population regrowth as a result of Camp Fire recovery efforts which could place an additional demand on existing utility services. However, long-term utility usage would be expected to be similar to pre-Camp Fire levels and within the approved capacities for these services.

Chico 2030 General Plan
Goal PPFS-8: Ensure that solid waste and
recyclable collection services are available to
City residents.

Consistent. The Proposed Project intends to construct a new a sewer collection system that is more efficient and safer for Town residents. Existing solid waste and recyclable collection services would not be impacted and would remain the same and available to City residents.

Mitigation. No mitigation required.

3.18.5 Impacts Summary
Table 3.18-4 summarizes the utilities and service systems impacts of the Proposed Project. 538
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 359
Table 3.18-4. Utilities and Service Systems Impacts Summary Impact
Level of
Significance
Before Mitigation
Mitigation
Level of
Significance
with Mitigation
Incorporated
Impact UTIL-1: Require or result in the relocation or construction of new or expanded water, wastewater treatment, storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects
S/M MM-UTIL-1 LTS
Impact UTIL-2: Have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years

NI N/A NI
Impact UTIL-3: Result in a determination by the wastewater treatment provider, which serves or may serve the Project, that it has inadequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments

NI N/A NI
Impact UTIL-4: 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

NI N/A NI
Impact UTIL-5: Comply with federal, state, and local management and reduction statutes and regulations related to solid waste

NI N/A NI
Notes: LTS = Less than Significant Impact, NI = No Impact, N/A = Not Applicable, SI = Significant Impact, S/M = Significant Impact but Mitigable to a Less than Significant Level

3.18.6 References
Butte County. 2000. Chico Urban Area Nitrate Compliance Plan. Program Report and Proposed Implementation Plan for Groundwater Nitrate Compliance in the Chico Urban Area. http://www.buttecounty.net/Portals/1/NitrateComplianceProgram/Chico_Urban_Area_Nitrate_ Compliance_Plan_Final-2000.pdf.

Butte County. 2013. “Power Butte.” 2013. Accessed April 2021. http://power.buttecounty.net/.

Butte County. 2021f. “Household Hazardous Waste.” Accessed April 2021. http://www.buttecounty.net/ recyclebutte/householdhazardouswaste.

California Department of Resources Recycling and Recovery (CalRecycle). 2022. “SWIS Facility/Site Activity Details.” Neal Road Recycling and Waste Facility (04-AA-0002). Accessed April 28, 2022. https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/110?siteID=108.

CEC. 2021c. California Electric Infrastructure App. Accessed April 2021. https://cecgiscaenergy.opendata.arcgis.com/apps/california-electric-infrastructure-app/explore. 539
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 360
California Water Service. 2021. “District Information”. Accessed April 2021. https://www.calwater.com/ district-information/?dist=ch.

City of Chico. 2017. Chico 2030 General Plan. Adopted April 2011. Amended March 2017. https://chico.ca.us/post/chico-2030-general-plan.

City of Chico. 2021a. “Water Pollution Control Plant.” Accessed November 29, 2021. https://chico.ca.us/ post/water-pollution-control-plant
City of Chico. 2021e. “Sewers Collection System Maintenance.” Accessed April 2021. https://chico.ca.us/post/sewers-collection-system-maintenance.

City of Chico. 2021f. Household Hazardous Waste. Accessed April 2021. https://chico.ca.us/post/ household-hazardous-waste.

Northern Recycling and Waste Services. 2010. “Our History.” Accessed April 2021. http://northernrecycling.biz/About%20us.html.

PID (Paradise Irrigation District). 2021. “Home.” Accessed April 2021. https://pidwater.com/.

PG&E. 2021. “Company Profile.” Accessed October 2021. https://www.pge.com/en_US/aboutpge/company-information/profile/profile.page.

Western Area Power Administration. 2021. “About WAPA.” Updated October 8, 2021. Accessed October 2021. https://www.wapa.gov/About/Pages/about.aspx.

Western Electricity Coordinating Council. 2015. “About WECC.” Accessed October 2021. https://www.wecc.org/Pages/home.aspx.
540
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 361

3.19 Wildfire
This section describes the environmental setting and regulatory framework for wildfire, and it identifies direct and indirect impacts of the Proposed Project during construction, operation, and maintenance. In particular, the wildfire analysis focuses on emergency response and evacuation, wildfire risk and hazards in the study area that may be exacerbated as a result of the Proposed Project’s construction, and operation, and maintenance. The study area for wildfire refers to the areas within and directly adjacent to the Town and areas of unincorporated Butte County and the City where the proposed pipeline alignment would run.

3.19.1 Environmental Setting
The County encompasses over 1.1 million acres and is located at an elevation ranging between 60 feet to 7,000 feet above sea level (Butte County 2020). Approximately 52 percent of the County is designated SRA, and approximately 14 percent is designated Federal Responsibility Area (FRA) (Butte County 2020). Public lands primarily include parts of Lassen National Forest and the Plumas National Forest. The remaining 34 percent of the County is located in a LRA (Butte County 2020). Wildfires are common in the LRA, which poses a significant threat to the adjacent SRA.

The Core Collection System and Extended Collection System are located in a LRA Very High FHSZ (CALFIRE 2008). Farther south of the Town, the Export Pipeline traverses Very High, Moderate and High FHSZs in the SRA. The Chico WPCP is located in a LRA Non-Very High FHSZ.

Vegetation is generally grouped into three fuel types, including grass, brush, and timber. Numerous factors such as fuel type and size, loading (tons/acre), arrangement (vertical and horizontal), chemical composition, and dead and live fuel moisture, contribute to the flammability characteristics of vegetation (Butte County 2020). In the County, the valley and lower foothills (up to approximately 1,000 feet in elevation) are covered by the grass fuel types, which is the main carrier of fire. The mid-foothill and lower mountain areas (approximately 1,000 feet to 2,000 feet in elevation) are dominated by brush, which burns readily and can be difficult to control particularly on steep topography and when moisture content reaches critical levels. The mountainous areas (above approximately 2,000 feet in elevation) are generally covered by the timber fuel types, which burn readily and are difficult to control on steep topography and during strong wind events (Butte County 2020).

The County has a Mediterranean climate characteristic of hot, dry summers, and cool, wet winters.

Occasionally during the summer, dry weather fronts will approach northern California bringing increased wind speeds from the south. Typically, annually in the autumn months, north wind events bring high temperatures, very low humidity, and strong winds. These conditions usually produce red flag warnings, which provide the highest potential for extreme fire behavior. These conditions in combination with fuels, already at their driest moisture content, can create a severe fire weather situation (Butte County 2020).

The responsibility for the prevention and suppression of wildfires within the County belongs to the BCFD/CALFIRE and to individual municipalities (Butte County 2012). 541
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 362

3.19.1.1 Local Setting
Wildland Urban Interface
Paradise
The Town is located in a LRA Very High FHSZ (CALFIRE 2008). Areas directly surrounding the Town are located in an SRA and zoned Very High FHSZ. The Town is characteristic of an urban interface environment where wildland abruptly adjoins housing and the population is approximately 4,500.

However, prior to the Camp Fire the population was approximately 27,000 (DOF 2021a).

Emergency access and evacuation is a concern in the Town due to the limited narrow roads. To mitigate traffic issues during an evacuation, several miles of Skyway have been reconstructed and paved from Stirling City to Butte Meadows as a possible additional evacuation route. Emergency response in the Town is provided by CALFIRE/BCFD, PFD, and Paradise Fire Safe Council (Butte County 2020).

Chico
The City is located in a LRA Non-Very High FHSZ (CALFIRE 2008). Critical infrastructure within the City includes a UPRR main line, an underground petroleum pipeline, state highways and high voltage power lines. The 3,670-acre Bidwell Park located near the center of the city also has high potential for urban/wildland interface. Home development in the City has substantially increased in recent years and a large area of the city can be characterized as urban interface environment where the wildland abruptly adjoins high density housing. The BCFD/CALFIRE and CFD provide fire protection in the City and the unincorporated areas in and immediately surrounding the City (Butte County 2020).

Topography
Paradise
The Town ranges in elevation from approximately 1,000 to 2,300 feet and is located on a broad gently sloping ridge. There are numerous steep canyons near the perimeter of the Town. Butte Creek Canyon, bordering to the west, and the West Branch of the Feather River, bordering to the east, are the two largest canyons surrounding the Town and are most influential on fire behavior. Nance, Hamlin, Berry, Clear Creek, and Dry Creek Canyons are smaller north-south trending canyons located along the southern border of the Town. These small canyons are less prominent but are still very influential on fire behavior (Butte County 2020).

Chico
The City is predominantly flat and is located at an elevation of 197 feet. The western trending foothills in the City rise at a slope of approximately 15 percent. Big Chico Creek and Little Chico Creek traverse the City and the Lindo Channel acts as the major drainage for flood control. Other creeks traversing the city include Mud Creek, Sycamore Creek, Comanche Creek, Dead Horse Slough, and Butte Creek (Butte County 2020).

Weather and Fire History
Paradise
In the Town, seasonal weather patterns do not vary significantly from seasonal averages; average rainfall is 32 inches per year (Weather Atlas 2022a). As a result, extreme weather conditions have not been the primary factor in large fires within the area historically. However, weather outside of the Town limits has great potential to have an impact on fire behavior, thereby driving fire into the Town. In June 542
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 363
2008, a 23,000-acre fire in Humboldt burned 57 acres within the Town. Conditions under the Humboldt Fire were intensified by high winds. In 2018, the Camp Fire burned approximately 153,000 acres, over 18,000 buildings, and resulted in 85 fatalities (Butte County 2020).

Chico
The City is lower in elevation; the average annual rainfall is approximately 28 inches per year (Weather Atlas 2022b). In the summer, temperatures range from high to very high (above 100 °F), low humidity and light to moderate south winds associated with high pressure weather gradients.

The highest potential for extreme fire behavior occurs during north wind events that produce red flag warnings conditions. Wind is the primary factor resulting in large fire spread in the City. Historically, large fires in or near the City have included the Skyway Fire, which burned 425 acres in 2006, and the Humboldt Fire, described above (Butte County 2020).

Fuels
Paradise
Fuel loading in the Town was significantly reduced after the Camp Fire; however, conditions allow for regrowth of native and non-native (invasive) plant species. There are a wide range of vegetation types in the Town, ranging from chaparral brush mix and oak woodland to mixed-conifer timber. An overstory of ponderosa pine/California black oak mix, with an understory of chaparral brush component consisting of manzanita, ceanothus, scotch broom, and poison oak make up the lower elevations of the Town. Greenbelt areas and undeveloped areas also consist of regrowth brush, which has the potential to affect fire behavior. In addition to regrowth brush, the potential for invasive species is high. These vegetation types present fire risk and may lead to fuel driven fires in the Town (Butte County 2020).

Chico
The City is predominantly covered by grasses, planted trees, and brush. The areas surrounding the City and eastern parts of the City that extend to the foothills are covered primarily by annual grasses, oak woodland, and chapparal brush mix. These are considered light to medium fuels. The drainage areas in many of the City’s channels are non-native weed Arundo. These fuel types combined with recent structural development and flat topography create fire suppression hazards given their ability to readily support ignition and fire spread, particularly under windy conditions (Butte County 2020).

3.19.2 Regulatory Framework
This section summarizes the federal, state, regional, and local laws, regulations, policies, and plans relevant to evaluation of the Proposed Project’s impacts on wildfire. Additional information on the relevant regulations, laws, and plans is provided in Appendix C, Regulatory Framework.

3.19.2.1 Federal
The National Strategy
The Federal Land Assistance, Management, and Enhancement Act of 2009 (FLAME Act) directed the U.S. Department of the Interior (DOI) and U.S. Department of Agriculture (USDA) to develop a national cohesive wildland fire management strategy to comprehensively address wildland fire management across all lands in the United States. The DOI and USDA committed to a three-phased planning and analysis effort to thoroughly examine and address the complexities of wildland fire management. The 543
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 364
National Strategy: The Final Phase in the Development of the National Cohesive Wildland Fire Management Strategy (National Strategy) (DOI and USDA 2014) is the result of a collaborative effort by Federal, state, local, and tribal governments and nongovernmental partners and public stakeholders, in conjunction with scientific data analysis. The National Strategy recognizes and accepts fire as a natural process necessary for the maintenance of many ecosystems and strives to reduce conflicts between fire-prone landscapes and people (DOI and USDA 2014). Specifically, the National Strategy identifies the following primary goals:
 Restoration and maintenance of landscapes: Landscapes across all jurisdictions are resilient to fire-related disturbances in accordance with management objectives.  Fire-adapted communities: Human populations and infrastructure can withstand a wildfire without loss of life and property.
 Wildfire response: All jurisdictions participate in making and implementing safe, effective, efficient risk-based wildfire management decisions.

The National Strategy guides federal direction for the state and local agencies responsible for fire protection in the vicinity of the Proposed Project.

The Proposed Project will be held to the goals of the National Strategy.

FEMA Grants – Town of Paradise Wildfire Mitigation Projects The Town has applied to FEMA through the California Office of Emergency Services for four grants under FEMA’s Hazard Mitigation Grant Program Post-Fire Assistance (FEMA 2022). The Town is proposing four wildfire mitigation projects to enhance fire safety and mitigate the threat of wildfire. The purpose of the proposed projects is to protect people and property by reducing wildfire-related hazards within the Town. The projects would implement wildfire mitigation measures throughout the Town, through a combination of enhanced enforcement, education, and incentives to help property owners reduce hazards on their own lands and reduce hazardous fuels on Town rights-of-way. The four projects include the following: (1) enhancing code enforcement activities to manage hazardous fuels and defensible space, (2) introducing a residential ignition-resistant improvement and defensible space program, (3) hazardous fuel reduction along Town rights-of-way, and (4) removing hazardous dead or dying trees on private properties (FEMA 2022).

The Proposed Project will be held to the requirements of FEMA’s Hazard Mitigation Grant Program.

3.19.2.2 State
2018 Strategic Fire Plan for California
The 2018 Strategic Fire Plan for California, developed by the State Board of Forestry and Fire Protection, provides direction and guidance to CALFIRE and its 21 field units. This plan sets forth a number of goals focused on fire prevention, natural resource management, and fire suppression efforts, including the following (CALFIRE 2018):
 Improve the availability and use of consistent, shared information on hazard and risk assessment.
544
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 365
 Promote the role of local planning processes, including general plans, new development, and existing developments, and recognize individual landowner/homeowner responsibilities.  Foster a shared vision among communities and the multiple fire protection jurisdictions, including county-based plans and community-based plans such as community wildfire protection plans.
 Increase awareness and actions to improve fire resistance of human-made assets at risk and fire resilience of wildland environments through natural resource management.  Integrate implementation of fire and vegetative fuels management practices consistent with the priorities of landowners or managers.
 Determine and seek the needed level of resources for fire prevention, natural resource management, fire suppression, and related services.
 Implement needed assessments and actions for post-fire protection and recovery.

The 2018 Strategic Fire Plan for California guides CALFIRE oversight of local agencies’ responsibilities for fire protection and natural resource management in the vicinity of the Proposed Project.

The Proposed Project will be held to the goals set forth by the 2018 Strategic Fire Plan.

Community Wildfire Prevention and Mitigation Report
CALFIRE prepared the Community Wildfire Prevention & Mitigation Report in response to Executive Order N-05-19, which directed CALFIRE, in consultation with other state agencies and departments, to recommend immediate, medium-term, and long-term actions to help prevent destructive wildfires, with a specific focus on vulnerable communities and populations in the state (CALFIRE 2019). Based on local fire plans developed by CALFIRE units, CALFIRE identified 35 priority projects for immediate implementation to help reduce public safety risks for more than 200 communities. Projects include removal of hazardous dead trees, vegetation clearing, creation of fuel breaks and community defensible spaces, and creation of ingress and egress corridors. The Community Wildfire Prevention & Mitigation Report also identifies near-term administrative, regulatory, and policy actions to address community vulnerability and wildfire fuel buildup through rapid deployment of resources.

CALFIRE’s identified medium-term and long-term actions encourage coordination and cooperation among the various levels of regional and local fire protection agencies.

The Proposed Project would be held to the strategies in the Community Wildfire Prevention & Mitigation Report.

California Fire Code
The California Fire Code (CCR Title 24, Part 9) establishes minimum requirements to safeguard the public health, safety, and general welfare from the hazards of fire, explosion, or dangerous conditions in new and existing buildings. Chapter 33 of the code contains requirements for fire preserving safety during construction, such as to develop a pre-fire plan in coordination with the fire chief, maintain vehicle access for firefighting at construction sites, and meet requirements for safe operation of construction equipment powered by internal combustion engines.

The Proposed Project will be held to the requirements set forth by the California Fire Code. 545
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 366
CALFIRE’s Fire Hazard Severity Zone Mapping
CALFIRE is required by law to identify areas, referred to as FHSZs, based on the severity of fire hazard that is expected to prevail there. The FHSZ maps are developed using a science-based, field-tested computer model that assigns a hazard score based on the factors that influence fire likelihood and fire behavior. The FHSZ maps are developed based on factors such as fire history, existing and potential fuel (natural vegetation), predicted flame length, blowing embers, terrain, and weather (CALFIRE 2022).

SRAs are defined as areas where the State of California has financial responsibility for wildland fire protection and prevention; incorporated cities and federal ownership are not included. Within SRAs, CALFIRE is responsible for fire prevention and suppression (CALFIRE 2022). The Board of Forestry and Fire Protection classifies lands as SRA. All SRAs are within a FHSZ. There are three levels of hazard in the SRAs: moderate, high, and very high (CALFIRE 2022).

LRAs are defined as incorporated cities, urban regions, agricultural lands, and portions of the desert where the local government is responsible for wildfire protection. This is typically provided by city fire departments, fire protection districts, counties, and by CALFIRE under contract (CALFIRE 2022).

CALFIRE uses an extension of the SRA FHSZ model as the basis for evaluating fire hazard in LRAs.

The LRA hazard rating reflects flame and ember intrusion from adjacent wildlands and from flammable vegetation in the urban area.

FHSZ maps evaluate wildfire hazards, which are the physical conditions that create a likelihood and expected fire behavior over a 30 to 50-year period without considering short-term modifications such as fuel reduction effort (CALFIRE 2022). FHSZ maps can be used for the following purposes:
implementing wildland-urban interface building standards for new construction, natural hazard real estate disclosure at time of sale 100-foot defensible space clearance requirements around buildings, and property development standards such as road widths, water supply, and signage consideration in city and county general plans (CALFIRE 2022).

The Proposed Project will be held to the restrictions associated with FHSZ mapping.

3.19.2.3 Regional and Local
Butte County Local Hazard Mitigation Plan Update
The Butte County Local Hazard Mitigation Plan Update (Butte County 2019b) includes an assessment of the county’s risk and vulnerability related to natural and other identified hazards and a comprehensive mitigation strategy which includes actions and projects designed to mitigate or reduce the impacts of those hazards and to increase community resiliency.

The Proposed Project will be held to the strategies in the Butte County Local Hazard Mitigation Plan Update.

Butte County General Plan 2030
The Butte County General Plan 2030 (Butte County 2012) includes the following goals and policies related to wildland fires that are relevant to the Proposed Project:
 Goal HS-11: Reduce risks from wildland fire and urban fire. 546
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 367
 Policy HS-P11.1: Fire hazards will be considered in all land use and zoning decisions, environmental review, subdivisions review and the provision of public services.  Policy HS-P11.2: Create communities that are resistant to wildfire by supporting the implementation of community wildfire protection plans and wildfire fuel load reduction measures in coordination with the appropriate government, community group, or non-profit organization and California Department of Forestry and Fire Protection (CALFIRE).  Policy HS-P11.3: The County supports the Wildfire Mitigation Action Plan, the Butte County Local Hazard Mitigation Plan (LHMP), and the Butte Unit Community Wildfire Protection Plan prepared by CALFIRE and will cooperate with the Butte County Fire Department and the Butte County Fire Safe Council in implementing these plans.
 Policy HS-P11.4: New development projects will meet current fire safe ordinance standards for adequate emergency water flow, emergency vehicle access, signage, evacuation routes, fuel management, defensible space, fire safe building construction and wildfire preparedness.  Goal HS-12: Protect people and property from wildland or urban fires.  Policy HS-P12.4: All development projects in wildland urban interface areas in High or Very High Fire Hazard Severity Zones will provide, at a minimum, small-scale water systems for fire protection.
 Goal HS-13: Identify safe and effective evacuation routes and access for fire prevention and suppression
 Policy HS-P13.1: New development in High or Very High Fire Hazard Severity Zones, as shown in Figure HS-9, shall identify access and egress routes and make improvements or contribute to a fund to develop upgrade and maintain these routes.

The Proposed Project will be held to the goals and policies in the Butte County General Plan 2030.

Butte County Multi-Jurisdictional All Hazard Pre-Disaster Mitigation Plan The Butte County Multi-Jurisdictional All Hazard Pre-Disaster Mitigation Plan (Butte County 2007) was developed by Butte County and participating jurisdictions (City of Biggs, City of Chico, City of Gridley, City of Oroville, and Town of Paradise) to meet the requirements of the Disaster Mitigation Act of 2000.

This plan represents the commitment of Butte County and participating jurisdictions to reduce risks from natural and other hazards and serves as a guide for decision-makers as they commit resources to reducing the effects of natural and other hazards. The overall intent of this plan is to reduce or prevent injury and damage from hazards in the county. It identifies past and present mitigation activities, current policies and programs, and mitigation strategies for the future.

The Proposed Project will be held to the strategies in this plan.

Butte County Community Wildfire Protection Plan 2020–2025 The Butte County Community Wildfire Protection Plan 2020–2025 (Butte County 2020) was developed by federal, State, and local agencies in order to identify and prioritize pre-fire and post-fire management strategies and tactics meant to reduce the loss of value at risk within the County. The plan establishes a framework for reducing the risks associated with wildfire by placing emphasis on what needs to be done before the fire starts. The plan strives to reduce firefighting costs and property losses, increase firefighter safety, and to enhance ecosystem health (Butte County 2020). 547
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 368
The Proposed Project will be held to the strategies in the Butte County Community Wildfire Protection Plan.

Town of Paradise General Plan
The Town of Paradise General Plan (Town of Paradise and Quad Consultants 2008) includes the following policies related to wildland fires that are relevant to the Proposed Project:
 Goal SG-1: Assure that law enforcement and fire protection services are enhanced sufficiently to meet the demands of new and existing land use development.  Policy SP-1: New and unmitigated land use development will not cause the police and fire protection services emergency response times to full below the service levels established by this plan.
 Policy SP-2: Through the development review process, adequate roads will be required to be constructed and/or improved for emergency vehicle access, particularly in high wildland fire hazard areas.
 Policy SP-3: Future development should be designed and constructed to take maximum advantage of known fire and crime prevention siting, orientation and building techniques.  Policy SP-5: The Town should promote fire prevention by continuing to require brush removal and fuel load clearing as ongoing conditions of development approval and property maintenance.
 Implementation Measure SI-6: Enforce and comply with the provisions of the Unform Building Code and Uniform Fire Code.

The Proposed Project will be held to the goals, policies, and implementation measures in the Town of Paradise General Plan.

Town of Paradise Emergency Operations Plan
The purpose of the Town of Paradise Emergency Operations Plan (Town of Paradise 2011), its Functional Annexes and Hazard/Threat Specific Appendices is to provide the basis for a coordinated response before, during, and after a disaster incident affecting the Town. The plan is the principal guide for the Town’s response to, and management of real or potential emergencies and disasters occurring within its designated geographic boundaries. It also identifies how the Town integrates into the Standardized Emergency management System and the National Incident Management System.

Reducing risks from and response to wildland fire is also discussed in the plan and focuses on fuel reduction and the reduction of wildland fire to infrastructure.

The Proposed Project will be held to the strategies in this plan.

Paradise Fire Safe Council
Founded in 1999, the Paradise Fire Safe Council is comprised of volunteer community members under the umbrellas of the Butte County Fire Safe Council and the California Fire Safe Council. The council is designated under the Town of Paradise to provide community input on wildfire prevention and safety (Paradise Fire Safe Council 2008).

The Proposed Project will be held to the principles set forth by the Paradise Fire Safe Council. 548
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 369
Chico 2030 General Plan
The Chico 2030 General Plan (City of Chico 2017) includes the following policies related to wildland fires that are relevant to the Proposed Project:
 Goal S-4: Continue to provide effective and efficient fire protection and prevention services to Chico area residents.
 Action S-4.1.1, Fire Response Time: Strive to obtain an initial response time of five and a half minutes or less for at least 90 percent of fire emergency response calls in urbanized areas.  Action S-4.3.3, Project Design: As part of the project review process in wildland fire areas, require consideration of emergency evacuation routes and defensible buffer areas.  Policy S-4.4, Vegetation Management: Support vegetation management and weed abatement programs that reduce fire hazards.

The Proposed Project will be held to the goals and policies of the Chico 2030 General Plan.

3.19.3 Method of Analysis
This section describes the methods used to analyze wildfire impacts within the study area.

3.19.3.1 CEQA Significance Criteria
For the purposes of this PEIR, the Proposed Project would result in a significant impact on wildfire if it would:
 Impact FIRE-1: Substantially impair an adopted emergency response plan or emergency evacuation plan
 Impact FIRE-2: Exacerbate wildfire risks due to slope, prevailing winds, and other factors, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire
 Impact FIRE-3: 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  Impact FIRE-4: 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

3.19.3.2 Approach to Analysis
Construction, Operation, and Maintenance
Impacts on wildfire were identified qualitatively based on the Proposed Project’s potential to increase wildfire occurrence and associated risks.

A desktop analysis was completed to collect and analyze data related to wildfire risks in the study area.

For the purposes of this analysis, information related to wildfire risks was collected using the following sources:
 Map of Butte County Very High FHSZ in LRA (CALFIRE 2008)  Butte County Community Wildfire Protection Plan (Butte County 2020) 549
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 370
The analysis of environmental effects focuses on foreseeable changes to wildfire in the context of effects listed in Section 3.19.3.1, CEQA Significance Criteria. The analysis considers the Core Collection System, Export Pipeline System, and Extended Collection System, as appropriate, in the context of construction, operation, and maintenance.

3.19.4 Impact Analysis
This section describes the potential environmental impacts on wildfire as a result of implementation of the Proposed Project. It includes an analysis of the Proposed Project’s potential to the substantially impair an adopted emergency response plan or evacuation plan; exacerbate wildfire risks and expose project occupants to pollutant concentrations; require the installation or maintenance of associated infrastructure that may exacerbate fire risk; or expose people or structures to significant risks as a result of runoff, post-fire slope instability, or drainage changes.

3.19.4.1 Impact FIRE-1: Substantially impair an adopted emergency response plan or emergency evacuation plan (Less than Significant Impact with Mitigation Incorporated)
Construction
As discussed in Section 2.7.2 Traffic Management and Temporary Construction Road Closures, no total road closures would result from implementation of the Proposed Project, other than for movement of equipment, which would be very temporary. Installation of the Export Pipeline System would occur along Skyway, which is a primary evacuation route. Closures within the ROWs would be partial; however, in the event of a wildfire, all four lanes of Skyway would be required for evacuation.

Therefore, the construction area for the Export Pipeline System along Skyway could potentially interfere with the flow of evacuation traffic. As a result, the impact on an emergency response or emergency evacuation plan during construction would be significant.

Mitigation. To minimize potentially significant impacts on emergency response or emergency evacuation plan during construction of the Proposed Project to a less than significant level, mitigation measures MM-HAZ-3, MM-HAZ-4, MM-HAZ-5, and MM-HAZ-6 will be implemented.

MM-HAZ-3: Road Closure Restrictions (see Section 0, Hazards and Hazardous Materials, for description)
MM-HAZ-4: Rapid Demobilization Plan (see Section 0, Hazards and Hazardous Materials, for description)
MM-HAZ-5: Evacuation Warning Procedures (see Section 0, Hazards and Hazardous Materials, for description)
MM-HAZ-6: Traffic Management Plan (see Section 0, Hazards and Hazardous Materials, for description)
Significance after Mitigation. With implementation of mitigation measures MM-HAZ-3, MM-HAZ-4, MM-HAZ-5, and MM-HAZ-6, impacts on an emergency response or emergency evacuation plan would be reduced to a less than significant level.
550
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 371
Operation and Maintenance
Once operational, the Proposed Project would support objectives for multi-family housing units being located near emergency evacuation routes. This is because multi-family housing units typically generate a high amount of wastewater relative to their parcel size; this typically means that on-site septic systems are not feasible for this type of development, and they would need to connect to the Core Collection System. The main part of the Core Collection System would be installed along roads that also serve as the primary evacuation corridors for the Town. The end result is denser, multi-family housing being located on primary evacuation corridors, rather than on the canyon edges in Paradise, which in turn will facilitate safer, more rapid evacuation in case of a future fire.

Operation and maintenance activities, as described in Section 2.8, would not involve the presence or operation of equipment on roads for extended periods of time. Operation and maintenance activities would require few vehicles that would not alter the traffic volumes on roads in the study area. As a result, emergency access would remain similar to existing conditions during operations and maintenance. Therefore, operation and maintenance activities would have no impact on an adopted emergency response plan or emergency evacuation route.

Mitigation: No mitigation required.

3.19.4.2 Impact FIRE-2: Exacerbate wildfire risks due to slope, prevailing winds, and other factors, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire (Less than Significant Impact with Mitigation Incorporated)
Construction
The Core Collection System and Extended Collection System are located in a LRA Very High FHSZ (CALFIRE 2008). Farther south of the Town, the Export Pipeline traverses Very High, Moderate, and High FHSZs in the SRA. The Chico WPCP is located in a LRA Non-Very High FHSZ.

The Town is located at an elevation of 1,000 to 2,300 feet on a broad and gently sloping ridge.

Vegetation types found in the Town present fire risk and may lead to fuel driven fires. Together, these factors, along with Town’s history of wildfire, create a potential for high fire risks. The City is predominantly flat. However, the weather in Chico (temperatures ranging from high to very high in the summer, low humidity, and winds), fuel types and recent structural developments supportive of fire hazards, and the urban/wildland interface can also create wildfire risk in the study area.

Operation and fueling of construction equipment in Very High FHSZs could create fire hazards in the study area. As described in Section 0, Hazards and Hazardous Materials, hazardous materials will be used, transported, and disposed of during construction of the Proposed Project. The Town will comply with all relevant federal, state, and local statutes and regulations related to the transport, use, storage, or disposal of hazardous materials associated with construction activities, and all materials designated for disposal will be evaluated for appropriate state and federal hazardous waste criteria and properly disposed of according to their classifications.

Because the Proposed Project is located in a Very High FHSZ, the potential for wildfire exists during construction. Therefore, this impact is considered significant. 551
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 372
Mitigation. To minimize potentially significant impacts from exacerbating wildfire risk in the study area during construction of the Proposed Project to a less than significant level, mitigation measures MM-HAZ-1, MM-HAZ-7, MM-HAZ-8, and MM-HAZ-9 will be implemented.

MM-HAZ-1: Vehicle Equipment Access and Fueling (see Section 0, Hazards and Hazardous Materials, for description)
MM-HAZ-7: Incorporate Fire Prevention Measures (see Section 0, Hazards and Hazardous Materials, for description)
MM-HAZ-8: Incorporate Public Safety Measures (see Section 0, Hazards and Hazardous Materials, for description)
MM-HAZ-9. Wildland Fire Area (see Section 0, Hazards and Hazardous Materials, for description) Significance after Mitigation. With implementation of mitigation measures MM-HAZ-1, MM-HAZ-7, MM-HAZ-8, and MM-HAZ-9, impacts from exacerbating wildfire risk in the study area would be less than significant.

Operation and maintenance activities, as described in Section 2.8, would not require the use of heavy equipment, fueling, or other activities likely to create an additional fire hazard. Additionally, operation and maintenance activities would not be located adjacent to wildland areas. Furthermore, fire suppression equipment would be made available during operation and maintenance activities and Chico WPCP would continue to comply with existing fire codes. Therefore, operation and maintenance of the Proposed Project would not exacerbate wildfire risk in the study area, resulting in a less than significant impact.

Mitigation: No mitigation required.

3.19.4.3 Impact FIRE-3: 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 Impact with Mitigation Incorporated) Construction
The Proposed Project would involve the construction of the Core Collection System, Export Pipeline System, and Extended Collection System. As discussed under Impact FIRE-2, portions of the study area are located within Very High FHSZs. Construction activities such as operation and fueling of construction equipment in Very High FHSZs could create fire hazards in the study area. Therefore, 552
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 373
impacts on wildfire from the installation or maintenance of utility infrastructure during construction are considered significant.

Mitigation. To minimize potentially significant impacts on wildfire from installation or maintenance of utility infrastructure during construction of the Proposed Project to a less than significant level, mitigation measures MM-HAZ-1, MM-HAZ-7, MM-HAZ-8, and MM-HAZ-9 will be implemented.

MM-HAZ-1: Vehicle Equipment Access and Fueling (see Section 0, Hazards and Hazardous Materials, for description)
MM-HAZ-7: Incorporate Fire Prevention Measures (see Section 0, Hazards and Hazardous Materials, for description)
MM-HAZ-8: Incorporate Public Safety Measures (see Section 0, Hazards and Hazardous Materials, for description)
MM-HAZ-9. Wildland Fire Area (see Section 0, Hazards and Hazardous Materials, for description) Significance after Mitigation. With implementation of mitigation measures MM-HAZ-1, MM-HAZ-7, MM-HAZ-8, and MM-HAZ-9, impacts on wildfire from the installation or maintenance of utility infrastructure would be less than significant.

Operation and maintenance activities, as described in Section 2.8, would not require the use of heavy equipment, fueling, or other activities likely to create an additional fire hazard. Additionally, operation and maintenance activities would not exacerbate wildfire risk in the study area because these activities would not occur adjacent to wildland areas. Furthermore, fire suppression equipment would be made available during operation and maintenance activities and Chico WPCP would continue to comply with existing fire codes. Therefore, operation and maintenance of the Proposed Project would result in a less than significant impact on wildfire from installation or maintenance of utility infrastructure.

Mitigation. No mitigation required.

3.19.4.4 Impact FIRE-4: 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 Impact with Mitigation Incorporated) Construction
The Town is located on a broad and gently sloping ridge, while the City is predominantly flat.

Installation of the Core and Extended Collection Systems and Export Pipeline System would require 553
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 374
installation via trenching or open cut methods within the Town’s roadway ROWs. Sections of the proposed Core Collection System and Export Pipeline System would cross private parcels and would require easements from the property owners. Once installed, disturbed areas would be backfilled and the ground surface would be restored to original conditions or better. Additionally, the Core Collection System, Extended Collection System and Export Pipeline System would be constructed in segments and any drainage impacts would be localized and temporary. However, given the sloped topography of the Town and ground disturbing activities that could create runoff or temporarily alter drainage patterns, impacts would be significant during construction.

Mitigation. To minimize significant impacts on post-fire slope instability, or drainage changes during construction of the Proposed Project to a less than significant level, mitigation measures MM-HYD-1, MM-HYD-3, and MM-GEO-1 will be implemented.

MM-HYD-1: Stormwater Management and Treatment Plan (see Section 0, Hydrology and Water Quality, for description)
MM-HYD-3: Flood Protection Plan (see Section 0, Hydrology and Water Quality, for description) MM-GEO-1: Minimize Geologic Hazards (see Section 0, Geology, Soils, and Paleontological Resources, for description)
Significance after Mitigation. With implementation of mitigation measures MM-HYD-1, MM-HYD-3, and MM-GEO-1, impacts from exposing 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 would be less than significant.

Operation and maintenance activities, as described in Section 2.8, would not involve activities that create runoff or alter drainage. Additionally, operation and maintenance activities would not exacerbate wildfire risk in the study area because these activities would not occur adjacent to wildland areas.

Therefore, operation and maintenance of the Proposed Project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, resulting in a less than significant impact.

Mitigation. No mitigation required.

3.19.5 Impacts Summary
Table 3.19-1 summarizes the wildfire impacts of the Proposed Project. 554
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 375
Table 3.19-1. Wildfire Impacts Summary
Impact
Level of
Significance
Before Mitigation
Mitigation
Level of
Significance
with Mitigation
Incorporated
Impact FIRE-1: Substantially impair an adopted emergency response plan or emergency evacuation plan
SI MM-HAZ-3, MMHAZ-4, MM-HAZ5, and MM-HAZ-6 S/M
Impact FIRE-2: Exacerbate wildfire risks due to slope, prevailing winds, and other factors, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire
SI MM-HAZ-1, MMHAZ-7, MM-HAZ8, and MM-HAZ-9 S/M
Impact FIRE-3: 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
SI MM-HAZ-1, MMHAZ-7, MM-HAZ8, and MM-HAZ-9 S/M
Impact FIRE-4: 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 SI MMHYD-1, MMHYD-3, and MMGEO-1
S/M
Notes: LTS = Less than Significant Impact, NI = No Impact, N/A = Not Applicable, SI = Significant Impact, S/M = Significant Impact but Mitigable to a Less than Significant Level

3.19.6 References
Butte County. 2007. Butte County Multi-Jurisdictional All Hazard Pre-Disaster Mitigation Plan. March 2007. http://www.buttecounty.net/Portals/19/ButteMHMPMarch2007Resolutions1-8-10.pdf.

Butte County. 2019b. Butte County Local Hazard Mitigation Plan Update. Prepared by Foster Morrison.

October 2019. http://www.buttecounty.net/oem/mitigationplans.

Butte County. 2020. Butte County Community Wildfire Protection Plan 2020-2025. Updated April 23, 2020. Accessed April 7, 2022. https://www.osfm.fire.ca.gov/media/xsap3zcr/2020-btu-fireplan.pdf.

DOF. 2021a. E-4 Population Estimates for Cities, Counties, and the State, 2011-2020, with 2010 Census Benchmark. May 2021. Accessed March 2022.
https://dof.ca.gov/Forecasting/Demographics/estimates/estimates-e4-2010-2020/.

CALFIRE. 2008. Butte County Very High Fire Hazard Severity Zone in LRA. May 28, 2008. Accessed April 7, 2022. https://osfm.fire.ca.gov/media/6650/fhszl_map4.pdf.

CALFIRE. 2018. 2018 Strategic Fire Plan for California. August 22, 2018. Accessed April 7, 2022. https://osfm.fire.ca.gov/media/5590/2018-strategic-fire-plan-approved-08_22_18.pdf. 555
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 376
CALFIRE. 2019. Community Wildfire Prevention and Mitigation Report. February 22, 2019. https://www.fire.ca.gov/media/5584/45-day-report-final.pdf.

CALFIRE. 2022. “Fire Hazard Severity Zones.” Accessed April 7, 2022. https://osfm.fire.ca.gov/ divisions/community-wildfire-preparedness-and-mitigation/wildfire-preparedness/fire-hazardseverity-zones/.

City of Chico. 2017. Chico 2030 General Plan. Adopted April 2011. Amended March 2017. https://chico.ca.us/post/chico-2030-general-plan.

FEMA. 2022. Town of Paradise Wildfire Mitigation Projects. January 2022. Accessed April 7, 2022. https://www.fema.gov/sites/default/files/documents/fema_town-paradise-wildfire-mitigationprojects.pdf.

Paradise Fire Safe Council. 2008. Paradise Fire Safe Council Membership Guide. November 2008.

Accessed April 7, 2022. https://www.paradisefiresafe.org/wp-content/uploads/ pfsc_membership_guide.pdf.

Town of Paradise. 2011. Town of Paradise Emergency Operations Plan. November 2011. Accessed April 7, 2022. https://www.townofparadise.com/sites/default/files/fileattachments/community/ page/22311/2011_town_of_paradise_eop_w_supporting_docs-final_1-12.pdf.

U.S. Department of the Interior and U.S. Department of Agriculture (DOI and USDA). 2014. The National Strategy: The Final Phase in the Development of the National Cohesive Wildland Fire Management Strategy. April 2014. https://www.forestsandrangelands.gov/documents/strategy/ strategy/CSPhaseIIINationalStrategyApr2014.pdf.
556
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 377

3.20 Summary of Environmental Impacts
Table 3.20-1 summarizes the environmental impacts of the Proposed Project.

Appendix H, Mitigation, Monitoring and Reporting Program, summarizes the Town’s program to ensure compliance with all mitigation measures committed to in this PEIR and included below, and assigns responsibility and timeframe for implementation. As noted in Appendix H, and in accordance with Section 21083, Public Resources Code (CEQA Guidelines Section 15097 (a)), a public agency shall adopt a program for monitoring and reporting on the measures that it has imposed in an EIR or negative declaration to mitigate or avoid significant environmental effects. A public agency may delegate reporting or monitoring responsibilities to another public agency or private entity which accepts the delegation; however, until mitigation measures have been completed, the lead agency remains responsible for ensuring that implementation of the mitigation measures occurs in accordance with the program (CEQA Guidelines Section 15097 (a)). This Mitigation Monitoring and Reporting Program (MMRP) addresses the requirement.
557
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.com
Final Program Environmental Impact Report 378
Page Intentionally Blank
558
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.comFinal Program Environmental Impact Report 379 Table 3.20-1. Proposed Project Impact Summary Table
Impact Level of Significance Before Mitigation Mitigation Measure Level of Significance After Mitigation Agriculture and Forestry Resources Impact AG-1: 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 non-agricultural use No Impact Not Applicable No Impact
Impact AG-2: Conflict with existing zoning for agricultural use, or a Williamson Act contract No Impact Not Applicable No Impact
Impact AG-3: Conflict with existing zoning for, or cause rezoning of, forest land (as defined in PRC Section 12220(g)), timberland (as defined by PRC Section 4526), or timberland zoned Timberland Production (as defined by California Government Code Section 51104(g)) No Impact Not Applicable No Impact
Impact AG-4: Result in the loss of forest land or conversion of forest land to non-forest use No Impact Not Applicable No Impact
Impact AG-5: 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 Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
Air Quality Impact AIR-1: Conflict with or obstruct implementation of an applicable air quality plan Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
Impact AIR-2: Result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is nonattainment under an applicable federal or state ambient air quality standard Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
Impact AIR-3: Expose sensitive receptors to substantial pollutant concentrations Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
Impact AIR-4: Result in other emissions, such as those leading to odors, adversely affecting a substantial number of people Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
559
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.comFinal Program Environmental Impact Report 380 Impact Level of Significance Before Mitigation Mitigation Measure Level of Significance After Mitigation Biological Resources Impact BIO-1: 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 CDFW or USFWS: Special-Status Plant Species Significant Impact MM-BIO-1: Minimize Disturbance
Footprint MM-BIO-2: Special-status Plant Surveys MM-BIO-3: Special-status Plant Avoidance MM-BIO-4: Biological Monitoring and Worker Environmental Awareness Training MM-BIO-5: Restoration of Temporarily Disturbed Areas Less-Than-Significant Impact
Impact BIO-1: 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 CDFW or USFWS: Vernal Pool Crustaceans Significant Impact MM-BIO-1: Minimize Disturbance
Footprint MM-BIO-6: No Net Loss of Aquatic Resources MM-BIO-7: Sensitive Community Fencing MM-BIO-8: Dry Work Areas Less-Than-Significant Impact
Impact BIO-1: 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 CDFW or USFWS: Valley Elderberry Longhorn Beetle Significant Impact MM-BIO-1: Minimize Disturbance
Footprint MM-BIO-9: Mapping of Elderberry Shrubs and Section 7 Consultation MM BIO-10: No Net Loss of Elderberry Shrubs MM-BIO-11: Elderberry Transplanting MM BIO-12: Avoidance Area MM-BIO-13: Chemical Use MM-BIO-14: Mowing Less-Than-Significant Impact
Impact BIO-1: 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 CDFW or USFWS: Special-Status Fishes Significant Impact MM-BIO-15: Frac-Out Plan Less-than-Significant Impact
560
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.comFinal Program Environmental Impact Report 381 Impact Level of Significance Before Mitigation Mitigation Measure Level of Significance After Mitigation Impact BIO-1: 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 CDFW or USFWS: Special-status Amphibians and Reptiles Significant Impact MM-BIO-1: Minimize Disturbance
Footprint MM-BIO-6: No Net Loss of Aquatic Resources MM-BIO-7: Sensitive Community Fencing MM-BIO-8: Dry Work Areas MM-BIO-16: Western Pond Turtle Visual Encounter Surveys MM-BIO-17: Foothill Yellow-legged Frog Surveys MM-BIO-18: California Red-legged Frog Surveys. MM-BIO-19: Conduct Construction Activities during the Active Period for Giant Garter Snakes. MM-BIO-20: Minimize Potential Effects on Giant Garter Snake Habitat.

Less-Than-Significant Impact
Impact BIO-1: 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 CDFW or USFWS: MBTA and FGC-Protected Birds and Raptors Significant Impact MM-BIO-1: Minimize Disturbance
Footprint MM-BIO-21: MBTA and FGCProtected Bird and Raptor Surveys MM-BIO-22: Protocol Swainson’s Hawk Surveys MM-BIO-23: Nest Avoidance Less-Than-Significant Impact
Impact BIO-1: 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 CDFW or USFWS: Special-Status Bats Significant Impact MM-BIO-1: Minimize Disturbance
Footprint MM-BIO-24: Bat Surveys
Less-Than-Significant Impact
Impact BIO-1: 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 CDFW or USFWS: American Badger Significant Impact MM-BIO-1: Minimize Disturbance
Footprint MM-BIO-25: American Badger Detection Surveys
Less-Than-Significant Impact
561
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.comFinal Program Environmental Impact Report 382 Impact Level of Significance Before Mitigation Mitigation Measure Level of Significance After Mitigation Impact BIO-2: Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the CDFW or USFWS Significant Impact MM-BIO-1: Minimize Disturbance
Footprint MM-BIO-5: Restoration of Temporarily Disturbed Areas MM-BIO-6: No Net Loss of Aquatic Resources MM-BIO-7: Sensitive Community Fencing MM-BIO-8: Dry Work Areas Less-Than-Significant Impact
Impact BIO-3: Have a substantial adverse effect on state or federally protected wetlands Significant Impact MM-BIO-1: Minimize Disturbance
Footprint MM-BIO-5: Restoration of Temporarily Disturbed Areas MM-BIO-6: No Net Loss of Aquatic Resources MM-BIO-7: Sensitive Community Fencing MM-BIO-8: Dry Work Areas MM-BIO-26: State or Federally Protected Wetlands Mitigation Less-Than-Significant Impact
Impact BIO-4: 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 wildlife nursery sites No Impact Not Applicable No Impact
Impact BIO-5: Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance No Impact Not Applicable No Impact
Impact BIO-6: 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 Not Applicable No Impact
Cultural Resources Impact CUL-1: Cause a substantial adverse change in the significance of a historical resource pursuant to section 15064.5 Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
Impact CUL-2: Cause a substantial adverse change in the significance of an archaeological resource pursuant to section 15064.5 Significant Impact MM-CUL-1: Targeted
archaeological monitoring MM-CUL-2: Follow inadvertent discovery procedures Less-Than-Significant Impact
562
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.comFinal Program Environmental Impact Report 383 Impact Level of Significance Before Mitigation Mitigation Measure Level of Significance After Mitigation Impact CUL-3: Disturb any human remains, including those interred outside of formal cemeteries Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
Energy Impact ENG-1: Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction, operation, or maintenance Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
Impact ENG-2: Conflict with or obstruct a state or local plan for renewable energy or energy efficiency No Impact Not Applicable No Impact
Geology, Soils, and Paleontological Resources Impact GEO-1(a): Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: 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 No Impact Not Applicable No Impact
Impact GEO-1(b): Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: Strong seismic ground shaking Significant Impact MM-GEO-1: Minimize Geologic
Hazards
Less-than-Significant Impact
Impact GEO-1(c): Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: Seismic-related ground failure, including liquefaction Significant Impact MM-GEO-1: Minimize Geologic
Hazards
Less-than-Significant Impact
Impact GEO-1(d): Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: Landslides Significant Impact MM-GEO-1: Minimize Geologic
Hazards
Less-than-Significant Impact
Impact GEO-2: Result in substantial soil erosion or the loss of topsoil Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
Impact GEO-3: 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 Significant Impact MM-GEO-1: Minimize Geologic
Hazards
Less-than-Significant Impact
Impact GEO-4: Be located on expansive soil, as defined in Table 18-1B of the Uniform Building Code (1994), creating substantial direct or indirect risk to life or property Significant Impact MM-GEO-1: Minimize Geologic
Hazards
Less-than-Significant Impact
Impact GEO-5: 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 wastewater No Impact Not Applicable No Impact
563
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.comFinal Program Environmental Impact Report 384 Impact Level of Significance Before Mitigation Mitigation Measure Level of Significance After Mitigation Impact GEO-6: Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature
Significant Impact MM-GEO-2: Inadvertent Discovery
Protocol
Less-Than-Significant Impact
Greenhouse Gas Emissions Impact GHG-1: Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
Impact GHG-2: Conflict with an applicable plan, policy, or regulation adopted for the purpose of reduction the emissions of GHG No Impact Not Applicable No Impact
Hazards and Hazardous Materials Impact HAZ-1: Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials Significant Impact MM-HAZ-1: Vehicle Equipment
Access and Fueling
Less-than-Significant Impact
Impact HAZ-2: 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 Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
Impact HAZ-3: Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
Impact HAZ-4: 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 Significant Impact MM-HAZ-2: Cypress Lane Site
Specific Contaminated Soil Management Plan
Less-than-Significant Impact
Impact HAZ-5: 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 Not Applicable No Impact
Impact HAZ-6: Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan Significant Impact MM-HAZ-3: Road Closure
Restrictions
MM-HAZ-4: Rapid Demobilization
Plan
MM-HAZ-5 : Evacuation Warning
Procedures
MM-HAZ-6: Traffic Management
Plan
Less-than-Significant Impact
564
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.comFinal Program Environmental Impact Report 385 Impact Level of Significance Before Mitigation Mitigation Measure Level of Significance After Mitigation Impact HAZ-7: Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires Significant Impact MM-HAZ-1: Vehicle Equipment
Access and Fueling
MM-HAZ-7: Incorporate Fire
Prevention Measures
MM-HAZ-8: Incorporate Public
Safety Measures MM-HAZ-9: Wildland Fire Area
Less-than-Significant Impact
Hydrology and Water Quality Impact HYD-1: Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality Significant Impact MM-HAZ-1: Vehicle and Equipment
Access and Fueling MM-HYD-1: Stormwater Management and Treatment Plan MM-HYD-2: Construction Best Management Practices MM-BIO-15: Frac-out Plan Less-than-Significant
Impact
Impact HYD-2: 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 Impact
Not Applicable Less-than-Significant
Impact
Impact HYD-3(a): 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: Result in substantial erosion or siltation on or off-site Significant Impact MM-HYD-1: Stormwater
Management and Treatment Plan
Less-than-Significant
Impact HYD-3(b): 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: Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site Significant Impact MM-HYD-1: Stormwater
Management and Treatment Plan MM-HYD-3: Flood Protection Plan Less-than-Significant Impact
Impact HYD-3(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: Create or contribute runoff water that would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff Significant Impact MM-HYD-1: Stormwater
Management and Treatment Plan MM-HYD-3: Flood Protection Plan Less-than-Significant Impact
565
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.comFinal Program Environmental Impact Report 386 Impact Level of Significance Before Mitigation Mitigation Measure Level of Significance After Mitigation Impact HYD-3(d): 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: Impede or redirect flood flows Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
Impact HYD-4: In flood hazard, tsunami, or seiche zones, risk release of pollutants due to Project inundation Significant Impact MM-HYD-3: Flood Protection Plan Less-than-Significant Impact
Impact HYD-5: Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan Significant Impact MM-HYD-1: Stormwater
Management and Treatment Plan
Less-than-Significant Impact
Land Use and Planning Impact LU-1: Physically divide an established community No Impact Not Applicable No Impact Impact LU-2: Cause any 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 No Impact Not Applicable No Impact
Noise and Groundborne Vibration Impact NSE-1: Generate 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 in applicable standards of other agencies Significant Impact MM-NSE-1: Minimize Construction
Noise
Less-Than-Significant Impact
Impact NSE-2: Generate excessive groundborne vibration or groundborne noise levels Significant Impact MM-NSE-1: Minimize Construction
Noise
Less-Than-Significant Impact
Impact NSE-3: Be 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, expose people residing or working in the Project area to excessive noise levels Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
Population and Housing Impact POP-1: Induce substantial unplanned population growth in an area, either directly (e.g., by proposing new homes and businesses) or indirectly (e.g., through extension of roads or other infrastructure) Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
Impact POP-2: Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere No Impact Not Applicable No Impact
566
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.comFinal Program Environmental Impact Report 387 Impact Level of Significance Before Mitigation Mitigation Measure Level of Significance After Mitigation Public Services Impact PS-1(a): Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically 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 following public services: Fire Protection Significant Impact MM-HAZ-6: Traffic Management
Plan
Less-than-Significant Impact
Impact PS-1(b): Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically 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 following public services: Police Protection Significant Impact MM-HAZ-6: Traffic Management
Plan
Less-than-Significant Impact
Impact PS-1(c): Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically 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 following public services: Schools Significant Impact MM-HAZ-6: Traffic Management
Plan
Less-than-Significant Impact
Impact PS-1(d): Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically 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 following public services: Other Public Facilities Significant Impact MM-HAZ-6: Traffic Management
Plan
Less-than-Significant Impact
Recreation Impact REC-1: 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 Impact
Not Applicable Less-than-Significant
Impact
Impact REC-2: 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 Impact
Not Applicable Less-than-Significant
Impact
Transportation Impact TRA-1: Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities Significant Impact MM-HAZ-6: Traffic Management
Plan
Less-than-Significant Impact
567
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.comFinal Program Environmental Impact Report 388 Impact Level of Significance Before Mitigation Mitigation Measure Level of Significance After Mitigation Impact TRA-2: Conflict with or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b) Less-than-Significant Impact
Not Applicable Less-than-Significant
Impact
Impact TRA-3: Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) No Impact Not Applicable No Impact
Impact TRA-4: Result in inadequate emergency access Significant Impact MM-HAZ-6: Traffic Management Plan
Less-than-Significant Impact
Tribal Cultural Resources Impact TCR-1: Cause a substantial adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, or 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:
 Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k), or  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 PRC Section 5024.1. In applying the criteria set forth in subdivision (c) of PRC Section 5024.1, the lead agency will consider the significance of the resource to a California Native American tribe.

Significant Impact MM-TCR-1: Coordination with
Konkow Valley Band of Maidu and Mechoopda Indian Tribe MM-TCR-2: Tribal Cultural Monitoring Less-than-Significant Impact
Utilities and Service systems Impact UTIL-1: Require or result in the relocation or construction of new or expanded water, wastewater treatment, storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects Significant Impact MM-UTIL-1: Minimize Utility and
Service System Disruptions
Less-Than-Significant Impact
Impact UTIL-2: Have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years No Impact Not Applicable No Impact
Impact UTIL-3: Result in a determination by the wastewater treatment provider, which serves or may serve the Project, that it has inadequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments No Impact Not Applicable No Impact
568
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.comFinal Program Environmental Impact Report 389 Impact Level of Significance Before Mitigation Mitigation Measure Level of Significance After Mitigation Impact UTIL-4: 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 No Impact Not Applicable No Impact
Impact UTIL-5: Comply with federal, state, and local management and reduction statutes and regulations related to solid waste No Impact Not Applicable No Impact
Wildfire Impact FIRE-1: Substantially impair an adopted emergency response plan or emergency evacuation plan Significant Impact MM-HAZ-3: Road Closure
Restrictions MM-HAZ-4: Rapid Demobilization Plan MM-HAZ-5: Evacuation Warning Procedures MM-HAZ-6: Traffic Management Plan Less-than-Significant Impact
Impact FIRE-2: Exacerbate wildfire risks due to slope, prevailing winds, and other factors, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire Significant Impact MM-HAZ-1: Vehicle and Equipment
Access and Fueling MM-HAZ-7: Incorporate Fire Prevention Measures MM-HAZ-8: Incorporate Public
Safety Measures MM-HAZ-9: Wildland Fire Area
Less-than-Significant Impact
Impact FIRE-3: 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 Significant Impact MM-HAZ-1: Vehicle and Equipment
Access and Fueling MM-HAZ-7: Incorporate Fire Prevention Measures MM-HAZ-8: Incorporate Public
Safety Measures MM-HAZ-9: Wildland Fire Area
Less-than-Significant Impact
Impact FIRE-4: 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 Significant Impact MM-HYD-1: Stormwater
Management Plan MM-HYD-3: Flood Protection Plan MM-GEO-1: Minimize Geologic Hazards Less-than-Significant Impact
569
Paradise Sewer Project | Final Program Environmental Impact Report Environmental Impact Analysis
hdrinc.comFinal Program Environmental Impact Report 390 Page Intentionally Blank
570
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 391

4. Other CEQA Considerations

4.1 Introduction
In addition to identifying the potential for physical effects of the Proposed Project and measures to mitigate any identified significant effects (Chapter 3, Environmental Impact Analysis), the CEQA Guidelines also require evaluation of the following topics:
 Significant irreversible environmental changes
 (CEQA Guidelines Section 15126.2 [d])
 Significant and unavoidable impacts (CEQA Guidelines Section 15126.2[c])  Growth-inducing impacts (CEQA Guidelines Section 15126[e])  Cumulative impacts (CEQA Guidelines Section 15130)

4.2 Irreversible Impacts
CEQA Guidelines Section 15126.2(d) requires that an EIR must identify irreversible impacts (also referred to as irreversible environmental changes) that may be caused by a project if it is implemented.

Irretrievable commitments of resources should be evaluated to justify current consumption. For the purpose of this analysis, the irreversible impacts described below could occur as a result of the Proposed Project.

Other than at the transition between Skyway and Southgate Avenue before crossing SR 99 (Chapter 2 Project Description), the Proposed Project would include activities primarily within the existing ROW and at the Chico WPCP. Constructing the Core Collection System, the Export Pipeline System, and the Extended Collection System, would involve using vehicles and heavy equipment that would use nonrenewable fossil fuels to transport construction materials, equipment, and construction workers to and from the work sites. Materials to be used for constructing the Core Collection System, the Export Pipeline System, and the Extended Collection System would include PVC pipe, metals, concrete, asphalt, backfill material and associated materials for installation such as slurry, pipe fittings, wire, and conduit.

Overall, construction activity included as part of the Proposed Project would not consume a substantial quantity of resources that would deplete current resources and prohibit their future use, such as fossil fuel energy, because work sites would be limited in size and duration (HDR 2022). During construction, the Town’s compliance with applicable BCAQMD regulations would reduce potential air quality effects.

As discussed in Section 3.3 Air Quality, the Proposed Project will also implement best practices as required by BCAQMD Rules 200 and 205 to reduce fugitive dust emissions. Finally, the Proposed Project will implement BCAQMD’s best practice measures to minimize diesel particulate matter from construction equipment. As a result, impacts on air quality were found not to be significant.

Energy usage during construction and operation and maintenance would not result in irreversible environmental changes. As discussed in Section 3.6 Energy, a multitude of state regulations are aimed at improving vehicle fuel efficiency, including Pavley Standards (AB 1493), the Advanced Clean Cars 571
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 392
Program, and the In-Use Off-Road Diesel-Fueled Fleets Regulation. Required conformance of vehicles and equipment to the regulations would minimize wasteful, inefficient, or unnecessary consumption of transportation fuel during construction.

The Proposed Project would consist of a system of gravity sewers, pump stations, force mains and associated structures and conduits. Gravity sewers do not use energy; the wastewater flows by gravity through the pipes based on the movement of the effluent from higher to lower elevations. The pump stations associated with the Core Collection System would consume approximately 601,000 kWh/year of electrical energy. Refer to Appendix I, Pump Station Energy Consumption Calculation, for the detailed energy demand calculations. This increase in electricity consumption represents a small fraction of the total energy demand in Butte County. As it relates to energy efficiency and sustainability, the Chico WPCP operates a 1.1-megawatt, solar photovoltaic facility providing electric power to the WPCP, which reduces the plant’s use of utility power by approximately 35 percent. Further, a 335- kilowatt co-generator is on site that uses methane produced by the plant processes as a fuel source to produce electricity, which is used at the WPCP (City of Chico 2021a). Therefore, energy efficiency and sustainability measures have already been built into the design of the Chico WPCP. While the Proposed Project would increase the amount of energy needed to treat wastewater at the existing Chico WPCP, it would be well within current capacity at the time of connection and would not result in an inefficient use of energy. As a result, impacts on energy were found to be not significant.

A review of the USGS Mineral Resources Online Spatial Data indicates that past or present mineral resources occur within the Core and Extended Collection Systems areas (USGS 2021). Past or present mineral resources may occur along the Skyway segment of the Export Pipeline System in unincorporated Butte County (USGS 2021). However, the Skyway segment of the Export Pipeline System would be constructed underground within the Butte County ROW. None of the parcels immediately adjacent to the Export Pipeline System are designated for mineral resource conservation or mining and mining is not allowed in any of those zones. As a result, the potential for mineral resources to be disturbed is low.

The proposed sewer collection system would replace private septic systems within the Town. Currently, the lack of municipal sewer infrastructure poses an environmental threat to groundwater and surface water quality, both precious regional resources. As discussed in Section 3.10, Hydrology and Water Quality, implementing a municipal wastewater collection system and reducing the reliance on private septic tanks and leach fields as a result of the Proposed Project could improve groundwater and surface water quality in the study area by removing the potential for contact with sewage, and removing the discharge of sewage into the ground within the sewer service area. Additionally, as discussed in Section 3.18, Utilities and Service Systems, the Proposed Project would connect to an existing and established treatment system at the Chico WPCP that has adequate capacity to serve the Proposed Project’s projected wastewater demand.

In summary, vehicle and equipment operation associated with the Proposed Project activities would require using nonrenewable fossil fuels. As discussed in Section 2.5.1.3 Equipment, Crews, and Materials (Core Collection System) and Section 2.5.2.3 Equipment, Crews, and Materials (Export Pipeline System), construction would require use of materials such as PVC pipe, metals, concrete, asphalt, and backfill material, which are also nonrenewable resources. These materials and the 572
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 393
necessary volume that would be used for the Proposed Project would be in line with standard pipeline construction and would not noticeably reduce the availability of these resources for other project uses.

Under CEQA Guidelines Section 15127, an analysis of irreversible changes is required for adoption by a LAFCo of a resolution making determinations. However, the information required by Section 15126.2(c) concerning irreversible changes, need be included only in EIRs prepared in connection with any of the following activities:
a. The adoption, amendment, or enactment of a plan, policy, or ordinance of a public agency; b. The adoption by a local agency formation commission of a resolution making determinations; or c. A project which will be subject to the requirement for preparing an environmental impact statement pursuant to the requirements of the National Environmental Policy Act of 1969, 42 USC 4321 – 4347.

4.3 Significant and Unavoidable Impacts
CEQA Guidelines Section 15126.2(c) requires an EIR to discuss significant effects, including those that can be mitigated but not reduced to a level of insignificance. The CEQA Guidelines state that:
(w)here there are impacts that cannot be alleviated without imposing an alternative design, their implications, and reasons why the project is being proposed, notwithstanding their effect, should be described.

Table 4.3-1 summarizes those resource topic areas found to have the potential for significant impacts resulting from the Proposed Project, as analyzed in Chapter 3. Significant impacts would occur for the following resource topic areas: biological resources; cultural resources; geology, soils and paleontological resources; hazards and hazardous materials; hydrology and water quality; noise and groundborne vibration; public services; transportation; tribal cultural resources; utilities and service systems; and wildfire. However, as discussed in detail in the Chapter 3 resource sections and summarized below, all impacts could be mitigated to a less than significant level, and no significant and unavoidable impacts are anticipated.

Table 4.3-1. Significant Impacts Mitigated from the Proposed Project Resource Topic Area
Significant Impacts
from the Proposed
Project
Effectively
Mitigated to Less
than Significant
Significant and
Unavoidable
Impacts
Biological Resources
BIO-1: 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 CDFW or USFWS
 
BIO-2: Have a substantial adverse effect on any
riparian habitat or other sensitive natural community
identified in local or regional plans, policies, and
regulations or by the CDFW or USFWS
 
573
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 394
Significant Impacts Effectively Significant and
Resource Topic Area from the Proposed Mitigated to Less Unavoidable Project than Significant Impacts
BIO-3: Have a substantial adverse effect on state or
federally protected wetlands  
Cultural Resources
CUL-2: Cause a substantial adverse change in the
significance of an archaeological resource pursuant to
section 15064.5
 
Geology, Soils, and Paleontological Resources
GEO-1(b): Directly or indirectly cause potential
substantial adverse effects, including the risk of loss, injury, or death involving: Strong seismic ground
shaking
 
GEO-1(c): Directly or indirectly cause potential
substantial adverse effects, including the risk of loss, injury, or death involving: Seismic-related ground
failure, including liquefaction
 
GEO-1(d): Directly or indirectly cause potential
substantial adverse effects, including the risk of loss, injury, or death involving: Landslides
 
GEO-3: 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
 
GEO-4: Be located on expansive soil, as defined in
Table 18-1B of the Uniform Building Code (1994),
creating substantial direct or indirect risk to life or property
 
GEO-6: Directly or indirectly destroy a unique
paleontological resource or site or unique geologic
feature
 
Hazards and Hazardous Materials
HAZ-1: Create a significant hazard to the public or the environment through the routine transport, use, or
disposal of hazardous materials
 
HAZ-4: 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
 
HAZ-6: Impair implementation of or physically interfere with an adopted emergency response plan or
emergency evacuation plan
 
HAZ-7: Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or death involving wildland fires
 
574
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 395
Significant Impacts Effectively Significant and
Resource Topic Area from the Proposed Mitigated to Less Unavoidable Project than Significant Impacts
Hydrology and Water Quality
HYD-1: Violate any water quality standards or waste
discharge requirements or otherwise substantially
degrade surface or ground water quality
 
HYD-3(a): 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: Result in substantial erosion or siltation on or offsite  
HYD-3(b): 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: Substantially increase the rate or amount of
surface runoff in a manner which would result in
flooding on- or off-site
 
HYD-3(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: Create or contribute runoff water that would
exceed the capacity of existing or planned storm water
drainage systems or provide substantial additional
sources of polluted runoff
 
HYD-4: In flood hazard, tsunami, or seiche zones, risk
release of pollutants due to Project inundation  
Noise and Groundborne Vibration
NSE-1: Generate 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 in applicable
standards of other agencies
 
NSE-2: Generate excessive groundborne vibration or
groundborne noise levels  
Public Services
PS-1(a): Result in substantial adverse physical impacts associated with the provision of new or physically
altered governmental facilities, need for new or
physically 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 following public services: Fire Protection
 
575
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 396
Significant Impacts Effectively Significant and
Resource Topic Area from the Proposed Mitigated to Less Unavoidable Project than Significant Impacts
PS-1(b): Result in substantial adverse physical impacts associated with the provision of new or physically
altered governmental facilities, need for new or
physically 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 following public services:

Police Protection
 
PS-1(c): Result in substantial adverse physical impacts associated with the provision of new or physically
altered governmental facilities, need for new or
physically 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 following public services:

Schools
 
PS-1(d): Result in substantial adverse physical impacts associated with the provision of new or physically
altered governmental facilities, need for new or
physically 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 following public services: Other Public Facilities
 
Transportation
TRA-1: Conflict with a program plan, ordinance or
policy addressing the circulation system, including
transit, roadway, bicycle and pedestrian facilities
 
TRA-4: Result in inadequate emergency access  
Tribal Cultural Resources
TCR-1: Cause a substantial adverse change in the
significance of a tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, or 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:
 Listed or eligible for listing in the California
Register of Historical Resources, or in a local
register of historical resources as defined in
PRC Section 5020.1(k), or
 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 PRC
 
576
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 397
Significant Impacts Effectively Significant and
Resource Topic Area from the Proposed Mitigated to Less Unavoidable Project than Significant Impacts
Section 5024.1. In applying the criteria set
forth in subdivision (c) of PRC Section
5024.1, the lead agency shall consider the
significance of the resource to a California
Native American tribe
Utilities and Service Systems
UTIL-1: Require or result in the relocation or
construction of new or expanded water, wastewater
treatment, storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant
environmental effects
 
Wildfire
FIRE-1: Substantially impair an adopted emergency
response plan or emergency evacuation plan  
FIRE-2: Exacerbate wildfire risks due to slope,
prevailing winds, and other factors, and thereby expose project occupants to pollutant concentrations from a
wildfire or the uncontrolled spread of a wildfire
 
FIRE-3: 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
 
FIRE-4: 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
 

4.4 Growth Inducing Impacts
CEQA Guidelines Section 15126(e) requires an EIR to include an analysis of the growth-inducing impacts of the project. CEQA Guidelines Section 15126.2(d) states that the analysis of growth-inducing impacts should discuss the ways in which the program or project could foster economic or population growth (such as by removing obstacles to growth) or the construction of additional housing, either directly or indirectly, in the surrounding environment.

The primary need for the Proposed Project is public health and safety. However, the secondary need is to accommodate the return of residents and commercial businesses to Paradise. A detailed discussion of the Need and Objectives of the Proposed Project is in Section 2.3 of this PEIR.

In general, a project can be considered growth inducing if it meets one or more of the following criteria:
 Fosters population growth directly or indirectly
 Fosters economic expansion directly or indirectly
577
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 398
 Establishes precedent-setting actions (such as innovation or expansion beyond the existing limits of the study area)
 Results in the development or encroachment in an isolated or adjacent area of open space  Removes an obstacle to growth (such as a major expansion of a wastewater treatment plant).

Examples of projects that are growth inducing might be the expansion of urban services into a previously unserved or underserved area, the creation or extension of transportation links, or the removal of major obstacles to growth. It is important to note that these direct forms of growth have secondary effects of expanding the size of local markets and attracting additional economic activity to the area. Typically, the growth-inducing potential of a project would be considered significant if it stimulates population growth or a population concentration above what is assumed in local and regional land use plans, or in projections made by regional planning authorities such as the BCAG. Significant growth impacts could also occur if the project provides infrastructure or service capacity to accommodate growth levels beyond those anticipated by local or regional plans and policies. It should not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment (CEQA Guidelines Section 15126.2(e).

The Proposed Project is a part of the Town’s recovery efforts from the 2018 Camp Fire and would address the need for a municipal wastewater collection, treatment and disposal solution, to improve and replace the private, failing or damaged septic systems (Section 2.3 Project Need and Objectives).

As a result, the Proposed Project is intended to foster population regrowth, support construction of multi-family and affordable housing, and generate economic recovery within the Town (Section 2.3 Project Need and Objectives). As discussed in Section 3.13, Population and Housing, a substantial decrease of approximately 83 percent of the population in Paradise occurred as a result of the 2018 Camp Fire. Any inducement of the population growth that might occur as a result of the Proposed Project in the shorter term would be a return and/or regrowth and repopulation toward pre-fire levels.

Any growth beyond pre-fire levels that could occur in the longer term would be consistent with the Town of Paradise 2022-2030 Housing Element Update (Town of Paradise 2022a). This growth would be limited by (1) the current boundaries of the Town, (2) the capacity of the Proposed Project infrastructure, and (3) the Chico WPCP operational (disposal permit allowance) and existing plant infrastructure (facilities limitations) capacity. In either case, implementation of the Proposed Project would not, in and of itself, cause the growth, but it would accommodate growth, eliminating an obstacle to planned growth within the Town. The Proposed Project would not provide new service to the City or the County outside of the Town boundaries, so would not induce growth to the City or other communities within the County outside of the Town. Some previous residents of the Town may choose to return when services and housing become available, which could slightly reduce the City population; however, estimating exact numbers would be speculative.

The Town of Paradise 2022-2030 Housing Element Update (Town of Paradise 2022a) states: “the proposed sewer collection system and treatment will facilitate regrowth, replace failed septic systems, provide for affordable housing, and improve the local economy”. In addition, the plan outlines a proposed SSA that will “serve approximately 1,400 parcels through the Skyway, Clark Road, and Pearson Road corridors, which represents most businesses in Paradise and provide for future development of more multi-family residences, which is currently limited because of septic system constraints (Town of Paradise 2022a). This proposed SSA is consistent in geography with the Core 578
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 399
Collection Area included in the Proposed Project. In addition, as discussed in Section 3.11.1.1 Town of Paradise General Plan (Land Use), the Proposed Project is also consistent with the broader goals and policies being included in the Town of Paradise General Plan updates.

The Housing Element includes implementation measures to guide Town staff, decision makers, and housing stakeholders by “translat(ing) goals and policies into actions”. The following measures demonstrate alignment of the Proposed Project with the Town of Paradise 2022-2030 Housing Element Update (Town of Paradise 2022a), and in some cases, how the Proposed Project is key to the Town meeting identified goals and policies:
 HI-1: Reduce Infrastructure Constraints to Development – Continue to reduce infrastructure constraints to new development, particularly those constraints associated with wastewater disposal. The General Plan authorizes an ongoing identification of infrastructure and service limitations including those related to sanitary waste disposal which inhibit housing development.  HI-5: Density Bonus and Other Opportunities for Increased Density – Revise the density bonus ordinance (Chapter 17.44) to be consistent with State law, including AB 2345 and Government Code Sections 65915 and 65917 and identify incentives for affordable housing development.

Perform the rezonings described in Chapter 4 (of the 2022-2030 Housing Element of the Town of Paradise General Plan), for key parcels in the (sewer service area) and establish a Sewer Service Overlay Zone to allow increased densities up to 30 dwelling units/acre in the (sewer service area) to accommodate affordable housing.
 HI-8: Small Lot Consolidation and Development – Continue to encourage consolidation of small multi-family parcels as well as small, commercially designated parcels appropriate for residential use. This program can facilitate the development of affordable housing by creating lots large enough to accommodate denser multi-family residential projects. The planned sewer system is anticipated to also be an impetus for lot consolidation.

Often, when specific data relating to growth that might be induced are available, it is possible, based on historic averages or other data, to develop a reasonable forecast of the amount of new development that could be accommodated by the expanded capacity. For example, when the capacity of utility systems or other infrastructure is expanded into a new area or infrastructure is sized to serve a larger population. The return of the Town’s population (that is, regrowth) to Paradise is driven by a disaster and, if it occurs, will occur only over an extended period of time. In their Provisional Long-Term Regional Growth Forecasts 2018-2040 (BCAG 2019b), BCAG forecasted a Low, Medium, and High Scenario for total housing growth for Paradise that reflects -31 percent, -13 percent, or 6 percent growth, respectively, between pre-fire conditions in 2018 and 2040. In other words, in the low and medium forecasts, it is not anticipated that the Town will even recover to pre-fire conditions until after 2040. The assumptions for these forecasts did not include construction of the sewer system; estimating if and how much these forecasts could change with implementation of the Proposed Project would be speculative, at best. Further, in the Post Camp Fire Regional Population and Transportation Study (Fehr and Peers 2021) prepared for BCAG in 2021, key findings in the housing and employment forecast included that there would be a reduction in total county housing count for each forecast year as compared to findings in a previous study in 2020, partially because the DOF lowered their population projections for all of Butte County (Fehr & Peers 2021). Further, specific to the Town, the report states “In addition to the countywide reduction, Paradise is expected to have slower growth (as compared to 579
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 400
their 2020 study) in both near and long-term forecasts, with Chico’s growth making up the difference” (Fehr and Peers 2021).

In The Demography of Disasters (Karacsonyi et al. 2021), a study and comparison of recent large-scale worldwide disasters, the authors find:
…there is inevitably short- to medium-term population loss as many people temporarily move away from danger and the loss of services, infrastructure and economic support. The return of this population has to be phased over a long period as the city is rebuilt, but a portion of this population may never return, or a different demographic or social group replaces some of those who have left. The challenge of recovery and adaptation is correctly identifying and anticipating this demographic change in order to adopt approaches that suit the altered settlement. Within this change are activities and strategies to build back better, and to enhance both resilience and sustainability” (King and Gurtner 2021).

The authors conclude that “rather than traditional planning premised on anticipated future growth and development, post-disaster recovery should be prepared to plan-to-scale or right sizing for greater resilience and sustainability (King and Gurtner 2021).” Implementation of the Proposed Project allows for this scalable regrowth over time, but forecasting the specific timing or level of population recovery over a 30-year horizon would be speculative and would not “constitute substantial evidence” at this time (CEQA Guidelines Section 15064 [f][5]).

For the most part, the Core Collection system would not induce growth because it replaces failed or failing septic systems in what was already a concentrated area for businesses and housing (Section 2.5.1 Core Collection System). According to the Town of Paradise 2022-2030 Housing Element Update (Town of Paradise 2022a), key parcels in the sewer service area will require rezoning, and a Sewer Service Overlay Zone was established to allow increased densities up to 30 dwelling units per acre in the sewer service area (Town of Paradise 2022a). The main purpose of that rezoning is to accommodate affordable multifamily development that was not possible with only septic. The Proposed Project is consistent with the goals and policies in the Housing Element as it would serve most businesses in the Town and provide for future development of more multi-family residences, which is currently limited because of septic system constraints. As discussed in Section 2.5.1 Core Collection System, the estimated maximum wastewater conveyance and treatment need for the sewer service area is 464,000 gallons per day (0.464 mgd). This sewer estimate accounts for current and future estimated growth consistent with the current Town of Paradise General Plan and updated Town of Paradise 2022-2030 Housing Element and would be realized progressively over the projected 30-year planning horizon (Town of Paradise and Quad Consultants 2008, Town of Paradise 2022a). This flow limit will also be contained within the inter-municipal agreement being developed between the Town and the City.

The Expanded Collection System is for a broader geographic area and would allow development to occur in additional areas and forms within the Town boundaries, such as multifamily rather than single family housing. However, this population growth is still limited, as it would be contained within the existing Town boundaries and would be controlled by the permits issued by the Town. Parcels in the 580
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 401
Extended Collection System might want to connect in the future (either before or after the 30-year planning horizon), prior to (or in lieu of) complete build-out of the Core Collection System. If so, those parcels in the Extended Collection System could be allowed to connect, as long as the total flow from the Core Collection System and Extended Collection System remained at or below 0.464 mgd. Further, as stated in Chapter 2 Project Description, the proposed sewer system would not extend to other cities or counties or benefit populations outside of the Town.

Paradise lost 83 percent of its population. Thus, return of that population would not place a burden on existing community systems which remained in place after the Camp Fire. Assessments of the effects of the Proposed Project on these community resources are included in Chapter 3 (Section 3.6 Energy,

3.14 Public Services, 3.15 Recreation, and 3.18 Utilities and Service Systems) and no growth inducing effects on these Town’s community services and resources over pre-fire conditions, at which level they were designed to support, were identified. A population increase above the recovery level is, at best, speculative, but as noted previously, would be expected to occur gradually over time.

As discussed in Section 3.13 Population and Housing, all construction jobs associated with the Proposed Project would be temporary and many of those jobs could be filled by the current workforce within the region. However, some workers could become permanent residents as part of the Town’s short-term repopulation growth. During operation and maintenance, as discussed in Chapter 2 Project Description, about 5–10 permanent employees would be required to serve the Proposed Project. The Town may hire additional staff to handle these operation and maintenance activities. The increase in permanent jobs from operation and maintenance, however, would not be at a level that would cause substantial or unplanned growth within the area or necessitate the construction of additional housing or business services specifically for the minimal number of staff that would be employed long term for operation and maintenance at the facilities.

There would be no precedent-setting action that might trigger expansion of the Town as the proposed sewer system would not change Town boundaries and does not allow for service beyond those boundaries. As such, there would be no resulting development or encroachment to isolated or adjacent areas of open space. Further, the Proposed Project would not trigger unplanned expansion of the existing Chico WPCP. The proposed sewer service is within the current capacity, facility function, and purpose of the Chico WPCP. Section 2.4.2 Chico Water Pollution Control Plant provides a brief description of the existing Chico WPCP facilities and the City’s planned expansion of the facility, which will be evaluated in a separate CEQA process and is not a part of this PEIR. Costs associated with meeting future regulatory requirements and system upgrades can be spread over a larger population and will ultimately reduce the per capita costs of wastewater treatment and disposal. Regionalization also increases the technical and economic feasibility of a higher level of wastewater treatment, allowing the treated water to be a resource for the communities instead of merely being a waste. In support of this goal, the City of Chico Municipal Code (CMC) Section 15.40.285 sets forth procedures and guidance for regional connections to the Chico WPCP.

Finally, the CEQA Guidelines state that growth inducement could occur if an obstacle to growth in the surrounding environment is removed, such as a major expansion of a wastewater treatment plant (CEQA Guidelines Section 15126.2(e)). The Proposed Project is intended to foster economic growth and population growth within the Town through an improved wastewater system. However, (1) much of 581
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 402
this growth would be in the context of regrowth and repopulation since the 2018 Camp Fire, (2) all growth would be consistent with the Town of Paradise 2022-2030 Housing Element Update (Town of Paradise 2022a), and (3) all growth would be contained within existing Town boundaries. Therefore, given the parameters imposed on the Proposed Project so as to remain consistent with the Town of Paradise General Plan and updated Town of Paradise 2022-2030 Housing Element (Town of Paradise and Quad Consultants 2008, Town of Paradise 2022a), compliant with the inter-municipal agreement being created between the City and Town, and remain within Town boundaries, as assumed in this PEIR, the Proposed Project would not be considered growth inducing.

4.5 Cumulative Impacts
CEQA require that EIRs include a discussion of cumulative impacts, specifically stating:
"Cumulative impacts" refer to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts.
(a) The individual effects may be changes resulting from a single project or a number of separate projects.
(b) The cumulative impact from several projects is the change in the environment which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects.

Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time (CEQA Guidelines Section 15355).

According to the CEQA Guidelines, “cumulatively considerable” means that “the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.” (CEQA Guidelines Section 15065(a)(3))
CEQA Guidelines also provide guidelines for assessing the potential for proposed projects to contribute to cumulative impacts when the project would include implementing measures (including mitigation) to reduce effects as defined in previously approved plans or regulations:

A lead agency may determine that a project’s incremental contribution to a cumulative effect is not cumulatively considerable if the project will comply with the requirements in a previously approved plan or mitigation program (including, but not limited to, water quality control plan, air quality attainment or maintenance plan, integrated waste management plan, habitat conservation plan, natural community conservation plan, plans or regulations for the reduction of greenhouse gas emissions) that provides specific requirements that will avoid or substantially lessen the cumulative problem within the geographic area in which the project is located (CEQA Guidelines Section 15064 (h)(3)).
582
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 403
Further, the CEQA Guidelines state that “the mere existence of significant cumulative impacts caused by other projects alone shall not constitute substantial evidence that the proposed project’s incremental effects are cumulatively considerable” (CEQA Guidelines Section 15064 (h)(4)).

4.5.1 Methods Used in the Cumulative Analysis
Two methods can be used for cumulative impact analysis (CEQA Guidelines Section 15130). In the list approach, the lead agency identifies related projects or activities that could add to the proposed project’s environmental impacts. In the projection, or plan, approach, the lead agency relies on projections in an adopted planning document or prior environmental document. This PEIR uses the list approach.

The following terminology is used in this PEIR to describe the various levels and types of environmental impacts associated with the Proposed Project:
 Cumulative impact: As defined in CEQA Guidelines Section 15355, a cumulative impact consists of an impact that is created as a result of the combination of the project evaluated in the EIR together with other projects causing related impacts.  Significance threshold: Consistent with thresholds used to evaluate the impacts resulting from the Proposed Project in Chapter 3, this is the criterion used in the EIR to determine whether the magnitude of a cumulative environmental impact would be significant.  Significant cumulative impact: A cumulative impact is considered significant if it would result in a substantial adverse change in the physical conditions of the environment, as determined by whether it exceeds the applicable significance threshold.  Cumulatively considerable: Pursuant to CEQA Guidelines Section 15065(a)(3), “cumulatively considerable” means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, other current projects, and probable future projects. Where a lead agency is examining a project with an incremental effect that is not “cumulatively considerable,” the lead agency need not consider that effect significant (CEQA Guidelines Section 15130).

Table 4.5-1 lists and describes the reasonably foreseeable probable future projects and activities considered for the cumulative impact analysis. This list of foreseeable probable future projects and activities was developed based on a review of the Town, City, Butte County, and BCAG websites and input from with Susan Hartman, the Town Planning Director. Construction schedules are estimated for the purpose of informing a cumulative analysis and will be refined as project planning proceeds.

The cumulative condition and activities, including a resource-specific analysis of the potential cumulative effects when the Proposed Project is added to those cumulative activities. s discussed in Section 4.5.2, Cumulative Impact Analysis.
583
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 404
Table 4.5-1. Cumulative Activities
Project Name Description Activity
Location Sponsor Timeframe
Chico WPCP
Condition, Regulatory,
and Capacity-Driven
Upgrades
In the future, the City will implement a series of projects at the Chico WPCP to (a) accommodate expansion needs
due to development within Chico and the potential
addition of the Town’s wastewater flow, (b) address the deteriorated condition of some existing facilities, and (c) meet more stringent regulatory requirements as defined
by the renewed NPDES discharge permit. Treatment of
the Town’s wastewater is being included in the planning of the Chico WPCP projects. The first projects contemplated are addition of a secondary clarifier; emergency effluent bypass, storage and return improvements; and various
near-term condition-driven improvements involving
replacement of equipment.

Chico City of
Chico
2022 to
2057
Paradise Irrigation
District Project Water
Intertie
Assemblyman James Gallagher and Jim Nielsen
introduced Assembly Bill 36, which would fast-track the Paradise Sewer Project and the Paradise Irrigation District Project Water Intertie. The water intertie would allow the sale of unused surface water in PID reservoirs, to help make up for losing most of its customers after the fire. It would involve transporting water to Chico. In 2020,
Gallagher made this proposal linked with PID and the
California Water Service Chico Division. The bill is
sponsored by the Town, PID, and the State Building and
Construction Trades Council of California. At this time, it is uncertain if the project is viable or moving forward by Paradise Irrigation District.

Paradise
and Chico
PID March 2020
to unknown
Tuscan Ridge Project The project is to build an on-site sewage wastewater treatment and disposal facility to serve as a temporary workers camp for those who were involved in the recovery and rebuilding efforts of facilities and properties damaged during the Camp Fire. The project Notice of Exemption
was received and posted in 2019. Its exempt status was
declared emergency. At this time, the facility is being used for various equipment staging intermittently.
3100
Skyway in
Paradise
Regional
Board
2019 to
current
City of Chico Nitrate
Plan
Nitrate Area 3N, Phase 5, Unit 3, Northwood
Woodcourt: Sanitary sewer installation. The project
included the placement of approximately 5,200 linear feet of sanitary sewer main pipe, installation of sanitary sewer laterals, and trench replacement. (Work completed
12/9/2020; Notice of Completion 12/23/2021)
Nitrate Area 3S, Phase 6, Unit 6, Nord: The project
included installation of 1,650 linear feet of 10-inch sanitary sewer pipe, 1,200 linear feet of 8-inch sanitary sewer pipe, 800 linear feet of 6- inch sanitary sewer pipe, and 950 linear feet of 4-inch sanitary sewer lateral. (Project
accepted 1/8/2021; Notice of Completion 1/19/2021)
Chico City of
Chico
2020 to
current
Paradise Transit
Center
The intent of the project is to provide a location for transit users to centrally access the B-Line in Paradise and also Paradise BCAG 2018 to
2023
584
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 405
Project Name Description Activity
Location Sponsor Timeframe
enhance the downtown multi modal atmosphere. The
project has tentatively been allocated FTA funding and is anticipated to be allocated in 2022 for construction in 2023.

Town of Paradise
Recovery Projects,
Road Repairs
On-System Road Rehabilitation: This project includes
32 miles of on-system roadway rehabilitation, consisting of asphalt concrete overlays and full depth roadway section replacement for areas with severe pavement damage. Onsystem roads are public roads that are a part of the federal-aid system, and do not include local roads or rural minor collectors.

Off-System Road Rehabilitation: This project includes
47 miles of off-system roadway rehabilitation, consisting of asphalt concrete overlays and full depth roadway section replacement for areas with severe pavement damage. Offsystem roads are public roads that are not part of the federal aid system, and include local roads and rural minor collectors.

Paradise Town of
Paradise
2022-2025
Town of Paradise
Recovery Projects,
Damage Repairs
On-System Culvert Replacements: This project includes
replacement of damaged culverts, including restoration of the roadway section above the pipe at various locations, along on-system roads to improve safety and provide safe and effective management of storm runoff.

On-System Hardscape Replacement: This project will
remove and replace existing damaged concrete curb,
gutter and sidewalk, lighting, planters, and amenities at 30 locations town-wide to improve safety and pedestrian
accessibility along on-system roads.

On-System Sign Replacement: This project will replace
123 damaged roadway signs at various locations along
on-system roads.

Off-System Culvert Replacements: This project includes
replacement of damaged culverts, including restoration of the roadway section above the pipe at various locations, along off-system roads to improve safety and provide safe and effective management of storm runoff.

Paradise Town of
Paradise
2022
Town of Paradise
Recovery Projects,
Road Widening
Upper Skyway Widening: This project includes the
widening of Skyway between Bille Road and Pentz Road
(2.7 miles) and the addition of a 12-feet wide center turn lane, increased shoulder widths, and a multi-use pathway.

This project is currently a high priority, however wholly unfunded and may not proceed.

Upper Clark Road Widening: This project includes the
widening of Clark Road between Wagstaff Road and
Skway (1.5 miles) and the addition of a 12-feet wide
center turn lane, increased shoulder widths, and a multiuse pathway. This project is currently a high priority, however wholly unfunded and may not proceed.

Roe Road Extension Phases 1&2: This project includes
Paradise Town of
Paradise
2022-2027
585
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 406
Project Name Description Activity
Location Sponsor Timeframe
the construction of an extended Roe Road between Pentz
Road and Clark Road, establishing a southerly east-west connection to South Libby Road, Sawmill Road and
Edgewood Road. The roadway would include travel lanes
and a multi-use pathway. This project is currently a high priority, however wholly unfunded and may not proceed.

Pentz Road Widening: This project includes the widening of Pentz Road between Pearson Road and Skway (4.0
miles) and the addition of a 12-feet wide center turn lane, increased shoulder widths, and a multi-use pathway. This project is currently a high priority, however mostly
unfunded and may not proceed.

Neal Road Widening: This project includes the widening
of Neal Road between Skyway and Town Limits at
Wayland Road (2.5 miles) and the addition of a 12-feet
wide center turn lane, increased shoulder widths, and a multi-use pathway. This project is currently a high priority, however wholly unfunded and may not proceed.

Town of Paradise
Recovery Projects,
Resiliency
Improvements
Early Warning System: This project includes the
installation of an audible communication tower at 21
locations throughout the Town of Paradise to increase
awareness of various hazards including information of
evacuation zones and warnings.

Category 4 Tree Removal: This project includes an
optional program for property owners to have dead or
dying trees burned by the Camp Fire removed at a
reduced cost. These trees are located on private property and are a threat.

Fuels Reduction Project: This project includes a multifaceted program to remove fire fuels from the public right of way in the Town of Paradise.

Defensible Space Code Enforcement: This project
includes proactive code enforcement and compliance
measures to reduce fuels located on private property in Paradise.

Ignition Resistant Home Hardening Program: This
project includes proactive retrofits on existing structures to improve structure resiliency in the event of a wildfire.

Paradise Town of
Paradise
2020-2024
Undergrounding of
Utilities
Electric Telecommunications: This project, initiated by PG&E in 2019 includes the conversion of all traditionally aerial electric facilities underground. Telecommunication facilities are also being included in joint trenching work with this project. The overall project will reduce community risk.

Paradise Utility
Companie
s
Ongoing
Source: Carollo Engineers 2022, Watkins-Bennett 2021, RWQCB 2019, City of Chico 2021g, BCAG 2022, and Town of Paradise 2021b 586
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 407

4.5.2 Cumulative Impact Analysis
The resource-specific cumulative impact analysis is provided in this section. These analyses consider those potential effects of the cumulative activities introduced in Table 4.5-1 combined with those of the Proposed Project discussed in Chapter 3.

4.5.2.1 Agriculture and Forestry Resources
The geographic study area for the cumulative impact analysis for agriculture and forestry resources is Butte County. The Proposed Project and cumulative projects listed in Table 4.5-1 are located within Butte County, which is located in the vast, productive floodplain of Sacramento River.

Cumulative impact thresholds for agriculture and forestry resources are the same as the impact thresholds presented in Section 3.2 Agriculture and Forestry Resources. Cumulative impacts are considered significant if they result in the following:
 Cumulative Impact AG-1: 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 non-agricultural use  Cumulative Impact AG-2: Conflict with existing zoning for agricultural use, or a Williamson Act contract
 Cumulative Impact AG-3: Conflict with existing zoning for, or cause rezoning of, forest land (as defined in PRC Section 12220(g)), timberland (as defined by PRC Section 4526), or timberland zoned Timberland Production (as defined by California Government Code Section 51104(g))  Cumulative Impact AG-4: Result in the loss of forest land or conversion of forest land to nonforest use  Cumulative Impact AG-5: Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to nonagricultural use or conversion of forest land to non-forest use
Past and existing cumulative urban development within Butte County has contributed to substantial loss of productive farmland to non-agricultural use in the county over time. The DOC monitors conversion of farmland through its FMMP. According to DOC’s Butte County 2004-2018 Land Use Summary table, approximately 4,844 acres of Prime Farmland within the county were converted to non-agricultural use or reclassified as another type of farmland during this period (DOC 2021c). In Butte County, from 2004 to 2018, Farmland of Statewide Importance increased by 74 acres and Unique Farmland decreased by 1,196 acres (DOC 2021c). Past and existing development within the county has resulted in a cumulatively significant impact on productive farmland, especially Prime Farmland, through conversion to urban and other uses.

As discussed in Section 3.2, the Proposed Project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural use, resulting in no impact.

Cumulative projects listed in Table 4.5-1 have the potential to result in the conversion of productive farmland to non-agricultural use, depending on their locations. Cumulative projects would be subject to the land use plans, policies, or regulations that would support necessary growth while minimizing conversion of productive agricultural land to non-agricultural use, where possible. Therefore, the 587
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 408
Proposed Project would not contribute to cumulative impacts on this criterion, and impacts would not be cumulatively considerable in combination with other cumulative projects.

The Proposed Project would not conflict with existing zoning for an agricultural use, or a Williamson Act contract, resulting in no impact. Cumulative projects listed in Table 4.5-1 could conflict with existing zoning for agricultural use or Williamson Act contract, depending on their locations. Cumulative projects would be subject to zoning regulations, land use plans, policies, or regulations, that would otherwise protect and prevent conflict with land zoned for agricultural use and Williamson Act contract parcels.

Therefore, the Proposed Project would not contribute to cumulative impacts on this criterion, and impacts would not be cumulatively considerable in combination with other cumulative projects.

The Proposed Project would not conflict with zoning for forest land, timberland, or timberland zoned Timberland Production, resulting in no impact. Additionally, the Proposed Project would not convert forestland to non-forest use, resulting in no impact. None of the cumulative projects listed in Table 4.5-1 under consideration are located within or adjacent to forest land or timberland. Further, the cumulative projects would be subject to compliance with zoning regulations, land use plans, policies, or regulations, that would otherwise protect forest and timber resources and prevent their conversion to non-forest use. Therefore, the Proposed Project would not contribute to cumulative impacts, and impacts would not be cumulatively considerable in combination with other cumulative projects.

As discussed under Impact AG-5 in Section 3.2, the Proposed Project would not involve changes in the existing environment that could result in conversion of farmland, to non-agricultural use or conversion of forest land to non-forest use, resulting in a less-than-significant impact. None of the cumulative projects under consideration are located within or adjacent to forest land or timberland. Cumulative projects listed in Table 4.5-1 have the potential to result in changes in the existing environment resulting in the conversion of farmland to non-agricultural use. However, cumulative projects, including the Proposed Project, would be subject to compliance with zoning regulations, land use plans, policies, or regulations, that would otherwise protect agricultural lands and prevent their conversion to non-agricultural use.

Therefore, the Proposed Project’s impacts from changes in the existing environment, in combination with other cumulative projects, would not be cumulatively considerable. Table 4.5-2 provides a summary of cumulative impacts on agriculture and forestry resources.

Table 4.5-2. Summary of Proposed Project Impact Contribution to Cumulative Agriculture and Forestry Resources Impacts
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact AG-1: 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 nonagricultural use

NI NCC N/A NCC
Cumulative Impact AG-2: Conflict with existing
zoning for agricultural use, or a Williamson Act
contract

NI NCC N/A NCC
588
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 409
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact AG-3: Conflict with existing
zoning for, or cause rezoning of, forest land (as
defined in PRC Section 12220(g)), timberland (as
defined by PRC Section 4526), or timberland
zoned Timberland Production (as defined by
California Government Code Section 51104(g))

NI NCC N/A NCC
Cumulative Impact AG-4: Result in the loss of
forest land or conversion of forest land to nonforest use

NI NCC N/A NCC
Cumulative Impact AG-5: Involve other changes
in the existing environment which, due to their
location or nature, could result in conversion of
Farmland to nonagricultural use or conversion of
forest land to non-forest use

LTS NCC N/A NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.2 Air Quality
The geographic study area for the cumulative impact analysis for air quality encompasses the entire Butte County. This is the area for which the BCAQMD has prepared plans for reducing specific types of air emissions and otherwise manages air quality to meet federal and state air quality standards. With regards to regional criteria air pollutants, no single project is sufficient in size, by itself, to result in nonattainment of ambient air quality standards. Instead, a project’s individual emissions contribute to cumulatively significant adverse air quality impacts.

Cumulative impact thresholds for air quality are the same as the thresholds presented in Section 3.3 Air Quality. Cumulative impacts are considered significant if they result in the following:
 Cumulative Impact AIR-1: Conflict with or obstruct implementation of an applicable air quality plan
 Cumulative Impact AIR-2: Result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is nonattainment under an applicable federal or state ambient air quality standard
 Cumulative Impact AIR-3: Expose sensitive receptors to substantial pollutant concentrations  Cumulative Impact AIR-4: Result in other emissions, such as those leading to odors, adversely affecting a substantial number of people
Conflict with Air Quality Plan
All construction jobs associated with cumulative projects would be temporary and would be expected to be filled by the current workforce within the County. Construction jobs associated with the Proposed Project will likely be filled by a mix of local and non-local workers; however, any temporary or permanent growth resulting from these positions would fall within the re-growth of the Town.

Construction of cumulative projects, including the Proposed Project, would not result in employment 589
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 410
growth within the County beyond growth projections presented in the 2018 Air Quality Attainment Plan and the Town of Paradise General Plan (Town of Paradise and Quad Consultants 2008).

As discussed under Impact AIR-1 in Section 3.3, the Proposed Project foster population growth in response to the 2018 Camp Fire recovery efforts. Cumulative projects, such as the City of Chico Nitrate Plan, Chico WPCP Upgrades, Paradise Irrigation District Project Water Intertie, Paradise Transit Center, and Town of Paradise Recovery Projects, could also foster population growth in the study area.

However, any population growth as a result of cumulative projects, including the Proposed Project, would be contained within the Town and the City, which are under the jurisdiction of the BCAQMD. As discussed in Section 3.3, the minimal increase in employment during operation and maintenance of the Proposed Project would be consistent with the growth projections in the 2018 Air Quality Attainment Plan. Other cumulative projects would likely result in a similar increase in employment during operation and maintenance, which would be consistent with the growth projections in the 2018 Air Quality Attainment Plan. Therefore, the Proposed Project would not contribute to cumulative impacts from criteria air pollutants, and in combination with the cumulative projects, would not be cumulatively considerable.

Criteria Air Pollutant Emissions
The Sacramento Valley Air Basin in Butte County is currently in nonattainment for O3; existing cumulative development has created a significant cumulative impact with regards to O3 emissions.

Potential growth and development within the cumulative study area could contribute to cumulative air quality impacts by contributing pollutants during construction and operation and maintenance within the cumulative study area.

Many of the cumulative projects include criteria pollutant emissions-generating activities during construction and operation and maintenance. Construction-related criteria air emissions would be generated from use of construction equipment, haul trucks, and construction labor commute vehicles.

Operational criteria air emissions would vary depending on the project but may include emissions from mobile, energy, area, water, and solid waste sources. Cumulative projects, such as the Paradise Irrigation District Project Water Intertie, Tuscan Ridge Project, Chico WPCP Upgrades, Paradise Transit Center, and Town of Paradise Recovery Projects, would generate criteria air pollutant emissions during construction and/or operations and maintenance. In general, these projects, combined with the Proposed Project, would affect air quality in the cumulative study area during construction and/or operation and maintenance.

In developing thresholds of significance for criteria air pollutants, BCAQMD considered the emissions levels for which a project’s individual emissions would be cumulatively considerable. Projects that do not exceed the BCAQMD’s significance thresholds may be assumed to not result in a cumulatively considerable net increase of any criteria pollutant for which the region is nonattainment (BCAQMD 2014).

As discussed under AIR-2 in Section 3.3, during construction, the Proposed Project would generate criteria air pollutant emissions that do not exceed BCAQMD thresholds. Criteria air pollutant emissions from operation and maintenance activities of the Proposed Project would be minimal and immeasurable due to the infrequency of these activities. Cumulative projects listed in Table 4.5-1 have the potential to 590
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 411
generate criteria air pollutant emissions during construction and/or operation and maintenance.

Cumulative projects, including the Proposed Project, would be subject to BCAQMD rules and regulations that would reduce criteria air pollutant emissions during construction and operation and maintenance. Therefore, the Proposed Project would not contribute to cumulative impacts from criteria air pollutants, and in combination with the cumulative projects, would not be cumulatively considerable.

Sensitive Receptors
The Proposed Project has the potential to generate TAC emissions from the use of diesel equipment during construction that could affect existing sensitive receptors. However, construction activities are temporary and short-term, and therefore, would not expose sensitive receptors to substantial pollutant concentrations. TAC emissions from operation and maintenance activities of the Proposed Project would be minimal and immeasurable due to the infrequency of these activities. Cumulative projects listed in Table 4.5-1 have the potential to generate TAC emissions during construction and/or operation and maintenance. Cumulative projects, including the Proposed Project, would be subject to BCAQMD rules and regulations that would reduce TAC emissions during construction and operation and maintenance. Based on these factors, the Proposed Project would not contribute to cumulative impacts on sensitive receptors, and in combination with the cumulative projects, would not be cumulatively considerable.

Odors
Construction of cumulative projects, including the Proposed Project, could result in emissions of odors in the form of diesel exhaust from construction equipment and vehicles. However, odors during construction would be short-term, limited in extent at any given time, and distributed throughout the area, and therefore, would not affect a substantial number of individuals. Odor emissions from operation and maintenance activities of the Proposed Project would be minimal and immeasurable due to the infrequency of these activities. The Proposed Project would include periodic inspection of odor control cannisters during routine operations and maintenance. Other cumulative projects would likely require similar odor control measures during operation and maintenance. Based on these factors, the Proposed Project would not contribute to cumulative impacts related to odors, and in combination with the cumulative projects, would not be cumulatively considerable. Table 4.5-3 provides a summary of cumulative impacts on air quality.

Table 4.5-3. Summary of Proposed Project Impact Contribution to Cumulative Air Quality Impacts Level of Incremental Applicable Incremental
Impact Cumulative Project Project Impact After
Significance Contribution Mitigations Mitigation
Cumulative Impact AIR-1: Conflict with or obstruct
implementation of an applicable air quality plan LTS NCC N/A NCC Cumulative Impact AIR-2: Result in a cumulatively
considerable net increase of any criteria pollutant
for which the project region is nonattainment
under an applicable federal or state ambient air
quality standard

LTS NCC N/A NCC
Cumulative Impact AIR-3: Expose sensitive
receptors to substantial pollutant concentrations LTS NCC N/A NCC Cumulative Impact AIR-4: Result in other LTS NCC N/A NCC 591
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 412
Level of Incremental Applicable Incremental
Impact Cumulative Project Project Impact After
Significance Contribution Mitigations Mitigation
emissions, such as those leading to odors,
adversely affecting a substantial number of
people

Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.3 Biological Resources
The geographic study area for the cumulative impact analysis for biological resources is defined by the Proposed Project’s construction limits and includes the sewer service areas in and between Paradise and Chico.

Cumulative impact thresholds for biological resources are the same as the thresholds presented in Section 3.4 Biological Resources. Cumulative impacts are considered significant if they result in the following:
 Cumulative Impact BIO-1: 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, regulations, or by the CDFW or USFWS  Cumulative Impact BIO-2: Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the CDFW or USFWS
 Cumulative Impact BIO-3: 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
 Cumulative Impact BIO-4: 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  Cumulative Impact BIO-5: Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance  Cumulative Impact BIO-6: Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan
In addition to the Proposed Project, the Paradise Irrigation District Project Water Intertie Tuscan Ridge Project, Paradise Transit Center, and Town of Paradise Recovery Projects could affect biological resources. Ground disturbance and vegetation clearing activities associated with each of the aforementioned projects, and the Proposed Project, would result in potentially significant cumulative impacts on biological resources, including special-status species, sensitive natural communities, and state or federally protected wetlands. However, implementing the mitigation measures listed below (and described in greater detail in Section 3.4) would reduce the Proposed Project’s potential contribution to cumulative impacts to a less than significant level by minimizing direct or indirect impacts on these resources, requiring monitoring during construction to clarify those avoidance elements, and installing a 592
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 413
restoration protocol to bring the project footprint back to pre-construction conditions following construction:
 MM-BIO-1: Minimize Disturbance Footprint
 MM-BIO-2: Special-status Plant Surveys
 MM-BIO-3: Special-status Plant Avoidance
 MM-BIO-4: Biological Monitoring and Worker Environmental Awareness Training  MM-BIO-5: Restoration of Temporarily Disturbed Areas
 MM-BIO-6: No Net Loss of Aquatic Resources
 MM-BIO-7: Sensitive Community Fencing
 MM-BIO-8: Dry Work Areas
 MM-BIO-9: Mapping of Elderberry Shrubs and Section 7 Consultation  MM-BIO-10: No Net Loss of Elderberry Shrubs
 MM-BIO-11: Elderberry Transplanting
 MM-BIO-12: Avoidance Area
 MM-BIO-13: Chemical Use
 MM-BIO-14: Mowing
 MM-BIO-15: Frac-Out Plan
 MM-BIO-16: Western Pond Turtle Visual Encounter Surveys  MM-BIO-17: Foothill Yellow-legged Frog Surveys
 MM-BIO-18: California Red-legged Frog Surveys
 MM-BIO-19: Conduct Construction Activities during the Active Period for Giant Garter Snakes  MM-BIO-20: Minimize Potential Effects on Giant Garter Snake Habitat  MM-BIO-21: MBTA and FGC-Protected Bird and Raptor Surveys  MM-BIO-22: Protocol Swainson’s Hawk Surveys
 MM-BIO-23: Nest Avoidance
 MM-BIO-24: Bat Surveys
 MM-BIO-25: American Badger Detection Surveys
 MM-BIO-26: State or Federally Protected Wetlands Mitigation Impacts from the cumulative projects considered would be similar. However, they would require similar environmental review to identify and mitigate for specific impacts. Therefore, the Proposed Project’s contribution to cumulative impacts on special-status species, sensitive natural communities, and state or federally protected wetlands would be less than significant with the implementation of aforementioned mitigation measures, and in combination with the cumulative projects would not be cumulatively considerable.

The Proposed Project would not interfere with movement of any fish or wildlife species, conflict with any local policies or ordinances protecting biological resources, or conflict with the provisions of an adopted habitat conservation plan. Impacts from the cumulative projects considered would be similar. However, they would require similar environmental review to identify and mitigate for specific impacts. Therefore, the Proposed Project would not contribute to cumulative impacts on these criteria, and impacts would 593
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 414
not be cumulatively considerable in combination with other cumulative projects. Table 4.5-4 provides a summary of cumulative impacts on biological resources.

Table 4.5-4. Summary of Proposed Project Impact Contribution to Cumulative Biological Resources Impacts
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact BIO-1: 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, regulations, or by
the CDFW or USFWS
SI CC
MM-BIO-1,
MM-BIO-2,
MM-BIO-3,
MM-BIO-4,
MM-BIO-5,
MM-BIO-6,
MM-BIO-7,
MM-BIO-8,
MM-BIO-9,
MM BIO-10,
MM-BIO-11,
MM BIO-12,
MM-BIO-13,
MM-BIO-14,
MM-BIO-15,
MM-BIO-16,
MM-BIO-17,
MM-BIO-18,
MM-BIO-19,
MM-BIO-20,
MM-BIO-21,
MM-BIO-22,
MM-BIO-23,
MM-BIO-24,
MM-BIO-25
NCC
Cumulative Impact BIO-2: Have a substantial
adverse effect on any riparian habitat or other
sensitive natural community identified in local or
regional plans, policies, or regulations, or by the
CDFW or USFWS
SI CC
MM-BIO-1,
MM-BIO-5,
MM-BIO-6,
MM-BIO-7,
MM-BIO-8
NCC
Cumulative Impact BIO-3: 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
SI CC
MM-BIO-1,
MM-BIO-5,
MM-BIO-6,
MM-BIO-7,
MM-BIO-8,
MM-BIO-26
NCC
Cumulative Impact BIO-4: Interfere substantially
with the movement of any native resident or
migratory fish or wildlife species or with
established native resident or migratory wildlife

NI NCC N/A NCC
594
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 415
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
corridors, or impede the use of native wildlife
nursery sites

Cumulative Impact BIO-5: Conflict with any local
policies or ordinances protecting biological
resources, such as a tree preservation policy or
ordinance

NI NCC N/A NCC
Cumulative Impact BIO-6: Conflict with the
provisions of an adopted Habitat Conservation
Plan, Natural Community Conservation Plan, or
other approved local, regional, or state habitat
conservation plan

NI NCC N/A NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.4 Cultural Resources
The geographic study area for the cumulative impact analysis for cultural resources includes central and northern Butte County and was selected because these areas include the relatively undeveloped portions of the ancestral Mechoopda and Konkow territory, and those rural areas outside of the historically developed urban population center in Chico.

According to CEQA, the importance of cultural resources comes from the research value and the information that they contain. Therefore, the issue that must be explored in a cumulative analysis is the cumulative loss of that information. For sites considered less than significant, the information is preserved through recordation and test excavations, if necessary. Significant sites that are placed in open space easements avoid impacts on cultural resources and also preserve the data. Significant sites that are not placed within open space easements preserve the information through recordation, test excavations and data recovery programs that would be presented in reports and filed with the county and the California Historical Resources Information System.

Cumulative impact thresholds for cultural resources are the same as the thresholds presented in Section 3.5 Cultural Resources. Cumulative impacts are considered significant if they result in the following:
 Cumulative Impact CUL-1: Cause a substantial adverse change in the significance of a historical resource pursuant to section 15064.5.
 Cumulative Impact CUL-2: Cause a substantial adverse change in the significance of an archaeological resource pursuant to section 15064.5.
 Cumulative Impact CUL-3: Disturb any human remains, including those interred outside of formal cemeteries.

The Paradise Irrigation District Project Water Intertie, Tuscan Ridge Project, Paradise Transit Center, and Town of Paradise Recovery Projects have the potential to impact cultural resources. Ground disturbance associated with each of the aforementioned projects, and the Proposed Project, could result in potentially significant cumulative impacts on previously recorded and/or newly discovered 595
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 416
cultural resources if identified within the footprint of each project. However, implementing MM-CUL1:

Targeted Archaeological Monitoring and MM-CUL-2: Follow Inadvertent Discovery Procedures would reduce the Proposed Project’s contribution to cumulative impacts to a less than significant level because appropriate procedures would be followed to ensure that any unanticipated cultural resources discovered during Project-related ground-disturbing activities are appropriately handled and documented and that all appropriate parties are contacted and coordinated with in a timely manner, in order to either avoid or minimize impacts on the cultural resources. Implementing these mitigation measures would provide assurances that the Proposed Project would not have a significant contribution to impacts on cultural resources meeting one of the significance criteria of the CRHR. With similar considerations and mitigation on other cumulative projects, impacts on cultural resources from Proposed Project, in combination with other cumulative projects, would not be cumulatively considerable. Table 4.5-5 provides a summary of cumulative impacts on cultural resources.

Table 4.5-5. Summary of Proposed Project Impact Contribution to Cumulative Cultural Resources Impacts
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact CUL-1: Cause a substantial
adverse change in the significance of a historical
resource pursuant to section 15064.5.

LTS NCC N/A NCC
Cumulative Impact CUL-2: Cause a substantial
adverse change in the significance of an
archaeological resource pursuant to section
15064.5.

SI CC MM CUL-1
MM CUL-2 NCC
Cumulative Impact CUL-3: Disturb any human
remains, including those interred outside of formal
cemeteries.

LTS NCC N/A NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.5 Energy
The geographic study area for the cumulative impact analysis for energy resources is Butte County.

The Proposed Project and cumulative projects listed in Table 4.5-1 are located within Butte County.

Cumulative impact thresholds for energy are to the same as the thresholds presented in Section 3.6 Energy. Cumulative impacts are considered significant if they result in the following:
 Cumulative Impact ENG-1: Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation and maintenance
 Cumulative Impact ENG-2: Conflict with or obstruct a state or local plan for renewable energy or energy efficiency
Potential growth and development within the cumulative study area could contribute to energy impacts by increasing energy demand during construction and operation and maintenance within the cumulative study area.
596
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 417
Cumulative projects, such as the Paradise Irrigation District Project Water Intertie, Chico WPCP Upgrades, Tuscan Ridge Project, Paradise Transit Center, and Town of Paradise Recovery Projects, would increase energy demand during construction and/or operational activities. Primary sources of energy use would be electricity, natural gas, and/or transportation fuel. In general, these projects, combined with the Proposed Project, would affect energy demand in the cumulative study area during construction and/or operation and maintenance. As presented in Section 3.6, the Proposed Project would result in a less than significant impact related to the wasteful, inefficient, or unnecessary consumption of energy during construction, operation, and maintenance. Cumulative projects, including the Proposed Project, would be subject to the plans, policies, or regulations that are aimed at improving vehicle fuel efficiency, improving energy efficiency, and enhancing energy conservation. Therefore, the Proposed Project’s contribution would be less than significant, and in combination with the cumulative projects would not be cumulatively considerable.

The Proposed Project would not conflict with a state or local plan for renewable energy or energy efficiency, resulting in no impact. Construction of the Proposed Project in combination with other cumulative projects identified in Table 4.5-1 has the potential to result in cumulative energy impacts. A multitude of state regulations and legislative acts are aimed at improving vehicle fuel efficiency, improving energy efficiency, and enhancing energy conservation. These include, but are not limited to, AB 1493, Advanced Clean Cars Program, In-Use Off-Road Diesel-Fueled Fleets Regulation, SB 100, and 2017 Scoping Plan. The Proposed Project and other cumulative projects are required to comply with these adopted plans and regulations. Therefore, the Proposed Project would not contribute to cumulative impacts on this criterion, and impacts would not be cumulatively considerable in combination with other cumulative projects. Table 4.5-6 provides a summary of cumulative impacts on energy resources.

Table 4.5-6. Summary of Proposed Project Impact Contribution to Cumulative Energy Impacts Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact ENG-1: Result in potentially
significant environmental impact due to wasteful,
inefficient, or unnecessary consumption of energy
resources, during project construction or
operation and maintenance

LTS NCC N/A NCC
Cumulative Impact ENG-2: Conflict with or
obstruct a state or local plan for renewable energy
or energy efficiency

NI NCC N/A NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.6 Geology, Soils, and Paleontological Resources
The geographic study area for the cumulative impact analysis for geology, soils, and paleontological resources is defined as the areas within and directly adjacent to the Town of Paradise and areas of unincorporated Butte County and Chico where the proposed pipeline alignment runs. The cumulative study area for geology, soils, and paleontological resources is not cumulatively additive across projects because each project site has a different set of geological formations and considerations. 597
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 418
Cumulative impact thresholds for geology, soils, and paleontological resources are the same as the thresholds presented in Section 3.7 Geology, Soils, and Paleontological Resources. Cumulative impacts are considered significant if the result in the following:
 Cumulative Impact GEO-1: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
o 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
o Strong seismic ground shaking
o Seismic-related ground failure, including liquefaction o Landslides
 Cumulative Impact GEO-2: Result in substantial soil erosion or the loss of topsoil  Cumulative Impact GEO-3: 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  Cumulative Impact GEO-4: Be located on expansive soil, as defined in Table 18-1B of the Uniform Building Code (1994), creating substantial direct or indirect risk to life or property  Cumulative Impact GEO-5: 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 wastewater
 Cumulative Impact GEO-6: Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature
Geology and Soils
As discussed in Section 3.7, the Proposed Project is not located within an Alquist-Priolo Earthquake Fault Zone. As discussed in Section 3.7, use of vibration-generating equipment during construction of the Proposed Project may exacerbate ground shaking, liquefaction, landslides. Additionally, use of vibration-generating equipment during construction of the Proposed Project may exacerbate risks associated with unstable soils and expansive soils. With the implementation of MM-GEO-1: Geologic Hazards impacts related to ground shaking, liquefaction, landslides, unstable soils, and expansive soils would be reduced to less than significant. The Proposed Project would expose and disturb soils during construction, making them vulnerable to erosion. The Proposed Project would be subject to the SWRCB’s CGP requirements and applicable grading permit requirements, which would ensure impacts related to soil erosion are less than significant. Additionally, the Proposed Project would not locate septic tanks or alternative wastewater disposal systems on soils incapable of adequate support.

Cumulative projects identified in Table 4.5-1 could result in damage to life and property from geologic and soils-related hazards during construction activities such as grading, excavations, or other ground disturbing activities. While these would be project-specific geologic- and soils-related risks during 598
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 419
construction, it is not anticipated that these impacts would combine across projects to create additional public risk. The magnitude of geologic- and soils-related hazards for individual cumulative projects would depend upon the location, type, and size of development and the specific hazards associated with individual sites. Cumulative projects would require individual environmental review with projectspecific analysis to evaluate the geologic- and soils-related hazard risks. Specific geologic- and soilsrelated hazards associated with individual project sites would be limited to those sites without affecting other areas. Cumulative projects would be subject to the SWRCB’s CGP requirements and applicable grading permit requirements, which would minimize soil erosion. Furthermore, cumulative projects would be subject to applicable regulations, building codes, and construction standards that are designed to reduce geology and soils-related hazards. Additionally, none of the cumulative projects include septic tanks or alternative wastewater disposal systems. Based on these factors, the Proposed Project’s contribution to cumulative impacts on geology and soils would be less than significant with the implementation of mitigation measure MM-GEO-1, and in combination with the cumulative projects would not be cumulatively considerable.

Paleontological Resources
Potential growth and development within the cumulative study area could contribute to cumulative impacts on paleontological resources by disturbing, damaging, or destroying paleontological resources during construction and operation and maintenance within the cumulative study area. Once lost, such resources cannot be recovered.

Ground disturbance during construction of the Proposed Project could disturb unknown paleontological resources within the Modesto Formation. With the implementation of mitigation measure MM-GEO-2:

Inadvertent Discovery Protocol, impacts on unknown paleontological resources would be less than significant. Future cumulative projects identified in Table 4.5-1 include ground-disturbing activities that could disturb, damage, or destroy paleontological resources. Cumulative projects would require individual environmental review with project-specific analysis to evaluate their impacts on unknown paleontological resources. Furthermore, cumulative projects would be subject to applicable regulations and construction standards that are designed to reduce potential impacts on paleontological resources from ground-disturbing activities. Therefore, the Proposed Project’s contribution to cumulative impacts on paleontological resources would be less than significant with the implementation of mitigation measure MM-GEO-2, and in combination with the cumulative projects would not be cumulatively considerable. Table 4.5-7 provides a summary of cumulative impacts on geology, soils, and paleontological resources.

Table 4.5-7. Summary of Proposed Project Impact Contribution to Cumulative Geology, Soils, and Paleontological Resources Impacts
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact GEO-1: Directly or indirectly
cause potential substantial adverse effects,
including the risk of loss, injury, or death involving:
a. Rupture of a known earthquake fault, as
delineated on the most recent AlquistPriolo Earthquake Fault Zoning Map SI CC MM-GEO-1 NCC
599
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 420
Level of Incremental Applicable Incremental
Impact Cumulative Project Project Impact After
Significance Contribution Mitigations Mitigation
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
b. Strong seismic ground shaking
c. Seismic-related ground failure, including
liquefaction
d. Landslides
Cumulative Impact GEO-2: Result in substantial
soil erosion or the loss of topsoil LTS NCC N/A NCC
Cumulative Impact GEO-3: 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
SI CC MM-GEO-1 NCC
Cumulative Impact GEO-4: Be located on
expansive soil, as defined in Table 18-1B of the
Uniform Building Code (1994), creating
substantial direct or indirect risk to life or property SI CC MM-GEO-1 NCC
Cumulative Impact GEO-5: 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
wastewater

NI NCC N/A NCC
Cumulative Impact GEO-6: Directly or indirectly
destroy a unique paleontological resource or site
or unique geologic feature
SI CC MM-GEO-2 NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.7 Greenhouse Gas Emissions
The geographic study area for the cumulative impact analysis for GHG encompasses the state of California. Climate change is a global phenomenon resulting from the combined effects of GHG emissions produced worldwide. While the true study area affected by GHG emissions is global, for purposes of this EIR, the study area is considered to be the state of California. This study area is selected because GHG emissions generated by individual projects must comply with statewide GHG emissions reduction goals. The analysis is conducted within the framework of California’s legislative and regulatory climate change framework, which is designed to reduce GHG emissions in the state over time to levels that substantially reduce California’s contribution to global climate change.

Cumulative impact thresholds for GHG emissions are the same as the thresholds presented in Section 3.8 Greenhouse Gas Emissions. Cumulative impacts are considered significant if they result in the following:
600
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 421
 Cumulative Impact GHG-1: Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment
 Cumulative Impact GHG-2: Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions
GHGs are global pollutants, unlike criteria air pollutants (such as O3 precursors), which are primarily pollutants of regional and local concern. Given their long atmospheric lifetimes, GHGs emitted by countless sources worldwide accumulate in the atmosphere. No single emitter of GHGs is large enough to trigger global climate change on its own. Rather, climate change is the result of the individual contributions of countless past, present, and future sources. Therefore, GHG impacts are inherently cumulative. Consequently, the analysis of climate change impacts from production of GHGs as included in Section 3.8 is inherently cumulative in nature.

Potential growth and development within the cumulative study area could contribute to climate change impacts by contributing GHG emissions during construction and operation and maintenance within the cumulative study area.

A number of planned cumulative projects include GHG emissions-generating activities during construction and operation and maintenance. Construction-related GHG emissions would be generated by operation of construction equipment, fueling activities, materials hauling, and daily trips by construction workers. Operational GHG emissions would vary depending on the project but may include emissions from mobile, energy, area, water, and solid waste sources. Cumulative projects, such as the Paradise Irrigation District Project Water Intertie, Chico WPCP Upgrades, Tuscan Ridge Project, Paradise Transit Center, and Town of Paradise Recovery Projects, would generate GHG emissions during construction and/or operation and maintenance activities. In general, these projects, combined with the Proposed Project, would affect GHGs in the cumulative study area during construction and/or operation and maintenance. As presented in Section 3.8, the Project’s construction GHG emissions would be below SMAQMD’s threshold of significance for construction emissions. GHG emissions from operation and maintenance activities of the Proposed Project would be minimal and immeasurable due to the infrequency of these activities. Impacts from other cumulative projects would likely be similar.

Therefore, the Proposed Project’s contribution would be less than significant, and in combination with the cumulative projects would not be cumulatively considerable.

The Proposed Project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions, resulting in no impact. The Proposed Project, in combination with other cumulative projects identified in Table 4.5-1, has the potential to result in GHG impacts, which are inherently cumulative. Statewide efforts are underway to reduce GHG emissions, and the Proposed Project and other cumulative projects are required to comply with these adopted plans and goals.

Therefore, the Proposed Project would not contribute to cumulative impacts on this criterion, and impacts would not be cumulatively considerable in combination with other cumulative projects. Table

4.5-8 provides a summary of cumulative impacts on GHG emissions. 601
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 422
Table 4.5-8. Summary of Proposed Project Impact Contribution to Cumulative Greenhouse Gas Emissions Impacts
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact GHG-1: Generate GHG
emissions, either directly or indirectly, that may
have a significant impact on the environment

LTS NCC N/A NCC
Cumulative Impact GHG-2: Conflict with an
applicable plan, policy, or regulation adopted for
the purpose of reduction the emissions of GHG
emissions

NI NCC N/A NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.8 Hazards and Hazardous Materials
The geographic study area for the cumulative impact analysis for hazards and hazardous materials is defined by the Proposed Project’s construction limits. The cumulative study area for hazards and hazardous materials is not cumulatively additive across projects because each project site has a different set of hazardous materials and considerations.

Cumulative impact thresholds for hazards and hazardous material are the same as the thresholds presented in Section 3.9 Hazards and Hazardous Materials. Cumulative impacts are considered significant if they result in the following:
 Cumulative Impact HAZ-1: Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials  Cumulative Impact HAZ-2: 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
 Cumulative Impact HAZ-3: Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school
 Cumulative Impact HAZ-4: 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  Cumulative Impact HAZ-5: 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
 Cumulative Impact HAZ-6: Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan
 Cumulative Impact HAZ-7: Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires 602
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 423
Transport, Use, or Disposal
Cumulative projects listed in Table 4.5-1 would involve the transport, use, and disposal of hazardous materials during construction and/or operation and maintenance. As discussed in Section 3.9, during construction, the Proposed Project would involve the transport and use of common construction materials such as fuel and grease, which could pose a threat as hazardous materials. Cumulative projects, including the Proposed Project, would be subject to the requirements of the SWRCB’s CGP and the NPDES permit for discharges of storm water associated with construction and land disturbance activities. The CGP requires preparation and implementation of a SWPPP, which would include measures to safely use and store hazardous materials. Cumulative projects, including the Proposed Project, would be subject to federal, state, and regional requirements for the transport, use, and disposal of hazardous materials, which would reduce impacts. The Proposed Project has the potential to result in fuel and grease spills associated with the use of trucks and equipment during operation and maintenance activities. With the implementation of mitigation measure MM-HAZ-1: Vehicle Equipment Access and Fueling, impacts related to routine transport, use, or disposal of hazardous materials would be less than significant. It is possible that other cumulative projects could increase fuel and grease drips over existing levels during operation and maintenance. Other cumulative projects may also implement similar mitigation measure to reduce impacts related to hazardous materials. Therefore, the Proposed Project’s contribution to cumulative hazardous materials impacts would be less than significant with the implementation of mitigation measure MM-HAZ-1. When combined with other cumulative projects, these impacts would not be cumulatively considerable.

Accidental Release
Cumulative projects, including the Proposed Project, would be required to implement a SWPPP with best management practices to reduce the likelihood and severity of the release of construction-related pollutants like fuel and grease to a less-than-significant level. Any contaminated soils encountered by the project would be managed, stored, and disposed of in accordance with requirements of the SWPPP and NPDES permit, which would minimize impacts related to the accidental release of hazardous materials. During operation and maintenance, the Proposed Project would involve the use of trucks and equipment that would use fuel and grease, which are considered hazardous materials. However, these vehicles would be operated in areas that already experiences vehicle traffic and maintenance activities would be very infrequent therefore not increasing the potential for fuel and grease drips significantly over existing levels. Impacts from other cumulative projects during operation and maintenance would likely be similar. Therefore, the Proposed Project’s contribution would be less than significant, and in combination with other cumulative projects would not be cumulatively considerable.

Hazardous Emissions near Schools
The Proposed Project has the potential to emit hazardous materials or substances near schools during construction. It is possible that some cumulative projects could emit hazardous materials or substances near schools during construction, depending on the project location. Cumulative projects, including the Proposed Project, would require implementation of a project SWPPP, consistency with hazardous materials handling, and consistency with BCAQMD requirements regarding diesel particulate matter.

During operation and maintenance, the Proposed Project would not increase the potential for hazardous emissions near schools significantly over existing levels. Impacts from other cumulative projects during operation and maintenance would likely be similar. Therefore, the Proposed Project’s 603
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 424
contribution would be less than significant, and in combination with other cumulative projects would not be cumulatively considerable.

List of Hazardous Materials Sites
As discussed in Section 3.9, construction of the Proposed Project has the potential to encounter contaminated soils associated with an underground kerosine storage tank site on the Envirostor database. With the implementation of mitigation measure MM-HAZ-2: Cypress Lane Site Specific Contaminated Soil Management Plan, impacts from being located on a hazardous materials site during construction would be reduced to less than significant. It is possible that some cumulative projects could encounter contaminated soils during construction, depending on the project location. Any contaminated soils encountered by cumulative projects, including the Proposed Project, would be managed, stored, and disposed of in accordance with requirements of the SWPPP and NPDES permit.

Additionally, any hazardous materials encountered, including contaminated soils, would be managed and disposed of in accordance with California Department of Toxic Substances Control regulations.

Therefore, cumulative impacts on this criterion would be less than significant with the implementation of mitigation measure MM-HAZ-2, and in combination with the cumulative projects, would not be cumulatively considerable.

Airport Hazards
As discussed in Section 3.9, the Proposed Project would result in a safety hazard or excessive noise for people residing or working in the project area due to nearby public airports, resulting in no impact.

None of the cumulative projects, including the Proposed Project, are located within two miles of a public airport. Therefore, the Proposed Project would not contribute to cumulative impacts on this criterion, and impacts would not be cumulatively considerable in combination with other cumulative projects.

Emergency Response Plan or Emergency Evacuation Plan
The Proposed Project has the potential to result in interruptions to emergency response or evacuation routes due to temporary road/lane closures during construction. Construction of the Proposed Project would occur along Skyway, which is an evacuation route in Paradise. With the implementation of mitigation measures MM-HAZ-3: Road Closure Restrictions, MM-HAZ-4: Rapid Demobilization Plan, MM-HAZ-5: Evacuation Warning Procedures, and MM-HAZ-6: Traffic Management Plan, impacts on emergency response plan or emergency evacuation plan during construction would be reduced to less than significant. There would be no interruptions to emergency response or evacuation routes during operation and maintenance activities. Impacts from other cumulative projects would likely be similar and would likely require similar mitigation measures. Therefore, the Proposed Project’s contribution to cumulative impacts on this criterion would be less than significant with the implementation of aforementioned mitigation measures, and in combination with the cumulative projects, would not be cumulatively considerable.

Wildland Fire Hazards
The Proposed Project has the potential to expose workers to wildland fires during construction, operation, and maintenance. With the implementation of mitigation measures MM-HAZ-1: Vehicle Equipment Access and Fueling, MM-HAZ-7: Incorporate Fire Prevention Measures, MM-HAZ-8:

Incorporate Public Safety Measures, and MM-HAZ-9: Wildland Fire Area, impacts from wildland fire exposure would be reduced to less than significant. It is possible that some cumulative projects could expose workers to wildland fires during construction and/or operation and maintenance, depending on project location. These cumulative projects would likely require similar mitigation measures to reduce 604
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 425
impacts related to wildland fires. Therefore, the Proposed Project's contribution to cumulative impacts on this criterion would be less than significant with the implementation of aforementioned mitigation measures, and in combination with the cumulative projects, would not be cumulatively considerable. Table 4.5-9 provides a summary of cumulative impacts on hazardous materials.

Table 4.5-9. Summary of Proposed Project Impact Contribution to Cumulative Hazards and Hazardous Materials Impacts
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact HAZ-1: Create a significant
hazard to the public or the environment through
the routine transport, use, or disposal of
hazardous materials
SI CC MM-HAZ-1 NCC
Cumulative Impact HAZ-2: 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

LTS NCC N/A NCC
Cumulative Impact HAZ-3: Emit hazardous
emissions or handle hazardous or acutely
hazardous materials, substances, or waste within
one-quarter mile of an existing or proposed school

LTS NCC N/A NCC
Cumulative Impact HAZ-4: 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
SI CC MM-HAZ-2 NCC
Cumulative Impact HAZ-5: 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

NI NCC N/A NCC
Cumulative Impact HAZ-6: Impair implementation
of or physically interfere with an adopted
emergency response plan or emergency
evacuation plan
SI CC
MM-HAZ-3,
MM-HAZ-4,
MM-HAZ-5
NCC
Cumulative Impact HAZ-7: Expose people or
structures, either directly or indirectly, to a
significant risk of loss, injury or death involving
wildland fires
SI CC
MM-HAZ-1,
MM-HAZ-7,
MM-HAZ-8,
MM-HAZ-9
NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.9 Hydrology and Water Quality
The cumulative projects are located throughout Butte County, primarily within Paradise and Chico.

Therefore, the geographic study area for the cumulative impact analysis for hydrology and water quality includes waterbodies within and the groundwater basin underlying Paradise and Chico. The cumulative projects and the Proposed Project are all located within the Sacramento Valley groundwater basin. 605
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 426
Therefore, the Sacramento Valley groundwater basin is considered in the cumulative study area for hydrology and water quality.

Cumulative impact thresholds for hydrology and water quality are the same as the thresholds presented in Section 3.10 Hydrology and Water Quality. Cumulative impacts are considered significant if they result in the following:
 Cumulative Impact HYD-1: Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality  Cumulative Impact HYD-2: Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin
 Cumulative Impact HYD-3: 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:
o Result in substantial erosion or siltation on or off-site o Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site
o Create or contribute runoff water that would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff
o Impede or redirect flood flows
 Cumulative Impact HYD-4: In flood hazard zones, risk release of pollutants due to project inundation
 Cumulative Impact HYD-5: Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan
Under the cumulative condition, the population of Paradise is expected to increase as the Town focuses on recovery efforts from the 2018 Camp Fire. Population increases could result in additional commercial, recreational, industrial, and residential developments in Paradise.

Surface Water Quality
Potential growth and development within the cumulative study area could contribute to cumulative surface water quality degradation, and the collective effect of development could degrade stormwater quality by contributing pollutants during construction and operation and maintenance within the cumulative study area.

A number of cumulative projects in the cumulative study area, described below, involve improvements or changes in the current water and sewer systems in the Town. Legislation has also been introduced to streamline the process for developing certain water projects. For example, AB 32 would allow the use of the design-build procurement method for projects, which would help to fast-track projects like the Paradise Irrigation District Project Water Intertie. The Proposed Project would allow the sale of unused surface water in PID reservoirs to help make up for losing most of its customers after the Camp Fire and would involve transporting water to Chico. The Tuscan Ridge Project would build an on-site 606
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 427
sewage wastewater treatment and disposal facility to serve as a temporary workers’ camp for those who are involved in the Camp Fire recovery and rebuilding efforts. Other projects such as the Tuscan Ridge Project, City of Chico Nitrate Plan, Chico WPCP Upgrades would also factor into changes in water quality and supply in the cumulative study area. In general, these projects, coupled with the Proposed Project, were intended to improve water quality in the cumulative study area during operation and maintenance. As discussed in Section 3.10, studies have shown evidence of high levels of fecal coliform and septic system effluent in water supply resulting in the degradation of water quality in the cumulative study area as a result of historical individually managed septic systems. As a result, in 1992 the Town of Paradise created the Town of Paradise Onsite Wastewater Management Zone in order to centralize the management of wastewater and improve public health. The Proposed Project would further improve public health and water quality in the cumulative study area by removing septic tanks and implementing an improved sewer system.

The additional amount of treated discharge entering into the Sacramento River as a result of Proposed Project operation and maintenance would also not impact water quality in the cumulative study area.

The Chico WPCP is licensed to treat 12 mgd of wastewater and is operating at 6.3 mgd. The Proposed Project would add an additional 0.5 mgd of wastewater to the system during operation and maintenance, which would then be discharged into the Sacramento River. Consistent with existing conditions, the treated wastewater from the Chico WPCP would continue to be discharged to the Sacramento River through a submerged outfall diffuser and is regulated in accordance with NPDES Permit No. CA0079081 (Order No. R5-2016-0023). This incremental increase in discharge as a result of the Proposed Project is within the permitted allowance and would not violate water quality standards or waste discharge requirements.

The Proposed Project will be subject to applicable permitting requirements (Section 404, Section 401, the Streambed Alteration Agreement, CGP, Small MS4 permit, and other standard water treatment BMPs), which would minimize water quality impacts during construction. To minimize significant water quality impacts during construction to a less than significant level, the Proposed Project will implement mitigation measures MM-HAZ-1: Vehicle and Equipment Access and Fueling, MM-HYD-1:

Stormwater Management and Treatment Plan, MM-HYD-2: Construction Best Management Practices, and MM-BIO-15: Frac-Out Plan. Impacts from other cumulative projects would likely be similar and would likely require similar mitigation measures. Therefore, the Proposed Project’s contribution to cumulative water quality impacts would be less than significant with the implementation of aforementioned mitigation measures, and in combination with the cumulative projects would not be cumulatively considerable.

Groundwater
The projects considered in this cumulative analysis may require dewatering and the use of groundwater during construction. Impacts on groundwater from the cumulative projects would largely be temporary and localized during construction and likely not cause a net deficit in aquifer volume or lower the groundwater table. The cumulative projects could also involve the addition of new impervious surfaces that would reduce groundwater recharge. However, given the developed nature of the study area, the cumulative impact of the cumulative projects on groundwater recharge would not be significant. During construction and operation and maintenance, any cumulative projects would be required to conform to groundwater management plans and state, local, and regional policies regarding groundwater supplies, 607
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 428
such as the Butte County Groundwater Conservation Ordinance. Once constructed, the Proposed Project would not impact groundwater. Therefore, cumulative impacts on this criterion would be less than significant and the Proposed Project’s contribution would not be cumulatively considerable.

Erosion
The Proposed Project has the potential to result in sediment transport from construction work near waterbodies. It is possible that some cumulative projects could increase sediment discharge into waterbodies, depending on the project location. Cumulative projects, including the Proposed Project, would be subject to the requirements of the SWRCB’s CGP, which requires preparation and implementation of a SWPPP. The construction SWPPP would propose BMPs to minimize potential short-term increases in sediment transport caused by construction, including erosion control requirements and stormwater management. To minimize significant impacts associated with erosion or siltation during construction to a less than significant level, the Proposed Project will implement mitigation measure MM-HYD-1: Stormwater Management and Treatment Plan. Once constructed, the Proposed Project would not result in erosion or siltation. Impacts from other cumulative projects would likely be similar and would likely require similar mitigation measures. Therefore, cumulative impacts on this criterion would be less than significant with the implementation of MM-HYD-1 and the Proposed Project’s contribution would not be cumulatively considerable.

Surface Water Hydrology
Cumulative projects, such as the City of Chico Nitrate Action Plan, Chico WPCP Upgrades, Tuscan Ridge Project, Paradise Transit Center, and Town of Paradise Recovery Projects, have the potential to change the surface water hydrology in the study area on a temporary basis during construction or permanently by potentially impacting or relocating stormwater infrastructure. However, adhering to existing laws and permit processes that control streambed alteration and limit changes to drainages, such as the federal Clean Water Act and the SWRCB’s CGP, would avoid cumulative impacts from these cumulative projects. Once constructed, stormwater facilities built as a part of these projects would capture and slow releases to waterways, thereby avoiding cumulative impacts. Construction of cumulative projects, including the Proposed Project, would result in construction flows to existing drainage systems as well as polluted runoff. Laws and permitting processes, including local stormwater permits, generally require new development projects to incorporate stormwater capture and infiltration features during construction. such that runoff volumes would not exceed the capacity of existing and planned stormwater facilities to accommodate the runoff. To minimize significant impacts associated with polluted runoff during construction to a less than significant level, the Proposed Project will implement mitigation measures MM-HYD-1: Stormwater Management and Treatment Plan and MMHYD-3: Flood Protection Plan. Once constructed, the Proposed Project would not result in polluted runoff. Impacts from other cumulative projects would likely be similar and would likely require similar mitigation measures. Therefore, cumulative impacts on this criterion would be less than significant with the implementation of aforementioned mitigation measures and the Proposed Project’s contribution would not be cumulatively considerable.

Floodplains
Future cumulative projects require work within a floodway or floodplain. All ongoing and planned cumulative projects, including the Proposed Project, are subject to and must comply with applicable 608
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 429
federal, state, and local policies, programs, and ordinances, which would reduce the impact on floodplains and flood risks during construction and operation and maintenance. The local flood control agencies and applicable flood control design criteria require projects in areas within the designated 100-year flood zones to design project-specific drainage systems in accordance with findings of sitespecific studies. As discussed in Section 3.10, with the implementation of mitigation measure MMHYD-3: Flood Protection Plan, the Proposed Project would have a less than significant impact from being located within a flood hazard zone. Construction associated with cumulative projects in such areas would be designed to comply with regulatory agency requirements as well and impacts on floodplains would require similar mitigation measures. Therefore, cumulative impacts on this criterion would be less than significant with the implementation of mitigation measure MM-HYD-3 and the Proposed Project’s contribution would not be cumulatively considerable.

Water Quality Control Plan or Sustainable Groundwater Management Plan The Proposed Project will require regulatory permits from USACE (Section 404), the Regional Board (Section 401), CDFW (Streambed Alteration Agreement), SWRCB (CGP), and Small MS4 Permit. The Proposed Project will comply with NPDES permitting. As discussed in Section 3.10, with the implementation of mitigation measure MM-HYD-1: Stormwater Management and Treatment Plan, impacts on a water quality control plan or sustainable groundwater management plan would be reduced to a less than significant level. Cumulative projects listed in Table 4.5-1 would be subject to similar permitting requirements and would require similar mitigation measures. Therefore, cumulative impacts on this criterion would be less than significant with the implementation of mitigation measure MM-HYD-1 and the Proposed Project’s contribution would not be cumulatively considerable. Table 4.5-10 provides a summary of cumulative impacts on hydrology and water quality.

Table 4.5-10. Summary of Proposed Project Impact Contribution to Cumulative Hydrology and Water Quality Impacts
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact HYD-1: Violate any water quality
standards or waste discharge requirements or
otherwise substantially degrade surface or ground
water quality
SI CC
MM-HAZ-1,
MM-HYD-1,
MM-HYD-2,
and MM-BIO15
NCC
Cumulative Impact HYD-2: Substantially decrease
groundwater supplies or interfere substantially with
groundwater recharge such that the project may
impede sustainable groundwater management of the
basin

LTS NCC NA NCC
Cumulative Impact HYD-3: 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:
a. Result in substantial erosion or siltation on or
off-site
SI CC MM-HYD-1,
MM-HYD-3 NCC
609
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 430
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
b. Substantially increase the rate or amount of
surface runoff in a manner which would
result in flooding on- or off-site
c. Create or contribute runoff water that would
exceed the capacity of existing or planned
storm water drainage systems or provide
substantial additional sources of polluted
runoff
Impede or redirect flood flows
Cumulative Impact HYD-4: In flood hazard zones, risk
release of pollutants due to project inundation SI CC MM-HYD-3 NCC HYD-5: Conflict with or obstruct implementation of a
water quality control plan or sustainable groundwater
management plan
SI CC MM-HYD-1 NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.10 Land Use and Planning
The geographic study area for the cumulative impact analysis for land use and planning is defined by the Proposed Project’s construction limits and includes all areas in and between Paradise and Chico, including unserved areas. This cumulative study area would capture impacts generated from the Proposed Project’s construction and potential regional impacts on land use and planning.

Cumulative impact thresholds for land use and planning are the same as the impact thresholds presented in Section 3.11, Land Use and Planning. Cumulative impacts are considered significant if they result in the following:
 Cumulative Impact LU-1: Physically divide an established community  Cumulative Impact LU-2: Cause any 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
As discussed in Section 3.11, the Proposed Project would not physically divide an established community, resulting in no impact. As a result, by definition, the Proposed Project would not contribute to a significant cumulative impact. The cumulative projects listed in Table 4.5-1 would be subject to zoning requirements and require approval if zoning changes are proposed. According to the Town of Paradise 2022-2030 Housing Element Update, key parcels in the sewer service area would require rezoning, and a Sewer Service Overlay Zone will be established to allow increased densities up to 30 dwelling units per acre in the sewer service area (Town of Paradise 2022). The Proposed Project is consistent with the goals and policies in the Housing Element Update as it would serve most businesses in the Town and provide for future development of more multi-family residences, which is currently limited because of septic system constraints. It is possible that some cumulative projects could divide an established community depending on the project location. However, many of the cumulative projects under consideration, such as the Tuscan Ridge Project, City of Chico Nitrate Plan, Chico 610
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 431
WPCP Upgrade/Expansion Project, Paradise Transit Center, and Town of Paradise Recovery Projects, do not include major roads, and would be constructed on an existing site, on existing infrastructure, or underground, and would not divide an established community. During construction of the cumulative projects, staging of construction vehicles and equipment could impede road access and road closures might be required. Similar to the Proposed Project, these impacts would be temporary and road access would be restored once construction is complete. Therefore, the Proposed Project’s impacts from dividing an established community, in combination with other cumulative projects, would not be cumulatively considerable.

The Proposed Project would not conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect, resulting in no impact. As a result, by definition, it would not contribute to a significant cumulative impact. As stated in Table 3.11-1, the Proposed Project is consistent with applicable land use and planning goals and policies identified in Section 3.11 Land Use and Planning, and Appendix C, Regulatory Framework, including Town of Paradise General Plan Objective LUO-10, which calls for the construction and installation of a formal sewer system. The Town of Paradise is updating its General Plan in response to the 2018 Campfire, and will include updates to its land use, circulation, conservation, noise, open space, and air quality elements, as well as other new state laws. It is anticipated to be a minimum 3-year process (S.

Hartman, personal communication, November 19, 2021). According to Susan Hartman, the Town Planning Manager, the Proposed Project is also consistent with the goals and policies of the updated Town of Paradise General Plan (S. Hartman, personal communication, November 19, 2021). The Proposed Project would also comply with goals, policies and objectives in the updated City of Chico General Plan The other cumulative activities defined in Table 4.5-1 would be subject to compliance with similar zoning regulations, land use plans, policies, or regulations, and would otherwise require approval by Butte County, the Town, and the City of Chico prior to construction. Based on these factors, the Proposed Project would not contribute to cumulative impacts on land use and planning, and in combination with the cumulative projects, would not be cumulatively considerable. Table 4.5-11 provides a summary of cumulative impacts on land use and planning.

Table 4.5-11. Summary of Proposed Project Impact Contribution to Cumulative Land Use and Planning Impacts
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact LU-1: Physically divide an
established community LTS NCC N/A NCC
Cumulative Impact LU-2: Cause any
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.

LTS NCC N/A NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact
611
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 432

4.5.2.11 Noise and Groundborne Vibration
Noise and groundborne vibration impacts are highly localized in nature. As such, the geographic study area for the cumulative impact analysis for noise includes the Proposed Project as well as a 1,000-foot buffer surrounding the Proposed Project, which includes sensitive receptors that could be exposed to noise and groundborne vibration impacts.

Cumulative impact thresholds for noise are the same as the thresholds presented in Section 3.12 Noise and Groundborne Vibration. Cumulative impacts are considered significant if they result in the following:
 Cumulative Impact NSE-1: Generate 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 in applicable standards of other agencies  Cumulative Impact NSE-2: Generate excessive groundborne vibration or groundborne noise levels
 Cumulative Impact NSE-3: Be located within the vicinity of a private airstrip or an airport landuse plan or, where such a plan has not been adopted, within two miles of a public airport or public-use airport, expose people residing or working in the Project area to excessive noise levels
Noise
Potential growth and development within the cumulative study area could contribute to cumulative noise impacts by generating noise during construction and operation and maintenance within the cumulative study area. Cumulative projects, such as the Paradise Irrigation District Project Water Intertie, Chico WPCP Upgrades, Tuscan Ridge Project, Paradise Transit Center, and Town of Paradise Recovery Projects, would generate noise during construction activities. Likewise, during construction, the Proposed Project could result in noise levels that would exceed the applicable daytime noise limits.

However, Project-generated noise levels would not combine with the noise of these projects to result in cumulative noise impacts because temporary Proposed Project construction activities would not be located in close proximity to planned, concurrent construction projects. Further, construction-related noise is typically a site-specific impact that affects only those in the vicinity of the construction activities.

Still, with the implementation of mitigation measure MM-NSE-1: Minimize Construction Noise, the Proposed Project’s noise levels during construction would be within the allowable limits of all applicable jurisdictions. Noise levels from operation and maintenance activities of the Proposed Project would be minimal and immeasurable due to the infrequency of these activities. Impacts from other cumulative projects listed in Table 4.5-1 would likely be similar and would likely require similar mitigation measures.

Therefore, with the implementation of mitigation measure MM-NSE-1, the Proposed Project’s contribution to cumulative noise impacts would be less than significant. Cumulative noise impacts would be distinct in location and would not be expected to be additive, and therefore would not be cumulatively considerable.

Groundborne Vibration
Potential growth and development within the cumulative study area could contribute to cumulative groundborne vibration impacts by generating groundborne vibration during construction and operation and maintenance within the cumulative study area.
612
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 433
Cumulative projects, including the Paradise Irrigation District Project Water Intertie, Chico WPCP Upgrades, Tuscan Ridge Project, Paradise Transit Center, and Town of Paradise Recovery Projects, would be expected to generate groundborne vibrations during construction activities. During construction, groundborne vibration associated with the Proposed Project is not anticipated to result in structural damage within the cumulative study area. However, groundborne vibration associated with Proposed Project construction could exceed the criteria for human annoyance. However, Projectgenerated groundborne vibration levels would not combine with the noise levels of these projects to result in cumulative groundborne vibration impacts. This is because groundborne vibration generally only travels short distances from the vibration source and does not readily combine with other vibration sources to increase in magnitude because of differing frequencies. Even if construction of cumulative projects occurs on adjacent properties at the same time, it is unlikely that there would be multiple vibration sources (such as impact pile drivers) generating high levels of vibration at the same frequency and at the same time in proximity to the same sensitive receptors. Still, with the implementation of mitigation measure MM-NSE-1: Minimize Construction Noise, the Proposed Project’s vibration levels on nearby noise-sensitive receptors would be below the criteria for human annoyance. Groundborne vibration levels from operation and maintenance activities of the Proposed Project would be minimal and immeasurable due to the infrequency of these activities. Impacts from other cumulative projects listed in Table 4.5-1 would likely be similar and would likely require similar mitigation measures.

Therefore, with the implementation of mitigation measure MM-NSE-1, the Proposed Project’s contribution to cumulative groundborne vibration impacts would be less than significant. Like noise impacts, cumulative impacts from groundborne vibration would be distinct in location and would not be expected to be additive, and therefore would not be cumulatively considerable.

Airport Noise
As discussed in Section 3.12 Noise and Groundborne Vibration, the Proposed Project would result in a less-than-significant impact on people residing or working in the area to excessive airport noise levels.

Cumulative projects listed in Table 4.5-1 have the potential to expose people residing or working in the vicinity of public or private airports to excessive noise levels, depending on their locations. Cumulative projects, including the Proposed Project, would be subject to land use plans, policies, or regulations that support necessary growth while minimizing impacts from airports or airstrips on surrounding land uses. Therefore, the Proposed Project’s contribution would be less than significant, and in combination with the cumulative projects would not be cumulatively considerable. Table 4.5-12 provides a summary of cumulative impacts on noise.

Table 4.5-12. Summary of Proposed Project Impact Contribution to Cumulative Noise and Groundborne Impacts
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact NOISE-1: Generate 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 in applicable
standards of other agencies
SI CC MM-NSE-1 NCC
613
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 434
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact NOISE-2: Generate excessive
groundborne vibration or groundborne noise
levels
SI CC MM-NSE-1 NCC
Cumulative Impact NOISE-3: Be located within
the vicinity of a private airstrip or an airport landuse plan or, where such a plan has not been adopted, within two miles of a public airport or
public-use airport, expose people residing or
working in the Project area to excessive noise
levels

LTS NCC N/A NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.12 Population and Housing
The geographic study area for the cumulative impact analysis for population and housing is defined as the jurisdictions that are within the Core and Extended Collection Systems and the Export Pipeline System alignment. This includes Paradise and Chico as well as the unincorporated areas of Butte County. This cumulative study area would capture impacts generated from the Proposed Project’s construction and potential regional impacts on population and housing.

Cumulative impact thresholds for population and housing are the same as the thresholds presented in Section 3.13 Population and Housing. Cumulative impacts are considered significant if they result in the following:
 Cumulative Impact POP-1: Induce substantial unplanned population growth in an area, either directly (e.g., by proposing new homes and businesses) or indirectly (e.g., through extension of roads or other infrastructure)
 Cumulative Impact POP-2: Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere The Proposed Project, considered along with the cumulative projects, such as the City of Chico Nitrate Plan, Chico WPCP Upgrades, Paradise Irrigation District Project Water Intertie, Paradise Transit Center, and Town of Paradise Recovery Projects, could indirectly foster population growth through by installing improved infrastructure and wastewater treatment. As a matter of fact, many of these cumulative projects are in response the Camp Fire recovery efforts. As discussed in Section 3.1,3 Population and Housing, a substantial decrease of approximately 83 percent of the population in Paradise occurred as a result of the 2018 Camp Fire. Any inducement of the population as a result of the Proposed Project or other cumulative projects would be a regrowth or repopulation of this area once found to be the most populated area of Butte County. While population growth that might result indirectly from the Proposed Project would be contained in Paradise, other cumulative activities could induce growth in Chico or elsewhere. Therefore, the Proposed Project’s contribution would be less than significant, and in combination with the cumulative projects would not be cumulatively considerable. 614
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 435
The Proposed Project would not displace substantial numbers of existing people or housing which would necessitate the construction of replacement housing, resulting in no impact. The Proposed Project and the cumulative projects would not acquire or take any residential-zoned land in the area.

Many of the cumulative projects are infrastructure improvement projects that would occur at an existing site, on existing infrastructure, or below ground. Improvements would not displace people or housing.

Therefore, the Proposed Project would not contribute to cumulative impacts on this criterion, and impacts would not be cumulatively considerable in combination with other cumulative projects. Table

4.5-13 provides a summary of cumulative impacts on population and housing.

Table 4.5-13. Summary of Proposed Project Impact Contribution to Cumulative Population and Housing Impacts
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact POP-1: Induce substantial
unplanned population growth in an area, either
directly (e.g., by proposing new homes and
businesses) or indirectly (e.g., through extension
of roads or other infrastructure)

LTS NCC N/A NCC
Cumulative Impact POP-2: Displace substantial
numbers of existing people or housing,
necessitating the construction of replacement
housing elsewhere

NI NCC N/A NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.13 Public Services
The geographic study area for the cumulative impact analysis for public services is defined by the Proposed Project’s construction limits and includes all areas in and between Paradise and Chico Cumulative impact thresholds for recreation are the same as the impact thresholds presented in Section 3.14 Public Services. Cumulative impacts are considered significant if they result in the following:
 Cumulative Impact PS-1: Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically 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 following public services:
a. Fire Protection
b. Police Protection
c. Schools
d. Other Public Facilities
Construction of Cumulative projects, including the Proposed Project, would not directly impact fire protection facilities, police protection facilities, schools, and other public facilities. However, indirect impacts may occur related to emergency vehicle access that may be impeded during construction of 615
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 436
cumulative projects, including the Proposed Project. As discussed in Section 3.14, with the implementation of mitigation measure MM-HAZ-6: Traffic Management Plan, the Proposed Project’s impacts on fire protection facilities, police protection facilities, schools, and other public facilities during construction would be less than significant. The Proposed Project, Chico WPCP Upgrades, City of Chico Nitrate Plan, Paradise Irrigation District Project Water Intertie, Tuscan Ridge Project, Paradise Transit Center, and Town of Paradise Recovery Projects are all infrastructure projects intended to improve water supply and quality or the wastewater system. None of the cumulative projects, including the Proposed Project, would result in any permanent impacts to fire protection facilities, police protection facilities, schools, and other public facilities. Some of these projects, including the Proposed Project and the Chico WPCP Upgrades, could indirectly induce population growth, resulting in the need for additional fire protection facilities, police protection facilities, schools, and other public facilities.

However, the Town of Paradise General Plan Update would consider future development in the area and further include elements and policies that address the need for additional public services. Impacts from other cumulative projects listed in Table 4.5-1 would likely be similar and would likely require similar mitigation measures. Therefore, the Proposed Project’s contribution to cumulative public services impacts would be less than significant with the implementation of mitigation measure MMHAZ-6, and in combination with the cumulative projects would not be cumulatively considerable. Table

4.5-14 provides a summary of cumulative impacts on public services.

Table 4.5-14. Summary of Proposed Project Impact Contribution to Cumulative Public Services Impacts
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact PS-1: Result in substantial
adverse physical impacts associated with the
provision of new or physically altered
governmental facilities, need for new or physically
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 following public services:
a. Fire Protection
b. Police Protection
c. Schools
d. Other Public Facilities
SI CC MM-HAZ-6 NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.14 Recreation
The geographic study area for the cumulative impact analysis for recreation is defined by the Proposed Project’s construction limits and includes all areas in and between Paradise and Chico Cumulative impact thresholds for recreation are the same as the impact thresholds presented in Section 3.15 Recreation. Cumulative impacts are considered significant if they result in the following:
616
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 437
 Cumulative Impact REC-1: 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
 Cumulative Impact REC-2: Include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment
The Proposed Project, Chico WPCP Upgrades, City of Chico Nitrate Plan, Paradise Irrigation District Project Water Intertie, Tuscan Ridge Project, Paradise Transit Center, and Town of Paradise Recovery Projects are all infrastructure projects intended to improve water supply and quality or the wastewater system. None of the cumulative projects, including the Proposed Project, would result in any permanent impacts to recreational facilities. Some of these projects, including the Proposed Project, the Chico WPCP Upgrades, and the Town of Paradise Recovery Projects, could induce population growth, resulting in the need for additional recreational facilities. However, the Town of Paradise General Plan Update would consider the need for additional recreational facilities and balance these needs against local goals and policies. Cumulative projects, including the Proposed Project, would not directly result in permanent acquisition, displacement, or relocation of parks and recreational facilities. During Project construction, temporary road and bike path closures may be required that could limit access to parks and recreational facilities. Minor increases in recreational use at other available facilities may occur on a short-term basis, but substantial physical deterioration of these facilities is not expected to occur or to be accelerated. Impacts from other cumulative projects listed in Table 4.5-1 would likely be similar.

Therefore, the Proposed Project would not contribute to cumulative recreation impacts, and impacts would not be cumulatively considerable in combination with other cumulative projects. Table 4.5-15 provides a summary of cumulative impacts on recreation.

Table 4.5-15. Summary of Proposed Project Impact Contribution to Cumulative Recreation Impacts Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact REC-1: Increase the use of
existing neighborhood and regional parks or
recreational facilities such that substantial
physical deterioration of the facility would occur or
be accelerated

LTS CC N/A NCC
Cumulative Impact REC-2: Include recreational
facilities or require the construction or expansion
of recreational facilities, which might have an
adverse physical effect on the environment

LTS CC N/A NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.15 Transportation
The geographic study area for the cumulative impact analysis for transportation is defined by the Proposed Project’s construction footprint within Paradise, Chico, and the unincorporated county between the two where the Export Pipeline System would be installed. This cumulative study area 617
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 438
would capture impacts generated from the Proposed Project’s construction and potential regional impacts on transportation.

Cumulative impact thresholds for transportation are the same as the thresholds presented in Section 3.16 Transportation. Cumulative impacts are considered significant if they result in the following:
 Cumulative Impact TRA-1: Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities  Cumulative Impact TRA-2: Conflict with or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)
 Cumulative Impact TRA-3: Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)  Cumulative Impact TRA-4: Result in inadequate emergency access The Proposed Project, considered along with the cumulative projects, including the Paradise Irrigation District Project Water Intertie, Chico WPCP Upgrades, Tuscan Ridge Project, Paradise Transit Center, and Town of Paradise Recovery Projects, would have potential for temporary construction-related transportation impacts and traffic operations degradation. The Proposed Project would implement mitigation measure MM-HAZ-6: Traffic Management Plan to reduce transportation impacts during construction to a less-than-significant level. Other cumulative projects may also implement a similar mitigation measure to minimize transportation impacts. Cumulative projects, including the Proposed Project, do not involve the permanent closure of any roads or features that would substantially impact the transportation system or circulation in the region. Therefore, the Proposed Project’s cumulative contribution to conflicting with a transportation program, plan, ordinance, or policy would be less than significant with the implementation of mitigation measure MM-HAZ-6. When combined with other cumulative projects, these impacts would not be cumulatively considerable.

The Proposed Project and cumulative projects would not conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b). This is because the Proposed Project and cumulative projects would not cause an increase in travel for the future besides the increase in trips due to construction. Therefore, the Proposed Project would not significantly contribute to a cumulative impact on inconsistencies with CEQA Guidelines Section 15064.3, subdivision (b), and in combination with the cumulative projects would not be cumulatively considerable.

Finally, the Proposed Project and the cumulative projects would not involve any permanent hazard geometric design feature or incompatible uses. This is because the Proposed Project and most of the cumulative projects, such as the Tuscan Ridge Project, City of Chico Nitrate Plan, Paradise Irrigation District Project Water Intertie, Paradise Transit Center, and Town of Paradise Recovery Projects, are infrastructure improvement projects and would largely occur on an existing site, on existing infrastructure, or underground. Based on these factors, the Proposed Project would not significantly contribute to a cumulative impact on transportation, and in combination with the cumulative projects, would not be cumulatively considerable.
618
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 439
The Proposed Project, considered along with the cumulative projects, including the Paradise Irrigation District Project Water Intertie, Chico WPCP Upgrades, Tuscan Ridge Project, Paradise Transit Center, and Town of Paradise Recovery Projects, would have potential to interfere with emergency access during construction. The Proposed Project would implement mitigation measure MM-HAZ-6: Traffic Management Plan to reduce impacts associated with inadequate emergency access during construction to a less-than-significant level. Other cumulative projects may also implement a similar mitigation measure. Cumulative projects, including the Proposed Project, would not include any permanent impacts to emergency response routes. Therefore, the Proposed Project’s cumulative contribution to inadequate emergency access would be less than significant with the implementation of mitigation measure MM-HAZ-6. When combined with other cumulative projects, these impacts would not be cumulatively considerable. Table 4.5-16 provides a summary of cumulative impacts on transportation.

Table 4.5-16. Summary of Proposed Project Impact Contribution to Cumulative Transportation Impacts
Level of Incremental Applicable Incremental
Impact Cumulative Project Project Impact After
Significance Contribution Mitigations Mitigation
Cumulative Impact TRA-1: Conflict with a program
plan, ordinance or policy addressing the
circulation system, including transit, roadway,
bicycle and pedestrian facilities
SI CC MM-HAZ-6 NCC
Cumulative Impact TRA-2: Conflict with or be
inconsistent with CEQA Guidelines section
15064.3, subdivision (b)

LTS NCC N/A NCC
Cumulative Impact TRA-3: Substantially increase
hazards due to a geometric design feature (e.g.,
sharp curves or dangerous intersections) or
incompatible uses (e.g., farm equipment)

LTS NCC N/A NCC
Cumulative Impact TRA-4: Result in inadequate
emergency access
SI CC MM-HAZ-6 NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.16 Tribal Cultural Resources
The geographic study area for the cumulative impact analysis for tribal cultural resources includes central and northern Butte County and was selected because these areas include the relatively undeveloped portions of the ancestral Mechoopda and Konkow territory, and those rural areas outside of the historically developed urban population center in Chico.

As discussed in Section 4.5.2.4, according to CEQA, the importance of cultural resources comes from the research value and the information that they contain. Therefore, the issue that must be explored in a cumulative analysis is the cumulative loss of that information.

Cumulative impact thresholds for tribal cultural resources are the same as the thresholds presented in Section 3.17 Tribal Cultural Resources. Cumulative impacts are considered significant if they result in the following:
619
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 440
 Cumulative Impact TCR-1: Cause a substantial adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, or 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:
o Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k), or o 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 PRC Section 5024.1. In applying the criteria set forth in subdivision (c) of PRC Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

The Chico WPCP Upgrades, Paradise Irrigation District Project Water Intertie, Tuscan Ridge Project, Paradise Transit Center, and Town of Paradise Recovery Projects have the potential to impact TCRs.

Ground disturbance associated with each of the aforementioned projects, and the Proposed Project, could result in potentially significant cumulative impacts on previously recorded and/or newly discovered TCR if identified within the footprint of each project. However, implementing MM-TCR-1:

Coordination with Konkow Valley Band of Maidu and Mechoopda Indian Tribe and MM-TCR-2:

Tribal Cultural Monitoring would reduce the Proposed Project’s contribution to cumulative impacts to a less than significant level because appropriate procedures would be followed to avoid impact on TCR in sensitive areas identified by the tribes during Proposed Project-related ground-disturbing activities.

Implementation of these measures would provide assurances that the Proposed Project would not have a significant contribution to impacts on TCR that meet significance criteria of the CRHR. Impacts from other cumulative projects listed in Table 4.5-1 would likely be similar and would likely require similar mitigation measures. Therefore, the Proposed Project’s contribution to cumulative impacts on tribal cultural resources would be less than significant with the implementation of mitigation measures MMTCR-1 and MM-TCR-2, and in combination with the cumulative projects would not be cumulatively considerable. Table 4.5-17 provides a summary of cumulative impacts on tribal cultural resources.

Table 4.5-17. Summary of Proposed Project Impact Contribution to Cumulative Tribal Cultural Resources Impacts
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
TCR-1: Cause a substantial adverse change in the
significance of a tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, or 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:
 Listed or eligible for listing in the California
Register of Historical Resources, or in a local
register of historical resources as defined in
PRC Section 5020.1(k), or
SI CC MM-TRC-1,
MM-TCR-2 NCC
620
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 441
Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
 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 PRC
Section 5024.1. In applying the criteria set forth
in subdivision (c) of PRC Section 5024.1, the
lead agency shall consider the significance of
the resource to a California Native American
tribe.

Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.17 Utilities and Service Systems
The geographic study area for the cumulative impacts analysis for utilities and service systems is defined by the Proposed Project’s construction footprint within Paradise, Chico, and unincorporated Butte County between the two where the export pipeline would be installed. This cumulative study area would capture impacts generated from the Proposed Project’s construction and potential regional impacts due to the nature of utility connections.

Cumulative impact thresholds for public utilities are the same as the thresholds presented in Section 3.18 Utilities and Service Systems. Cumulative impacts are considered significant if they result in the following:
 Cumulative Impact UTIL-1: Require or result in the relocation or construction of new or expanded water, wastewater treatment, storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects
 Cumulative Impact UTIL-2: Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years  Cumulative Impact UTIL-3: Result in a determination by the wastewater treatment provider, which serves or may serve the project that it has inadequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments  Cumulative Impact UTIL-4: 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
 Cumulative Impact UTIL-5: Comply with federal, state, and local management and reduction statutes and regulations related to solid waste
Relocation and Construction of Utility Infrastructure
As discussed in Section 3.18, the Proposed Project would not require or result in relocating or constructing utility infrastructure. However, utilities could be affected during construction of the Proposed Project, with the potential for disruption of utility service. The Proposed Project would implement mitigation measure MM-UTIL-1: Minimize Utility and Service System Disruptions to reduce impacts on utility service during construction to a less-than-significant level. Cumulative projects, such as the 621
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 442
Chico WPCP Upgrades, Paradise Irrigation District Project Water Intertie, Tuscan Ridge Project, Paradise Transit Center, and Town of Paradise Recovery Projects, would involve ground-disturbing work during construction that could intersect with utility infrastructure. PG&E is also currently relocating their utility infrastructure underground in the Town of Paradise. However, it is assumed that cumulative projects could avoid or otherwise restore or replace electric infrastructure, stormwater drainage, or telecommunications facilities and that exposed ground from construction activities would be restored.

Other cumulative projects may also implement a similar mitigation measure to minimize impacts on utility service. Any potential service disruptions would be short term and would require coordination with utility service providers, the Town, and the City, depending on the location of the service interruption. Based on these factors, the Proposed Project’s contribution to cumulative impacts on utility service would be less than significant with the implementation of mitigation measure MM-UTIL-1. When combined with other cumulative projects, these impacts would not be cumulatively considerable.

Water Supply
As discussed in Section 3.18, the Proposed Project would have no impact on water supply. Water supply required during construction of the Proposed Project would be the responsibility of the construction contractor and would only be required temporarily during the duration of construction. No potable water would be required during operation and maintenance of the Proposed Project. Other cumulative projects may require use of water supply during construction and/or operation and maintenance. However, projects such as the City of Chico Nitrate Plan, Chico WPCP Upgrades, Tuscan Ridge Project, Paradise Irrigation District Project Water Intertie, Paradise Transit Center, and Town of Paradise Recovery Projects would likely only require water supply during the duration of construction and would not require water supply during operation and maintenance given that these are largely infrastructure improvement projects.

Therefore, the Proposed Project would not contribute to significant cumulative impacts on water supply, and in combination with other cumulative projects, would not be cumulatively considerable.

Wastewater
As discussed in Section 3.18, the Proposed Project would have no impact on wastewater generation.

Other cumulative projects would generate wastewater temporarily during the duration of construction. It is assumed that cumulative projects involved in the construction of wastewater treatment, such as the Tuscan Ridge Project, City of Chico Nitrate Plan, Chico Upgrades, and Paradise Irrigation District Project Water Intertie , would have similar objectives as the Proposed Project. While these projects are not part of the Proposed Project’s sewer collection system, these projects would allow for more efficient wastewater management compared to the region’s existing sewer systems. Therefore, it is anticipated that some of these projects would result in beneficial cumulative impacts on wastewater. As a result, The Proposed Project would not contribute to significant cumulative impacts on wastewater, and in combination with other cumulative projects, would not be cumulatively considerable.

Solid Waste
As discussed in Section 3.18, the Proposed Project would have no impact on solid waste. The Proposed Project would generate solid waste during construction; however, the volume of waste is within the capacity accommodated by the existing landfills in the region. No solid waste would be generated during operation and maintenance. The Proposed Project has the potential to foster population regrowth as a result of Camp Fire recovery efforts which could place an additional demand on landfills. However, longterm landfill usage would be similar to pre-Camp Fire levels and within the approved capacities. The Proposed Project would also comply with federal, state, and local management and reduction statutes and regulations related to solid waste, as discussed in Table 3.18-2, Consistency with State and Local 622
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 443
Plans, Policies, and Regulations. Other cumulative projects in the area would also generate solid waste during construction and/or operation and maintenance; however, these projects would be subject to compliance with federal, state, and local regulations regarding solid waste. While there is a potential for cumulative projects listed in Table 4.5-1 to generate solid waste, these projects would require coordination with existing landfills or redistribution to other landfills with adequate capacity. The Proposed Project would not contribute to significant cumulative impacts on solid waste, and in combination with other cumulative projects, would not be cumulatively considerable. Table 4.5-18 provides a summary of cumulative impacts on utilities and service systems.

Table 4.5-18. Summary of Proposed Project Impact Contribution to Cumulative Utilities and Service Systems Impacts
Level of Incremental Applicable Incremental
Impact Cumulative Project Project Impact After
Significance Contribution Mitigations Mitigation
Cumulative Impact UTIL-1: Require or result in the
relocation or construction of new or expanded water,
wastewater treatment, storm water drainage, electric
power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects
SI CC MM-UTIL-1 NCC
Cumulative Impact UTIL-2: Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry
years

NI NCC N/A NCC
Cumulative Impact UTIL-3: Result in a determination by
the wastewater treatment provider, which serves or may
serve the project that it has inadequate capacity to serve the project’s projected demand in addition to the
provider’s existing commitments

NI NCC N/A NCC
Cumulative Impact UTIL-4: 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

NI NCC N/A NCC
Cumulative Impact UTIL-5: Comply with federal, state,
and local management and reduction statutes and
regulations related to solid waste

NI NCC N/A NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact

4.5.2.18 Wildfire
The geographic study area for the cumulative impact analysis for wildfire is defined as the areas within and directly adjacent to the Town of Paradise and areas of unincorporated Butte County and Chico where the proposed pipeline alignment runs.

Cumulative impact thresholds for hazards and hazardous material are the same as the thresholds presented in Section 3.19 Wildfire. Cumulative impacts are considered significant if they result in the following:
623
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 444
 Cumulative Impact FIRE-1: Substantially impair an adopted emergency response plan or emergency evacuation plan
 Cumulative Impact FIRE-2: Exacerbate wildfire risks due to slope, prevailing winds, and other factors, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire
 Cumulative Impact FIRE-3: 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
 Cumulative Impact FIRE-4: 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
Emergency Response Plan or Emergency Evacuation Plan
The Proposed Project has the potential to result in interruptions to emergency response or evacuation routes due to temporary road/lane closures during construction. Construction of the Proposed Project would occur Skyway, which is an evacuation route in Paradise. With the implementation of mitigation measures MM-HAZ-3: Road Closure Restrictions, MM-HAZ-4: Rapid Demobilization Plan, MMHAZ-5: Evacuation Warning Procedures, and MM-HAZ-6: Traffic Management Plan, impacts on emergency response plan or emergency evacuation plan during construction would be reduced to less than significant. There would be no interruptions to emergency response or evacuation routes during operation and maintenance activities. Impacts from other cumulative projects would likely be similar and would likely require similar mitigation measures. Therefore, the Proposed Project’s contribution to cumulative impacts on this criterion would be less than significant with the implementation of aforementioned mitigation measures, and in combination with the cumulative projects, would not be cumulatively considerable.

Exacerbate Wildfire Risks
The Proposed Project is located in a VHFHSZ and has the potential to exacerbate wildfire risks during construction that could affect the public and the environment. With the implementation of mitigation measures MM-HAZ-1: Vehicle Equipment Access and Fueling, MM-HAZ-7: Incorporate Fire Prevention Measures, MM-HAZ-8: Incorporate Public Safety Measures, and MM-HAZ-9: Wildland Fire Area, impacts from exacerbating wildfire risks would be reduced to less than significant. Operation and maintenance activities associated with the Proposed Project would not exacerbate wildfire risks that affect the public or the environment. It is possible that some cumulative projects could exacerbate wildfire risks during construction, operation and maintenance, depending on project location. These cumulative projects would likely require similar mitigation measures to reduce impacts from exacerbating wildfire risks. Therefore, the Proposed Project’s contribution to cumulative impacts on these criteria would be less than significant with the implementation of aforementioned mitigation measures, and in combination with the cumulative projects, would not be cumulatively considerable.

Fire-related Flooding or Landslides
Given the sloped topography of the Town, the Proposed Project has the potential to create runoff or alter drainage patterns during construction. With the implementation of mitigation measures MMHYD-1: Stormwater Management and Treatment Plan, MM-HYD-3: Flood Protection Plan, and MM-GEO-1: Minimize Geologic Hazards, impacts from exposing people or structures to significant 624
Paradise Sewer Project | Final Program Environmental Impact Report Other CEQA Considerations
hdrinc.com
Final Program Environmental Impact Report 445
risks, including downslope or downstream flooding or landslides, would be reduced to less than significant. Operation and maintenance of the Proposed Project would not involve activities that create runoff or alter drainage. Impacts from other cumulative projects would likely be similar and would likely require similar mitigation measures. Therefore, cumulative impacts on this criterion would be less than significant with the implementation of aforementioned mitigation measures and the Proposed Project’s contribution would not be cumulatively considerable. Table 4.5-19 provides a summary of cumulative impacts on wildfires.

Table 4.5-19. Summary of Proposed Project Impact Contribution to Cumulative Wildfire Impacts Impact
Level of
Cumulative
Significance
Incremental
Project
Contribution
Applicable
Project
Mitigations
Incremental
Impact After
Mitigation
Cumulative Impact FIRE-1: Substantially impair
an adopted emergency response plan or
emergency evacuation plan SI CC
MM-,HAZ-3
MM-HAZ-4,
MM-HAZ-5,
MM-HAZ-6
NCC
Cumulative Impact FIRE-2: Exacerbate wildfire
risks due to slope, prevailing winds, and other
factors, and thereby expose project occupants to
pollutant concentrations from a wildfire or the
uncontrolled spread of a wildfire
SI CC
MM-HAZ-1,
MM-,HAZ-7
MM-HAZ-8,
MM-HAZ-9
NCC
Cumulative Impact FIRE-3: 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
SI CC
MM-HAZ-1,
MM-HAZ-7,
MM-HAZ-8,
MM-HAZ-9
NCC
Cumulative Impact FIRE-4: 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
SI CC
MM-HYD-1,
MM-HYD-3,
MM-GEO-1
NCC
Notes: CC = cumulatively considerable, N/A = not applicable, NCC = not cumulatively considerable, NI = no impact, LTS = less than significant impact, SI = significant impact
625
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 446
Page Intentionally Blank
626
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 447

5. Alternatives

5.1 Introduction

5.1.1 CEQA Requirements
This chapter describes alternatives to the Proposed Project, consistent with CEQA Guidelines Section 15126.6. This chapter presents a description of the alternatives that were considered but eliminated from further consideration, followed by an analysis of the five alternatives evaluated, including the No Project Alternative. A comparison of the alternatives to the Proposed Project is provided, and the environmentally superior alternative is identified.

CEQA Guidelines Section 15126.6(a) states that “an EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation.” Further, an EIR need not consider an alternative whose effect cannot be reasonably ascertained and whose implementation is remote and speculative and/or infeasible (CEQA Guidelines Section 15126.6(f)(3)). Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries (projects with a regionally significant impact should consider the regional context), and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site (or the site is already owned by the proponent) (CEQA Guidelines Section 15126.6(f)(1)).

The CEQA Guidelines specifically require consideration of a “No Project” alternative. Including a No Project alternative allows decision-makers to compare the impacts of approving the project with the impacts of not approving the project. The No Project alternative is discussed in detail in Section 5.3.1, No Project Alternative.

In addition to the No Project Alternative and the Alternatives evaluated in the PEIR (Section 5.3), this chapter also introduces alternatives considered during the early planning process that were eliminated from further consideration. These alternatives, as discussed in Section 5.2, do not respond to or reduce significant impacts from the Proposed Project; however, they are included to describe the background of alternatives screening process and to present those results.

5.1.2 Project Objectives and Goals
Alternatives were evaluated and considered largely based on their ability to meet the objectives and goals of the Proposed Project. As discussed in Section 2.3 Project Need and Objectives, the objectives and associated goals of the Proposed Project are as follows:
627
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 448
 Provide long-term, efficient, reliable treatment of wastewater in a cost-effective, environmentally beneficial manner to current and returning Town residents, in a manner acceptable to the RWQCB and other permitting agencies;
o Accommodate regrowth while reducing further environmental degradation of groundwater and surface water from failing septic systems;
o Reduce the public health risk associated with failing septic systems;  Generate economic recovery by eliminating septic-related capacity limitations, as well as the general burden of on-site wastewater management for businesses; o Promote the return or arrival of essential community services and businesses by removing restrictions caused by on-site septic systems;
 Provide for the ability to construct and maintain affordable housing, specifically multi-family housing;
o Support centralizing affordable housing to Paradise’s urban core, along major evacuation routes.

5.2 Alternatives Considered but Eliminated from Detailed Consideration
Per CEQA Guidelines Section 15126.6, the EIR should briefly describe the rationale for selecting the alternatives to be discussed. The EIR also should identify any alternatives that were considered by the lead agency but were rejected and should briefly explain the reasons underlying the lead agency’s determination to remove these alternatives from consideration. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are:

9. failure to meet most of the project objectives,

10. effects that cannot be reasonably ascertained, for which implementation is remote and speculative,

11. infeasibility, or

12. inability to avoid significant environmental impacts that could result from implementation of the Proposed Project.

Per CEQA Guidelines Section 15126.6, discussion on alternatives to the proposed project should focus on those alternatives that feasibly accomplish most of the basic objectives and avoid or substantially lessen one or more of the significant effects (CEQA Guidelines Section 15126.6 [b]). As used here, feasible means ""capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors." (14 CCR Section 15364. See also PRC Section 21061.1). Specific factors may include:
 Site suitability;
 Economic viability;
 Availability of infrastructure;
 Availability of infrastructure;
628
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 449
 General plan consistency;
 Other plans or regulatory limitations;
 Jurisdictional boundaries;
 Whether the project proponent already owns the site; and  Whether the project proponent can acquire, control, or have access to the site if it does not own it. (14 CCR Section 15126.6(f)(1))
As such, the Town considered the following Project alternatives, which were developed during early planning efforts but eliminated them from further consideration, as explained in the following sections:
 Local construction of a new wastewater treatment plant in Town of Paradise  Neal Road export pipeline alignment
 Butte Creek alignment spur within the Skyway Export Pipeline System alignment

5.2.1 Local Construction of New Wastewater Treatment Plant Since 1969, the Town has prepared 13 different studies in its efforts to identify a viable wastewater solution for the Town (Section 2.2 Project Background). All of those studies considered a sewer collection system within the Town to gather wastewater that currently goes to existing septic tank systems and also assessed alternatives for treating and discharging or reusing the wastewater gathered by that collection system. The studies considered building a new wastewater treatment plant near the Town, to be owned and operated by the Town, with various options for reusing or discharging the treated wastewater. The studies also considered piping the wastewater to the City of Chico’s WPCP, for treatment. In the 2017 Town of Paradise Sewer Project, Alternative Analysis and Feasibility Report (Bennett Engineering 2017), construction of a local wastewater treatment plant was not recommended, primarily due to funding and land use restrictions. However, following the devastation caused by the November 2018 Camp Fire, the Town Council voted to reconsider a local wastewater treatment alternative because of the potential for more funding becoming available; availability of more land to consider as a location for a local WWTP due to the devastation caused by the Camp Fire; and because the Town would have more control over future decisions related to wastewater management if it owned its own wastewater treatment plant. The four local alternatives that were considered are presented in Table 5.2-1. The table also provides reasons why these alternatives were found to be infeasible and were not considered in this EIR. For these reasons, the local wastewater treatment alternative was eliminated from consideration due to infeasibility, as described in CEQA Guidelines Section 15126.6 (criterion 2 above).

As discussed in Section 2.3.2, Project Objectives and Goals, removing septic systems in areas where specific systems have failed, or are projected to fail would directly respond to the goals and priorities identified in SWECB’s Strategic Plan. The document also describes SWRCB’s Strategic Priority Actions, and in a discussion on wastewater infrastructure and sustainability, states:

The need for updated and new infrastructure is particularly critical for small communities with very limited resources. The State Water Board will emphasize a renewed focus on small community wastewater projects and make it a priority to help ensure that small and/or disadvantaged communities have the resources needed to protect water quality and public health related to wastewater (SWRCB 2010). 629
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 450
A lead agency may determine that an alternative is infeasible because of a conflict with relevant policies or regulatory limitations. Recent caselaw examples include the following:
 Bay Area Citizens v Association of Bay Area Gov'ts (2016) 248 CA4th 966, 1018 (alternative proposed in comments would not comply with statutory requirements for regional greenhouse gas reduction plan)
 Center for Biological Diversity v Department of Fish & Wildlife (2015) 234 CA4th 214, 255 (alternative of discontinuing hatchery production and fish stocking activities was infeasible due to conflict with Department's statutory mandate)
 City of Maywood v Los Angeles Unified Sch. Dist. (2012) 208 CA4th 362, 417 (school district reasonably determined that reduced school size alternative was infeasible because of conflict with state school siting guidelines)
Table 5.2-1. Local Alternatives and Reasons for Elimination from Consideration.

Local Alternative Reasons for Infeasibility
Local Alternative 1: Local
WWTP with Effluent Storage
and Land Application
 Does not comply with State and Regional Water Board policies supporting regionalization of wastewater services. Likely to receive less favorable consideration, or outright denial, especially if regionalization has similar or better overall feasibility. (Regional Board 2020)
 Land application would require extensive permitting from the Regional Board.  Due to the topography, geology and hydrology of the Paradise area, finding a suitable site for both treatment and disposal would be difficult. Acreage requirements for land application given local rocky soil conditions would be high and likely unavailable.  Finding 150 acres of land to purchase for effluent storage was found to be infeasible due to the high risk of increased impacts to biological resources, cultural resources, and tribal resources. (HDR 2020)
 Would take approximately 150 acres of land out of agricultural use including possible prime farmland and properties under Williamson Act contracts.  Negotiating agreements with farmers to use treated effluent or irrigation of pastureland would be complex and finding willing participants might be difficult.  Available land for effluent storage and land application would likely have environmentally sensitive plants and resources that would be destroyed or heavily impacted beyond mitigation by installation of the effluent storage and land application facilities: vernal pools, meadowfoam, and other rare plants.  Extensive truck traffic would be involved with hauling soil off-site during construction of the effluent storage reservoir and would impact local access and circulation.  Construction of a local WWTP would be a lengthy process and would involve significant noise, dust, and visual impacts on neighbors in the area. Permanent visual, noise and odor impacts would also occur during operations.  If facility is designed for a maximum predicted rate, even though flows will ramp up gradually, and may never reach the maximum rate, this would result in a WWTP that is oversized, at least for much of its useful life. Building a larger WWTP and initially operating at reduced capacity is technically challenging, wasteful of energy, and unnecessarily costly.
 Operation and maintenance for a full scale WWTP would have to be supported by small initial ratepayer base.
 High long-term monitoring costs and resources required to oversee adjacent farm uses for compliance with permit conditions associated with this alternative.  Alternatively, if a smaller facility is initially constructed, expansion of the WWTP to 630
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 451
Local Alternative Reasons for Infeasibility
accommodate larger future flows would be costly. Further, treatment processes may not be easily scalable without substantial redesign and reconstruction of WWTP elements.
 Extensive, ongoing monitoring required for both the local WWTP and the land application system, including monitoring wells, farmers’ proper handling of runoff, and the potential for continued impacts on groundwater.

Local Alternative 2: Local
WWTP with Surface Water
Discharge
 May not comply with State and Regional Water Board policies supporting regionalization of wastewater services. Likely to receive less favorable consideration, or outright denial,
 especially if regionalization has similar or better overall feasibility. (Regional Board 2020)
 Siting a local wastewater facility within residential and business areas is more complex than other local alternatives.
 The lack of year-round water flow in local streams makes a surface water discharge very difficult to permit. If permitted, there is a high potential for a very onerous discharge permit, including extensive, on-going monitoring requirements.  Initiating a new surface water discharge is contrary to the goal of the National Pollutant Discharge Elimination System program and may not be supported by the Regional Water Board (Regional Board 2020).
 Construction of a local WWTP would be a lengthy process and would involve significant noise, dust, and visual impacts on neighbors in the area. Permanent visual, noise and odor impacts would also occur during operations.  If facility is designed for a maximum predicted rate, even though flows will ramp up gradually, and may never reach the maximum rate, this would result in a WWTP that is oversized, at least for much of its useful life. Building a larger WWTP and initially operating at reduced capacity is technically challenging, wasteful of energy, and unnecessarily costly.
 Operation and maintenance for a full scale WWTP would have to be supported by small initial ratepayer base.
 Alternatively, if a smaller facility is initially constructed, expansion of the WWTP to accommodate larger, future flows would be costly. Further, treatment processes may not be easily scalable without substantial redesign and reconstruction of WWTP elements.

Local Alternative 3: Local
WWTP with Water Recycling
within the Town for Local
Reuse and Wildfire Defense
 May not comply with State and Regional Water Board policies supporting regionalization of wastewater services. Likely to receive less favorable consideration, or outright denial,
 especially if regionalization has similar or better overall feasibility. (Regional Board 2020)
 Siting a local wastewater facility within residential and business areas is more complex than other alternatives
 Lack of sufficient potential recycled water users in the area to match the quantity of wastewater produced.
 A large effluent storage facility likely needed for winter flows, similar to Local Alternative 1. Finding 150 acres of land to purchase for effluent storage was found to be infeasible. This alternative would also take approximately 150 acres of land out of agricultural use.
 Available land for effluent storage would likely have environmentally sensitive plants and resources that would be destroyed or heavily impacted beyond mitigation by installation of the effluent storage facilities: vernal pools, meadowfoam, and other rare plants (HDR 2020)
 Construction of a local WWTP would be a lengthy process and would involve 631
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 452
Local Alternative Reasons for Infeasibility
significant noise, dust, and visual impacts on neighbors in the area. Permanent visual, noise and odor impacts would also occur during operations.  The addition of an auxiliary water supply system for fire suppression would be a separate pipeline system that would have to be constructed within the Town and would greatly increase construction and operations costs that would be supported by small initial ratepayer base.
 If facility is designed for a maximum predicted rate, even though flows will ramp up gradually, and may never reach the maximum rate, this would result in a WWTP that is oversized, at least for much of its useful life. Building a larger WWTP and initially operating at reduced capacity is technically challenging, wasteful of energy, and unnecessarily costly.
 Operation and maintenance for a full scale WWTP would have to be supported by small initial ratepayer base.
 Alternatively, if a smaller facility is initially constructed, expansion of the WWTP to accommodate larger, future flows would be costly. Further, treatment processes may not be easily scalable without substantial redesign and reconstruction of WWTP elements.
 Extensive, ongoing monitoring required for the local WWTP and recycling facilities.

Local Alternative 4: Local
WWTP with discharge to the
Miocene Canal
 May not comply with State and Regional Water Board policies supporting regionalization of wastewater services. Likely to receive less favorable consideration, or outright denial,
 especially if regionalization has similar or better overall feasibility. (Regional Board 2020)
 Siting a local wastewater facility within residential and business areas is more complex than other alternatives.
 Current agriculture users along the Miocene Canal may not want treated effluent to be mixed with Lake Oroville water supplied to the canal.
 Because of the potential for direct use of treated wastewater by users along the Miocene Canal, there would likely be additional treatment processes required, resulting in more land required for treatment facilities and a more complex plant to operate.
 Very stringent discharge requirements in a permit issued by the Regional Board, including extensive, on-going monitoring requirements.
 The requirement to have several state agencies approve the discharge of advanced treated wastewater with downstream municipal drinking water uses would be more complex than other alternatives.
 Pentz Road, where the pipeline to the local WWTP would be built, is narrow and construction truck traffic would impact local residents and businesses.  Construction of a local WWTP would be a lengthy process and would involve significant noise, dust, and visual impacts on neighbors in the area. Permanent visual, noise and odor impacts would also occur during operations.  Potential for impacts on habitat along the Miocene Canal, or in Kunkle Reservoir if discharge were to occur there.
 Little or no storage would be available in the event of a WWTP upset and no alternative discharge location would be available.
 If facility is designed for a maximum predicted rate, even though flows will ramp up gradually, and may never reach the maximum rate, this would result in a WWTP that is oversized, at least for much of its useful life. Building a larger WWTP and initially operating at reduced capacity is technically challenging, wasteful of energy, and unnecessarily costly.
 Operation and maintenance for a full scale WWTP would have to be supported by 632
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 453
Local Alternative Reasons for Infeasibility
small initial ratepayer base.
 Alternatively, if a smaller facility is initially constructed, expansion of the WWTP to accommodate larger, future flows would be costly. Further, treatment processes may not be easily scalable without substantial redesign and reconstruction of WWTP elements.

Source: HDR 2020

5.2.2 Neal Road Export Pipeline System Alignment Alternative The Neal Road Alternative would place the pipeline along Neal Road rather than Skyway. This alternative would start at the intersection of Skyway and Neal Road and continue southwest along Neal Road. The Neal Road Alternative would follow Neal Road as it turns west and make a perpendicular trenchless crossing at SR 99. It would continue along Neal Road until it reaches the Oroville-Chico Highway, where it would turn northwest. The Neal Road Alternative would continue along the northern edge of the Oroville-Chico Highway and makes a trenchless crossing of Butte Creek. This alternative would then turn north on Midway and continue along Midway until it reaches Hegan Lane. At Hegan Lane, the Neal Road Alternative would turn southwest and continue along the same route as the Proposed Project to the Chico WPCP.

This alternative was eliminated based on criterion 2 (infeasibility) and criterion 3 (inability to avoid significant environmental impacts), as described in further detail below.  The Neal Road ROW is narrow in several locations and constructability would be difficult.

Because Neal Road is very narrow, homes are located very close to the road and there is little available ROW (criterion 2).
 The Neal Road alignment would be longer and more expensive. Specifically, the cost estimate for the Neal Road Alternative would be substantially more expensive than the Proposed Project during construction because the length of the open cut construction for the Neal Road Route is 22 percent longer. The Neal Road Alternative would also require an additional 19,000 feet of force main, which would incur additional pumping head loss and therefore would incur higher power costs during operations and maintenance (criterion 2).  Both the Proposed Project and the Neal Road Alternative would have similar constraints associated with biological resources, seasonal wetlands vernal pools, and sensitive and protected species documented in each location Moreover, each route would require the same types of permitting and regulatory consultation for these resources in Phase 2 of this planning process (criterion 3).
 Near SR 99 both the Neal Road Alternative and the Proposed Project would cross an agricultural ditch and Butte Creek. Because the pipeline installation across these water bodies would be done using trenchless methods, impacts on the water quality at these water bodies would be similar and would be an issue only if those activities resulted in a frac-out (criterion 3).

Although this alternative alignment would meet the Proposed Project objectives, it would not reduce the potential for significant effects on biological resources, and, since the alignment would be 22-percent longer, the construction period would be extended and would exacerbate impacts on other resources, 633
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 454
such as air quality and greenhouse gases. Only those locations that would avoid or substantially lessen any of the significant effects of the project need be considered for inclusion in the EIR (CEQA Guidelines Section 15126.6 [b]). Therefore, the Neal Road alternative was eliminated from consideration based on criterion 2 and criterion 3, as described above.

5.2.3 Butte Creek Alignment Spur within the Skyway Export Pipeline Alignment Alternative The Butte Creek Alternative would follow much of the proposed Skyway alignment; however, it would provide an alternate route between Skyway and Midway, crossing Butte Creek and SR 99 south of the proposed export pipeline alignment. The Butte Creek Alternative would turn southwest from Skyway and cross the Virgin Valley Unit of the Butte Creek Canyon Ecological Reserve before crossing Butte Creek and SR 99 with trenchless HDD. The pipeline would continue west along Marybill Ranch Road and would then turn north on Midway and rejoin the proposed export pipeline alignment along Midway to Hegan Lane.

This alternative was eliminated based on criterion 2 (infeasibility) and criterion 3 (inability to avoid significant environmental impacts) because it would require extensive open-cut trenching across the ecological reserve, which is both considered infeasible and highly impactful to a sensitive and protected area of habitat. Further, similar to the Neal Road alignment alternative, this alignment would also be longer and more expensive. Therefore, the Butte Creek alignment spur alternative was eliminated from consideration based on criteria 2 and 3, as described in Section 5.2.1.

5.3 Alternatives Evaluated in the EIR
This section describes the alternatives to the Proposed Project that were selected and analyzed according to CEQA Guidelines Section 15126.6(a) as part of this PEIR. The analyzed alternatives, including the No Project Alternative, represent a reasonable range of alternatives to the Proposed Project that would feasibly attain most of the Proposed Project’s basic objectives, and that would avoid or lessen the significant adverse environmental effects of the Proposed Project. The Proposed Project’s objectives are discussed in detail in Chapter 2 and listed in 5.1.2 Project Objectives and Goals. Significant Proposed Project impacts are summarized in Section 4.3 and are described in detail under the corresponding resource in Chapter 3 Environmental Impact Analysis.

The following four alternatives were selected for comparative analysis in this PEIR:
 No Project Alternative: The No Project Alternative is required by CEQA and consists of the circumstances under which the Proposed Project does not proceed.  Entler Avenue Hybrid Alternative: Proposed Project with alternative pipeline alignment for crossing SR 99.
 Crouch Avenue Alternative: Proposed Project with alternative pipeline alignment for crossing Little Chico Creek.
 Entler Avenue Hybrid and Crouch Avenue Alternative: Proposed Project with alternative pipeline alignment for crossing SR 99 and alternative pipeline alignment for crossing Little Chico Creek.
634
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 455
Each alternative is described below. Consistent with the Proposed Project, the transition to the Core Collection System for the Entler Avenue Hybrid Alternative, Crouch Avenue Alternative, and the Entler Avenue Hybrid and Crouch Avenue Alternative for existing structures would be at a property owner’s discretion, although the City is pursuing grants to incentivize sewer connection within the Core Collection System area; new construction would be required to connect to the system. Remediation and disposition of existing on-site septic tanks and leach fields would be the responsibility of the individual parcel owner, and these actions are not considered in this PEIR as part of the Proposed Project or alternatives, but a parcel’s septic system would need to be remediated (abandoned or removed) as a condition of connecting to the Proposed Project and alternatives. The following discusses whether the alternative would avoid or lessen identified Project impacts, whether new significant impacts may occur, and the ability of the alternative to meet Proposed Project objectives.

5.3.1 No Project Alternative
The No Project alternative represents conditions in the study area in the absence of approval of the proposed project (CEQA Guidelines Section 15126.6(e)(1)). The No Project Alternative must discuss current conditions as well as reasonably foreseeable future conditions expected to occur if the project were not approved (CEQA Guidelines Section 15126.6(e)(2)). However, the analysis of the No Project alternative should not be confused with comparison of the proposed project to Existing Conditions (the baseline for determining the project’s environmental impacts) (CEQA Guidelines Section 15126.6(e)(1)). The purpose of describing and analyzing a No Project alternative is to allow decision makers to compare the impacts of approving the proposed project with the impacts of not approving the proposed project. The analysis of the No Project alternative, as with the analysis of other alternatives, is usually a comparative or qualitative assessment (CEQA Guidelines Section 15126.6(d)(e))
Under the No Project Alternative, the Town would not construct a Core Collection System, an Export Pipeline System, or an Extended Collection System. The Town would continue to rely on private, individual septic systems for wastewater management. The Town’s objectives and goals for the Proposed Project would not be met and the risk of water contamination; public health risks; burdens of on-site wastewater management for business; and restrictions on essential community services, multifamily, and affordable housing would continue. In addition, regrowth in the community would continue to be limited by a requirement for separate septic systems. Multi-family housing construction in the core area would be restricted in size and numbers and would likely provide no additional multi-family housing for the community. Business growth would be limited to septic systems consistent with individual lot sizes, limiting growth for larger businesses and those that have higher capacity needs for sewage management (e.g., restaurants).

5.3.2 Entler Avenue Hybrid Alternative
The Entler Avenue Hybrid Alternative would include the same Core Collection System within the Town and the same Export Pipeline System along Skyway but would provide an alternative route between Skyway and Entler Avenue (see Figure 5.3-1). This alternative would cross Butte Creek with trenchless HDD at the same location as the Proposed Project but would cross SR 99 north of the Proposed Project alignment, bisecting the California Highway Patrol property and another private parcel. Similar to the Proposed Project, the Entler Avenue Hybrid Alternative would cross SR 99 with a trenchless 635
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 456
crossing aligned with Norfield Avenue. The pipeline would then rejoin the Proposed Project alignment along Entler Avenue. According to the Butte County General Plan Land Use Designations Map, land uses near the Entler Avenue Hybrid Alternative include Very Low Density Residential, Public and Industrial (Butte County 2012). The total length of this alternative is approximately 2,622 feet. All other components of the Proposed Project would remain the same as defined in Chapter 2, Project Description. Short- and possibly long-term easements would be required from California Highway Patrol and an adjacent property owner.

The Entler Avenue Hybrid Alternative offers an alternative alignment to a portion of the Export Pipeline System crossing SR 99. This alternative is feasible, meets the Proposed Project objectives, and could result in similar or fewer environmental impacts as compared to the Proposed Project; therefore, this alternative was carried forward for detailed environmental review in this PEIR.

5.3.3 Crouch Avenue Alternative
The Crouch Avenue Alternative would include the same Core Collection System within the Town and the same Export Pipeline System along Skyway but would provide an alternative route for the pipeline to cross Little Chico Creek (see Figure 5.3-2). After the Proposed Project alignment would cross Comanche Creek and turn north along Crouch Avenue, the Crouch Avenue Alternative would continue along Crouch Avenue to Chico River Road, crossing Little Chico Creek along the way. Little Chico Creek would be crossed using trenchless technology via HDD methods. The Crouch Avenue Alternative would then turn west to rejoin the Proposed Project alignment as it travels west along Chico River Road to the Chico WPCP. The area surrounding the Crouch Avenue Alternative is designated as Agriculture (Butte County 2012). The total length of this alternative is approximately 7,353 feet. All other components of the Proposed Project would remain the same as defined in Chapter 2, Project Description. The Crouch Avenue Alternative offers an alternative alignment to a portion of the Export Pipeline System crossing Little Chico Creek. This alternative is feasible, meets the Proposed Project objectives, and could result in similar or fewer environmental impacts as compared to the Proposed Project; therefore, this alternative was carried forward for detailed environmental review in this PEIR.

5.3.4 Entler Avenue Hybrid and Crouch Avenue Alternative The Entler Avenue Hybrid and Crouch Avenue Alternative would include the same Core Collection System within Paradise and the same Export Pipeline System along Skyway but would provide alternative routes for the pipeline to cross SR 99 and Little Chico Creek. This alternative comprises a combination of the Entler Avenue Hybrid and Crouch Avenue alternatives discussed in the previous two sections.

Consistent with the Entler Avenue Hybrid alternative, this alternative would cross Butte Creek with trenchless HDD at the same location as the Proposed Project but would cross SR 99 north of the Proposed Project alignment, bisecting the California Highway Patrol property and another private parcel. Similar to the Proposed Project, the Entler Avenue Hybrid Alternative would cross SR 99 with a trenchless crossing aligned with Norfield Avenue. The pipeline would then rejoin the Proposed Project alignment along Entler Avenue. Consistent with the Crouch Avenue alternative, this alternative would 636
Paradise Sewer Project | Final Program Environmental Impact hdrinc.comFinal Program Environmental Impact Report 457 Alternatives
Figure 5.3-1. Entler Avenue Hybrid Alternative
637
Paradise Sewer Project | Final Program Environmental Impact hdrinc.comFinal Program Environmental Impact Report 458 Alternatives
Figure 5.3-2. Crouch Avenue Alternative
638
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 459
leave the Proposed Project alignment at Chico Avenue to continue along Crouch Avenue, crossing Little Chico Creek using trenchless technology along the way. This alternative would then turn west to rejoin the Proposed Project alignment as it travels west along Chico River Road to the Chico WPCP.

According to the Butte County General Plan Land Use Designations Map, land uses near the Entler Avenue Hybrid Alternative include Very Low Density Residential, Public and Industrial, and Agriculture (Butte County 2012). The total length of this alternative is approximately 9,975 feet. All other components of the Proposed Project would remain the same as defined in Chapter 2 Project Description.

The Entler Avenue Hybrid and Crouch Avenue Alternative offers an alternative alignment to portions of the Export Pipeline System crossing SR 99 and Little Chico Creek. This alternative is feasible, meets the project objectives, and could result in similar or fewer environmental impacts as compared to the Proposed Project; therefore, this alternative has been carried forward for detailed environmental review in this PEIR.

5.4 Methodology and Organization for Evaluating Alternatives This section discusses the methods used for evaluating impacts from implementation of the alternatives during construction, operation, and maintenance. This section also describes how the alternatives impact analysis is organized.

5.4.1 Method for Evaluating Alternatives
Each of the alternatives was evaluated using the same Project area and methodology as described in Chapter 3, Environmental Impact Analysis, for the Proposed Project. The alternatives analysis evaluates each alternative’s impacts on the various resources during construction, operation, and maintenance activities. A resource-specific study area is defined for each respective resource topic in Chapter 3 and carried forward in this alternatives analysis. Methods and data sources that analysts used to identify impacts on each resource are also consistent with those discussed in Chapter 3.

Accordingly, the methods for analysis vary by resource, and rely on both qualitative and quantitative techniques. For some resource topics, fieldwork was conducted to collect data to support the impact analysis. Thresholds of significance for each resource in the alternatives analysis were also developed consistent with CEQA Guidelines Appendix G to determine the significance of potential impacts. Where feasible, mitigation measures are proposed to minimize significant adverse impacts from the alternatives.

5.4.2 Organization for Alternatives Impact Analysis
This section is organized first by resource, then by alternative: No Project Alternative, Entler Avenue Hybrid Alternative, Crouch Avenue Alternative, and the Entler Avenue Hybrid and Crouch Avenue Alternative. Under each alternative, each resource topic area follows the same order as the Proposed Project analysis in Chapter 3, Environmental Impact Analysis. As applicable, construction impacts were considered and are discussed based on the three Project components: (1) construction of the Core Collection System; (2) construction of the Export Pipeline System; and (3) construction of the Extended Collection System. When impacts are found to be significant, mitigation measures are proposed, and 639
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 460
post-mitigation significance conclusions are provided. Impacts and mitigation measures follow the same naming and numbering structure as in Chapter 3.

5.5 Alternatives Impact Analysis

5.5.1 Agriculture

5.5.1.1 No Project Alternative
Impact AG-1: 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 nonagricultural use (No Impact) Under the No Project Alternative, existing conditions would remain the same and no ground disturbance would occur. Therefore, the No Project Alternative would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural use, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because neither the No Project Alternative nor the Proposed Project would convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural use.

Mitigation. No mitigation required.

Impact AG-2: Conflict with existing zoning for agricultural use, or a Williamson Act contract (No Impact)
Under the No Project Alternative, existing conditions would remain the same. Therefore, the No Project Alternative would not conflict with existing zoning for agricultural use or a Williamson Act contract, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because neither the No Project Alternative nor the Proposed Project would conflict with agricultural zonings or a Williamson Act contract.

Mitigation. No mitigation required.

Impact AG-3: 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)
Under the No Project Alternative, existing conditions would remain the same. Therefore, the No Project Alternative would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because neither the No Project Alternative nor the Proposed Project would conflict with such zonings. 640
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 461
Mitigation. No mitigation required.

Impact AG-4: Result in the loss of forest land or conversion of forest land to non-forest use (No Impact)
Under the No Project Alternative, existing conditions would remain the same and no ground disturbance would occur. Therefore, the No Project Alternative would not result in the loss of forest land or conversion of forest land to non-forest use, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because neither the No Project Alternative nor the Proposed Project would impact forest land.

Mitigation. No mitigation required.

Impact AG-5: Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to nonagricultural use or conversion of forest land to non-forest use (No Impact)
Under the No Project Alternative, existing conditions would remain the same and no ground disturbance would occur. Therefore, the No Project Alternative would not result in conversion of Farmland to nonagricultural use or conversion of forest land to non-forest use, resulting in no impact.

The level of impact would be less than that for the Proposed Project because the Proposed Project would result in a less-than-significant impact on this criterion.

Mitigation. No mitigation required.

5.5.1.2 Entler Avenue Hybrid Alternative
Impact AG-1: 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 nonagricultural use (No Impact) Consistent with the analysis for the Proposed Project, the Entler Avenue Hybrid Alternative would be located primarily within the Butte County ROW. When the Entler Avenue Hybrid Alternative leaves UPRR’s ROW, it would traverse private parcels before rejoining the public ROW at the Entler Avenue and Norfield Avenue intersection. The Entler Avenue Hybrid Alternative would traverse parcels designated as Urban and Built-Up Land (DOC 2021b). The remaining Entler Avenue Hybrid Alternative alignment would be located in the Butte County public ROW. Therefore, construction, operation, and maintenance of the Entler Avenue Hybrid Alternative would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural use, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because neither the Entler Avenue Hybrid Alternative nor the Proposed Project Entler Avenue alignment would convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural use and no impact would occur on this criterion.

Mitigation. No mitigation required.
641
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 462
Impact AG-2: Conflict with existing zoning for agricultural use, or a Williamson Act contract (No Impact)
Consistent with the analysis for the Proposed Project, the Entler Avenue Hybrid Alternative would be located primarily within the Butte County public ROW. When the Entler Avenue Hybrid Alternative leaves UPRR’s ROW, it would traverse private parcels before rejoining the public ROW at the Entler Avenue and Norfield Avenue intersection. The Entler Avenue Hybrid Alternative would traverse parcels with a City of Chico zoning of CR – Regional Commercial (City of Chico 2020b). The Entler Avenue Hybrid Alternative would traverse parcels that are not enrolled in the Williamson Act (Butte County 2021b). The remaining Entler Avenue Hybrid Alternative alignment would be located within the Butte County public ROW. Therefore, construction, operation, and maintenance of the Entler Avenue Hybrid Alternative would not conflict with existing zoning for agricultural use, or a Williamson Act contract, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because neither the Entler Avenue Hybrid Alternative nor the Proposed Project Entler Avenue alignment would conflict with existing zoning for agricultural use, or a Williamson Act contract and no impact would occur on this criterion.

Mitigation. No mitigation required.

Impact AG-3: 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)
No lands zoned forest land, timberland, or timberland zoned Timberland Production occur within the Entler Avenue Hybrid Alternative area. Therefore, construction, operation, and maintenance of the Entler Avenue Hybrid Alternative would not conflict with existing zoning for forest land, timberland, or timberland zoned Timberland Production, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because neither the Entler Avenue Hybrid Alternative nor the Proposed Project Entler Avenue alignment would conflict with existing zoning for forest land, timberland, or timberland zoned Timberland Production and no impact would occur on this criterion.

Mitigation. No mitigation required.

Impact AG-4: Result in the loss of forest land or conversion of forest land to non-forest use (No Impact)
A review of aerial imagery and street view indicates no forest or timber resources occur within the Entler Avenue Hybrid Alternative area (Google Earth 2022). Therefore, construction, operation, and maintenance of the Entler Avenue Hybrid Alternative would not result in the loss of forest land nor conversion of forest land to non-forest use, resulting in no impact. 642
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 463
The level of impact would be the same as that for the Proposed Project because neither the Entler Avenue Hybrid Alternative nor the Proposed Project Entler Avenue alignment would result in loss or conversion of forest land and no impact would occur on this criterion.

Mitigation. No mitigation required.

The temporary effects at adjacent farmlands would cease once construction is complete. Therefore, impacts on farmlands during construction of the Entler Avenue Hybrid Alternative would be less than significant. Operation and maintenance activities would mostly occur in previously disturbed areas (within paved roads). Operation and maintenance activities, as described in Section 2.8, would not generate excessive dust or substantially increase stormwater runoff in the vicinity of farmlands due to the infrequency of these activities. Therefore, no impacts on farmlands would occur.

The level of impact would be the same as that for the Proposed Project because both the Entler Avenue Hybrid Alternative and the Proposed Project Entler Avenue alignment would result in less than significant impacts on this criterion.

Mitigation. No mitigation required.

5.5.1.3 Crouch Avenue Alternative
Impact AG-1: 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 nonagricultural use (No Impact) The Crouch Avenue Alternative would be located entirely within the Butte County public ROW.

Therefore, construction, operation, and maintenance of the Crouch Avenue Alternative would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural use, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because neither the Crouch Avenue Alternative nor the Proposed Project Entler Avenue alignment would convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural use and no impact would occur on this criterion.

Mitigation. No mitigation required.
643
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 464
Impact AG-2: Conflict with existing zoning for agricultural use, or a Williamson Act contract (No Impact)
The Crouch Avenue Alternative would be located entirely within the Butte County public ROW.

Therefore, construction, operation, and maintenance of the Crouch Avenue Alternative would not conflict with existing zoning for agricultural use, or a Williamson Act contract, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because neither the Crouch Avenue Alternative nor the Proposed Project Entler Avenue alignment would conflict with existing zoning for agricultural use, or a Williamson Act contract and no impact would occur on this criterion.

Mitigation. No mitigation required.

Impact AG-3: 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)
There are no lands zoned forest land, timberland, or timberland zoned Timberland Production within the Crouch Avenue Alternative area. Therefore, construction, operation, and maintenance of the Crouch Avenue Alternative would not conflict with existing zoning for forest land, timberland, or timberland zoned Timberland Production, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because neither the Crouch Avenue Alternative nor the Proposed Project Entler Avenue alignment would conflict with existing zoning for forest land, timberland, or timberland zoned Timberland Production and no impact would occur on this criterion.

Mitigation. No mitigation required.

Impact AG-4: Result in the loss of forest land or conversion of forest land to non-forest use (No Impact)
A review of aerial imagery and street view indicates that there are no forest or timber resources within the Crouch Avenue Alternative area (Google Earth 2022). Therefore, construction, operation, and maintenance of the Crouch Avenue Alternative would not result in the loss of forest land or conversion of forest land to non-forest use, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because neither the Crouch Avenue Alternative nor the Proposed Project Entler Avenue alignment would result in loss or conversion of forest land and no impact would occur on this criterion.

Mitigation. No mitigation required.
644
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 465
Impact AG-5: Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to nonagricultural use or conversion of forest land to non-forest use (Less than Significant Impact)
As noted under Impact AG-4, there are no forest resources within the Crouch Avenue Alternative area.

While the Crouch Avenue Alternative would be located entirely within the Butte County public ROW, it would be adjacent to farmlands (Google Earth 2022). Construction activities associated with this alternative have the potential to result in temporary effects involving dust and stormwater runoff at adjacent farmlands. The Crouch Avenue Alternative will be required to implement best practices during construction to control dust emissions and reduce stormwater runoff. The temporary effects at adjacent farmlands would cease once construction is complete. Therefore, impacts on farmlands during construction of the Crouch Avenue Alternative would be less than significant. Operation and maintenance activities, as described in Section 2.8, associated with this alternative would not generate excessive dust or substantially increase stormwater runoff in the vicinity of farmlands due to the infrequency of these activities and no impacts on farmlands would occur.

The level of impact would be the same as that for the Proposed Project because both the Crouch Avenue Alternative and the Proposed Project Entler Avenue alignment would result in less than significant impacts on this criterion.

Mitigation. No mitigation required.

5.5.1.4 Entler Avenue Hybrid and Crouch Avenue Alternative Impact AG-1: 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 nonagricultural use (Less than Significant Impact)
Consistent with the analysis for the Proposed Project, the Entler Avenue Hybrid and Crouch Avenue Alternative would be located primarily within the Butte County public ROW. When the Entler Avenue Hybrid and Crouch Avenue Alternative leaves UPRR’s ROW, it would traverse private parcels before rejoining the public ROW at the Entler Avenue and Norfield Avenue intersection. The Entler Avenue Hybrid and Crouch Avenue Alternative would traverse parcels designated as Urban and Built-Up Land (DOC 2021b). The remaining Entler Avenue Hybrid and Crouch Avenue Alternative alignment would remain within the Butte County public ROW. Therefore, construction, operation, and maintenance of the Entler Avenue Hybrid and Crouch Avenue Alternative would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural use, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because neither the Entler Avenue Hybrid and Crouch Avenue Alternative nor the Proposed Project Entler alignment would convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural use and no impact would occur on this criterion.

Mitigation. No mitigation required.
645
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 466
Impact AG-2: Conflict with existing zoning for agricultural use, or a Williamson Act contract (No Impact)
Consistent with the analysis for the Proposed Project, the Entler Avenue Hybrid and Crouch Avenue Alternative would be located primarily within the Butte County public ROW. When the Entler Avenue Hybrid and Crouch Avenue Alternative leaves UPRR’s ROW, it would traverse private parcels before rejoining the public ROW at the Entler Avenue and Norfield Avenue intersection. The Entler Avenue Hybrid and Crouch Avenue Alternative would traverse parcels with a City of Chico zoning of CR – Regional Commercial (City of Chico 2020b). The Entler Avenue Hybrid and Crouch Avenue Alternative would traverse parcels that are not enrolled in the Williamson Act (Butte County 2021b). The remaining Entler Avenue Hybrid and Crouch Avenue Alternative alignment would remain within the public ROW.

Therefore, construction, operation, and maintenance of the Entler Avenue Hybrid and Crouch Avenue Alternative would not conflict with existing zoning for agricultural use, or a Williamson Act contract, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because neither the Entler Avenue Hybrid and Crouch Avenue Alternative nor the Proposed Project Entler alignment would conflict with existing zoning for agricultural use, or a Williamson Act contract and no impact would occur on this criterion.

Mitigation. No mitigation required.

Impact AG-3: 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)
There are no lands zoned forest land, timberland, or timberland zoned Timberland Production within the Entler Avenue Hybrid and Crouch Avenue Alternative area. Therefore, construction, operation, and maintenance of the Entler Avenue Hybrid and Crouch Avenue Alternative would not conflict with existing zoning for forest land, timberland, or timberland zoned Timberland Production, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because neither the Entler Avenue Hybrid and Crouch Avenue Alternative nor the Proposed Project Entler alignment would conflict with existing zoning for forest land, timberland, or timberland zoned Timberland Production and no impact would occur on this criterion.

Mitigation. No mitigation required.

Impact AG-4: Result in the loss of forest land or conversion of forest land to non-forest use (No Impact)
A review of aerial imagery and street view indicates that there are no forest or timber resources within the Entler Avenue Hybrid and Crouch Avenue Alternative area (Google Earth 2022). Therefore, construction, operation, and maintenance of the Entler Avenue Hybrid and Crouch Avenue Alternative 646
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 467
would not result in the loss of forest land or conversion of forest land to non-forest use, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because neither the Entler Avenue Hybrid and Crouch Avenue Alternative nor the Proposed Project Entler alignment would result in loss or conversion of forest land and no impact would occur on this criterion.

Mitigation. No mitigation required.

Impact AG-5: Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to nonagricultural use or conversion of forest land to non-forest use (Less than Significant Impact)
As noted under Impact AG-4, there are no forest resources within the Entler Avenue Hybrid and Crouch Avenue Alternative area. While the Entler Avenue Hybrid and Crouch Avenue Alternative would be located primarily within the Butte County public ROW, it would be adjacent to farmlands (Google Earth 2022). Construction activities associated with this alternative have the potential to result in temporary, effects involving dust and stormwater runoff at adjacent farmlands. The Entler Avenue Hybrid and Crouch Avenue Alternative will be required to implement best practices during construction to control dust emissions and reduce stormwater runoff. The temporary effects at adjacent farmlands would cease once construction is complete. Therefore, impacts on farmlands during construction of the Entler Avenue Hybrid and Crouch Avenue Alternative would be less than significant. Operation and maintenance activities, as described in Section 2.8, associated with this alternative would not generate excessive dust or substantially increase stormwater runoff in the vicinity of farmlands due to the infrequency of these activities and no impacts on farmlands would occur.

The level of impact would be the same as that for the Proposed Project because both the Entler Avenue Hybrid and Crouch Avenue Alternative and the Proposed Project Entler alignment would result in less than significant impacts on this criterion.

Mitigation. No mitigation required.

5.5.1.5 Alternatives Impact Summary
Table 5.5-1 summarizes the agriculture and forestry resources impacts of the alternatives and a comparison to the Proposed Project.

Table 5.5-1. Alternatives Impacts Summary for Agriculture and Forestry Resources Impact Proposed
Project
No Project
Alternative
Entler
Avenue
Hybrid
Alternative
Crouch
Avenue
Alternative
Entler Avenue
Hybrid and
Crouch
Avenue
Alternative
Impact AG-1: Convert Prime Farmland,
Unique Farmland, or Farmland of
Statewide Importance (Farmland), as
shown on the maps prepared pursuant to
the Farmland Mapping and Monitoring
NI NI (=) NI (=) NI (=) NI (=)
647
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 468
Impact Proposed
Project
No Project
Alternative
Entler
Avenue
Hybrid
Alternative
Crouch
Avenue
Alternative
Entler Avenue
Hybrid and
Crouch
Avenue
Alternative
Program of the California Resources
Agency, to non-agricultural use
Impact AG-2: Conflict with existing zoning
for agricultural use, or a Williamson Act
contract
NI NI (=) NI (=) NI (=) NI (=)
Impact AG-3: Conflict with existing zoning
for, or cause rezoning of, forest land (as
defined in PRC Section 12220(g)),
timberland (as defined by PRC
Section 4526), or timberland zoned
Timberland Production (as defined by
California Government Code
Section 51104(g))
NI NI (=) NI (=) NI (=) NI (=)
Impact AG-4: Result in the loss of forest
land or conversion of forest land to nonforest use
NI NI (=) NI (=) NI (=) NI (=)
Impact AG-5: 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 nonforest use
LTS NI (-) LTS (=) LTS (=) LTS (=)
Notes: LTS = Less than Significant Impact, NI = No Impact, N/A = Not Applicable, SU = Significant and Unavoidable Impact, S/M = Significant Impact but Mitigable to a Less than Significant Level, (+) indicates a greater level of impacts compared to the Proposed Project; (-) indicates less impacts compared the Proposed Project; (=) indicates the same level of impacts as the Proposed Project

5.5.2 Air Quality

5.5.2.1 No Project Alternative
Impact AIR-1: Conflict with or obstruct implementation of an applicable air quality plan (No Impact)
Under the No Project Alternative, existing conditions would remain the same, and no population or employment growth would be induced. Therefore, the No Project Alternative would not conflict with or obstruct implementation of the applicable air quality attainment plan, resulting in no impact. The level of impact would be the same as that for the Proposed Project because neither the No Project Alternative nor the Proposed Project would conflict with or obstruct implementation of an applicable air quality plan.

Mitigation. No mitigation required.
648
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 469
Impact AIR-2: 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 (No Impact)
Under the No Project Alternative, existing conditions would remain the same. No construction would occur; therefore, no criteria air pollutant emissions would be generated. The No Project Alternative would not 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.

Therefore, no impact would occur. The level of impact would be less than that for the Proposed Project because the No Project Alternative would not result in a cumulatively considerable net increase of criteria air pollutants, while the Proposed Project would result in less-than-significant impacts on this criterion.

Mitigation. No mitigation required.

Impact AIR-3: Expose sensitive receptors to substantial pollutant concentrations (No Impact) Under the No Project Alternative, existing conditions would remain the same. No construction would occur; therefore, no TAC emissions would be generated. The No Project Alternative would not expose sensitive receptors to substantial pollutant concentrations. Therefore, no impact would occur. The level of impact would be less than that for the Proposed Project because the No Project Alternative would not expose sensitive receptors to substantial pollutant concentrations, while the Proposed Project would result in less-than-significant impacts on this criterion.

Mitigation. No mitigation required.

Impact AIR-4: Result in other emissions, such as those leading to odors, adversely affecting a substantial number of people (Less than Significant Impact) Under the No Project Alternative, the wastewater system in Paradise would continue to consist of individual, privately owned septic tanks and leach fields with subsurface disposal systems. Septic systems, by their nature, can emit odors that are unpleasant. However, no documented odor complaints are associated with the Town’s existing wastewater treatment system. Therefore, odor impacts under the No Project Alternative would be less than significant. The level of impact would be similar to that for the Proposed Project during construction of the Proposed Project. However, when compared to odor impacts during operation and maintenance of the Proposed Project, impacts from the No Project Alternative would be greater than Proposed Project. This is because the Proposed Project would improve odor through the removal of septic systems.

Mitigation. No mitigation required.

5.5.2.2 Entler Avenue Hybrid Alternative
Impact AIR-1: Conflict with or obstruct implementation of an applicable air quality plan (Less than Significant Impact)
The Entler Avenue Hybrid Alternative would result in similar impacts as those discussed for the Proposed Project in Section 3.3, Air Quality. Similar to the Proposed Project, all construction jobs 649
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 470
associated with the Entler Avenue Hybrid Alternative would be temporary and would be primarily filled by the current workforce within Butte County. During construction, the Entler Avenue Hybrid Alternative would not result in employment growth within the county beyond growth projections presented in the 2018 Air Quality Attainment Plan. Operation and maintenance of the Entler Avenue Hybrid Alternative could foster population and economic growth in the study area. However, any population inducement would be a regrowth and repopulation towards pre-fire levels and would be contained within the Town.

About 5-10 permanent employees would serve this alternative during operation and maintenance, which may be re-assigned from existing staff within the Town or may be additional new staff. The minimal increase in employment during operation and maintenance of this alternative would be consistent with the growth projections in the 2018 Air Quality Attainment Plan. Therefore, construction, operation, and maintenance of the Entler Avenue Hybrid Alternative would not conflict with or obstruct implementation of the 2018 Air Quality Attainment Plan, resulting in a less than significant impact.

The level of impact would be the same as that for the Proposed Project because both the Entler Avenue Hybrid Alternative and the Proposed Project Entler Avenue alignment would have a less than significant impact on conflicting with or obstructing implementation of the 2018 Air Quality Attainment Plan.

Mitigation. No mitigation required.

Impact AIR-2: 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 Impact)
Consistent with the analysis for the Proposed Project, the Entler Avenue Hybrid Alternative would generate criteria air pollutant emissions during construction. The Entler Avenue Hybrid Alternative would generate criteria air pollutant emissions similar to those listed in Table 3.3-3, Unmitigated Construction Criteria Air Pollutant Emissions. This alternative would generate ROG, NOX, PM10, and PM2.5 emissions that do not exceed the BCAQMD’s thresholds of significance. Similar to the Proposed Project, the Entler Avenue Hybrid Alternative will implement BCAQMD’s best practice measures to minimize fugitive dust during construction. Therefore, impacts from criteria air pollutant emissions during construction of the Entler Avenue Hybrid Alternative would be less than significant. Criteria air pollutant emissions during operation and maintenance activities of this alternative would be minimal and immeasurable due to the infrequency of these activities, resulting in no impact.

Mitigation. No mitigation required.

Impact AIR-3: Expose sensitive receptors to substantial pollutant concentrations (Less than Significant Impact)
The Entler Avenue Hybrid Alternative would result in similar impacts as those discussed for the Proposed Project in Section 3.3, Air Quality. The closest sensitive receptors to the Entler Avenue Hybrid Alternative are residential dwelling units along Entler Avenue, located approximately 50 feet 650
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 471
away (Google Earth 2022). During construction, the Entler Avenue Hybrid Alternative would generate TAC emissions from the use of diesel equipment that could affect existing sensitive receptors.

However, construction activities would be temporary and short-term. Only portions of this alternative would be disturbed at a given time throughout the construction period, with operation of construction equipment occurring intermittently throughout the course of a day rather than continuously at any one location along Entler Avenue. This would allow for the dispersal of TAC emissions and would avoid continuous construction activity in the portions of the Entler Avenue Hybrid Alternative area closest to existing sensitive receptors. Similar to the Proposed Project, the Entler Avenue Hybrid Alternative will implement BCAQMD best practice measures to reduce diesel particulate matter from construction equipment. Therefore, construction of the Entler Avenue Hybrid Alternative would result in a less-thansignificant impact from TAC emissions. TAC emissions during operation and maintenance activities of this alternative would be minimal and immeasurable due to the infrequency of these activities, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because sensitive receptors are located at the same distance (50 feet) from both the Entler Avenue Hybrid Alternative and the Proposed Project Entler Avenue alignment. Therefore, both the Proposed Project Entler Avenue alignment and the Entler Avenue Hybrid Alternative would result in a less-than-significant impact on this criterion.

Mitigation. No mitigation required.

Impact AIR-4: Result in other emissions, such as those leading to odors, adversely affecting a substantial number of people (Less than Significant Impact) The Entler Avenue Hybrid Alternative would result in similar impacts as those discussed for the Proposed Project in Section 3.3, Air Quality. During construction, the Entler Avenue Hybrid Alternative would result in emissions of odors in the form of diesel exhaust from construction equipment and vehicles. However, these odors would be short-term, limited in extent at any given time, and distributed throughout the Entler Avenue Hybrid Alternative area for the duration of construction. Therefore, construction of the Entler Avenue Hybrid Alternative would result in a less-than-significant impact from odor emissions. Similar to the Proposed Project, the Entler Avenue Hybrid Alternative would provide an overall odor benefit by replacing existing septic tanks that emit unpleasant odors. Odor emissions during operation and maintenance activities of this alternative would be minimal and immeasurable due to the infrequency of these activities, resulting in no impact.

Mitigation. No mitigation required.
651
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 472

5.5.2.3 Crouch Avenue Alternative
Impact AIR-1: Conflict with or obstruct implementation of an applicable air quality plan (Less than Significant Impact)
The Crouch Avenue Alternative would result in similar impacts as those discussed for the Proposed Project in Section 3.3, Air Quality. Similar to the Proposed Project, all construction jobs associated with the Crouch Avenue Alternative would be temporary and would be primarily filled by the current workforce within Butte County. During construction, the Crouch Avenue Alternative would not result in employment growth beyond growth projections presented in the 2018 Air Quality Attainment Plan.

Operation and maintenance of the Crouch Avenue Alternative could foster population and economic growth in the study area. However, any population inducement would be a regrowth and repopulation towards pre-fire levels and would be contained within the Town. About 5-10 permanent employees would serve this alternative during operation and maintenance, which may be re-assigned from existing staff within the Town or may be additional new staff. The minimal increase in employment during operation and maintenance of this alternative would be consistent with the growth projections in the 2018 Air Quality Attainment Plan. Therefore, construction, operation, and maintenance of the Crouch Avenue Alternative would not conflict with or obstruct implementation of the 2018 Air Quality Attainment Plan, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because the Crouch Avenue Alternative and the Proposed Project Entler Avenue alignment would have a less than significant impact on the implementation of the 2018 Air Quality Attainment Plan.

Mitigation. No mitigation required.

Impact AIR-2: 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 Impact)
Consistent with the analysis for the Proposed Project, the Crouch Avenue Alternative would generate criteria air pollutant emissions during construction. The Crouch Avenue Alternative would generate criteria air pollutant emissions similar to those listed in Table 3.3-3, Unmitigated Construction Criteria Air Pollutant Emissions. This alternative would generate ROG, NOX, PM10, and PM2.5 emissions that do not exceed the BCAQMD’s thresholds of significance. Similar to the Proposed Project, the Crouch Avenue Alternative will implement BCAQMD’s best practice measures to minimize fugitive dust during construction. Therefore, impacts from criteria air pollutant emissions during construction of the Crouch Avenue Alternative would be less than significant. Criteria air pollutant emissions during operation and maintenance activities of this alternative would be minimal and immeasurable due to the infrequency of these activities, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because both the Crouch Avenue Alternative and the Proposed Project Entler Avenue alignment would have a less than significant impact on this criterion.

Mitigation. No mitigation required.
652
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 473
Impact AIR-3: Expose sensitive receptors to substantial pollutant concentrations (Less than Significant Impact)
The Crouch Avenue Alternative would result in similar impacts as those discussed for the Proposed Project in Section 3.3, Air Quality. The closest sensitive receptors to the Crouch Avenue Alternative are residential dwelling units along Crouch Avenue, located approximately 60 feet away (Google Earth 2022). During construction, the Crouch Avenue Alternative would generate TAC emissions from the use of diesel equipment that could affect existing sensitive receptors. However, construction activities would be temporary and short-term. Only portions of this alternative would be disturbed at a given time throughout the construction period, with operation of construction equipment occurring intermittently throughout the course of a day rather than continuously at any one location along Crouch Avenue. This would allow for the dispersal of TAC emissions by avoiding continuous construction activity in the portions of the Crouch Avenue Alternative area closest to existing sensitive receptors. Similar to the Proposed Project, the Crouch Avenue Alternative will implement BCAQMD best practice measures to reduce diesel particulate matter from construction equipment. Therefore, construction of the Crouch Avenue Alternative would result in less-than-significant impacts from TAC emissions. TAC emissions during operation and maintenance activities of this alternative would be minimal and immeasurable due to the infrequency of these activities, resulting in no impact.

The level of impact would be the same as that for the Proposed Project, except that, sensitive receptors are farther away under the Crouch Avenue Alternative (60 feet) compared to the Proposed Project (50 feet). Therefore, while both would result in a less-than-significant impact on this criterion, impacts under the Crouch Avenue Alternative would be considered slightly less than the Proposed Project Entler Avenue alignment impacts.

Mitigation. No mitigation required.

Impact AIR-4: Result in other emissions, such as those leading to odors, adversely affecting a substantial number of people (Less than Significant Impact) The Crouch Avenue Alternative would result in similar impacts as those discussed for the Proposed Project in Section 3.3, Air Quality. During construction, the Crouch Avenue Alternative would result in emissions of odors in the form of diesel exhaust from construction equipment and vehicles. However, these odors would be short-term, limited in extent at any given time, and distributed throughout the Crouch Avenue Alternative area for the duration of construction. Therefore, construction of the Crouch Avenue Alternative would result in a less-than-significant impact from odor emissions. Similar to the Proposed Project, the Crouch Avenue Alternative would provide an overall odor benefit by replacing existing septic tanks that emit unpleasant odors. Odor emissions during operation and maintenance activities of this alternative would be minimal and immeasurable due to the infrequency of these activities, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because both the Crouch Avenue Alternative and the Proposed Project alignment would result in less than significant impacts on this criterion.

Mitigation. No mitigation required.
653
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 474

5.5.2.4 Entler Avenue Hybrid and Crouch Avenue Alternative Impact AIR-1: Conflict with or obstruct implementation of an applicable air quality plan (Less than Significant Impact)
The Entler Avenue Hybrid and Crouch Avenue Alternative would result in similar impacts as those discussed for the Proposed Project in Section 3.3, Air Quality. Similar to the Proposed Project, all construction jobs associated with the Entler Avenue Hybrid and Crouch Avenue Alternative would be temporary and would primarily be filled by the current workforce within Butte County. During construction, the Entler Avenue Hybrid and Crouch Avenue Alternative would not result in employment growth within the county beyond growth projections presented in the 2018 Air Quality Attainment Plan.

Operation and maintenance of the Entler Avenue Hybrid and Crouch Avenue Alternative could foster population and economic growth in the study area. However, any population inducement would be a regrowth and repopulation towards pre-fire levels and would be contained within the Town. About 5-10 permanent employees would serve this alternative during operation and maintenance, which may be re-assigned from existing staff within the Town or may be additional new staff. The minimal increase in employment during operation and maintenance of this alternative would be consistent with the growth projections in the 2018 Air Quality Attainment Plan. Therefore, construction, operation, and maintenance of the Entler Avenue Hybrid and Crouch Avenue Alternative would not conflict with or obstruct implementation of the 2018 Air Quality Attainment Plan, resulting in a less than significant impact.

The level of impact would be the same as that for the Proposed Project because both the Entler Avenue Hybrid and Crouch Avenue Alternative and the Proposed Project Entler Avenue alignment have a less than significant impact on obstructing implementation of the 2018 Air Quality Attainment Plan.

Mitigation. No mitigation required.

Impact AIR-2: 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 Impact)
Consistent with the analysis for the Proposed Project, the Entler Avenue Hybrid and Crouch Avenue Alternative would generate criteria air pollutant emissions during construction. The Entler Avenue Hybrid and Crouch Avenue Alternative would generate criteria air pollutant emissions similar to those listed in Table 3.3-3, Unmitigated Construction Criteria Air Pollutant Emissions. This alternative would generate ROG, NOX, PM10, and PM2.5 emissions that do not exceed the BCAQMD’s thresholds of significance. Similar to the Proposed Project, the Entler Avenue Hybrid and Crouch Avenue Alternative will implement BCAQMD’s best practice measures to minimize fugitive dust during construction.

Therefore, impacts from criteria air pollutant emissions during construction of the Entler Avenue Hybrid and Crouch Avenue Alternative would be less than significant. Criteria air pollutant emissions during operation and maintenance activities of this alternative would be minimal and immeasurable due to the infrequency of these activities, resulting in no impact. 654
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 475
The level of impact would be the same as that for the Proposed Project because both the Entler Avenue Hybrid and Crouch Avenue Alternative and the Proposed Project Entler Avenue alignment would have a less than significant impact on this criterion.

Mitigation. No mitigation required.

Impact AIR-3: Expose sensitive receptors to substantial pollutant concentrations (Less than Significant Impact)
The Entler Avenue Hybrid and Crouch Avenue Alternative would result in similar impacts as those discussed for the Proposed Project in Section 3.3, Air Quality. The closest sensitive receptors to the Entler Avenue Hybrid and Crouch Avenue Alternative are residential dwelling units along Entler Avenue, located approximately 50 feet away (Google Earth 2022). During construction, the Entler Avenue Hybrid and Crouch Avenue Alternative would generate TAC emissions from the use of diesel equipment that could affect existing sensitive receptors. However, construction activities would be temporary and short-term. Only portions of this alternative would be disturbed at a given time throughout the construction period, with operation of construction equipment occurring intermittently throughout the course of a day rather than continuously at any one location along Entler Avenue or Crouch Avenue. This would allow for the dispersal of TAC emissions by avoiding continuous construction activity in the portions of the Entler Avenue Hybrid and Crouch Avenue Alternative area closest to existing sensitive receptors. Similar to the Proposed Project, the Entler Avenue Hybrid and Crouch Avenue Alternative will implement BCAQMD best practice measures to reduce diesel particulate matter from construction equipment. Therefore, construction of the Entler Avenue Hybrid and Crouch Avenue Alternative would result in a less-than-significant impact from TAC emissions. TAC emissions during operation and maintenance activities of this alternative would be minimal and immeasurable due to the infrequency of these activities, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because sensitive receptors are located at the same distance (50 feet) from both the Entler Avenue Hybrid and Crouch Avenue Alternative and the Proposed Project alignment. Therefore, both the Proposed Project and the Entler Avenue Hybrid and Crouch Avenue Alternative would result in a less-than-significant impact on this criterion.

Mitigation. No mitigation required.

Impact AIR-4: Result in other emissions, such as those leading to odors, adversely affecting a substantial number of people (Less than Significant Impact) The Entler Avenue Hybrid and Crouch Avenue Alternative would result in similar impacts as those discussed for the Proposed Project in Section 3.3, Air Quality. During construction, the Entler Avenue Hybrid and Crouch Avenue Alternative would result in emissions of odors in the form of diesel exhaust from construction equipment and vehicles. However, these odors would be short-term, limited in extent at any given time, and distributed throughout the Entler Avenue Hybrid and Crouch Avenue Alternative area for the duration of construction. Therefore, construction of the Entler Avenue Hybrid and Crouch Avenue Alternative would result in a less-than-significant impact from odor emissions. Similar to the Proposed Project, the Entler Avenue Hybrid and Crouch Avenue Alternative would provide an overall 655
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 476
odor benefit by replacing existing septic tanks that emit unpleasant odors. Odor emissions during operation and maintenance activities of this alternative would be minimal and immeasurable due to the infrequency of these activities, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because both the Entler Avenue Hybrid and Crouch Avenue Alternative and the Proposed Project alignment would result in less than significant impacts on this criterion.

Mitigation. No mitigation required.

5.5.2.5 Alternatives Impact Summary
Table 5.5-2 summarizes the air quality impacts of the alternatives and a comparison to the Proposed Project.

Table 5.5-2. Alternatives Impacts Summary for Air Quality Impact Proposed
Project
No Project
Alternative
Entler
Avenue
Hybrid
Alternative
Crouch
Avenue
Alternative
Entler Avenue
Hybrid and
Crouch Avenue
Alternative
Impact AIR-1: Conflict with or obstruct
implementation of an applicable air quality
plan
LTS NI (-) LTS (=) LTS (=) LTS (=)
Impact AIR-2: Result in a cumulatively
considerable net increase of any criteria
pollutant for which the Project region is
nonattainment under an applicable federal
or state ambient air quality standard
LTS NI (-) LTS (=) LTS (=) LTS (=)
Impact AIR-3: Expose sensitive receptors
to substantial pollutant concentrations LTS NI (-) LTS (=) LTS (-) LTS (=) Impact AIR-4: Result in other emissions,
such as those leading to odors, adversely
affecting a substantial number of people
LTS LTS (+) LTS (=) LTS (=) LTS (=)
Notes: LTS = Less than Significant Impact, NI = No Impact, N/A = Not Applicable, SU = Significant and Unavoidable Impact, S/M = Significant Impact but Mitigable to a Less than Significant Level, (+) indicates a greater level of impacts compared to the Proposed Project; (-) indicates less impacts compared the Proposed Project; (=) indicates the same level of impacts as the Proposed Project

5.5.3 Biological Resources

5.5.3.1 No Project Alternative
Impact BIO-1: 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 CDFW or USFWS (No Impact) Under the No Project Alternative, existing conditions would remain the same, and no ground disturbance would occur. Therefore, the No Project Alternative would not result in substantial adverse effects involving candidate, sensitive, or special-status species, resulting in no impact. The level of 656
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 477
impact would be less than that for the Proposed Project because the impacts from the Proposed Project would be less than significant with mitigation incorporated under this criterion.

Mitigation. No mitigation required.

Impact BIO-2: Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the CDFW or USFWS (No Impact)
Under the No Project Alternative, existing conditions would remain the same, and no ground disturbance would occur. Therefore, the No Project Alternative would not result in substantial adverse effects involving riparian habitat or other sensitive natural communities, resulting in no impact. The level of impact would be less than that for the Proposed Project because the impacts from the Proposed Project would be less than significant with mitigation incorporated under this criterion.

Mitigation. No mitigation required.

Impact BIO-3: Have a substantial adverse effect on state or federally protected wetlands (No Impact)
Under the No Project Alternative, existing conditions would remain the same, and no ground disturbance would occur. Therefore, the No Project Alternative would not result in substantial adverse effects involving state or federally protected wetlands, resulting in no impact. The level of impact would be less than that for the Proposed Project because the impacts from the Proposed Project would be less than significant with mitigation incorporated under this criterion.

Mitigation. No mitigation required.

Impact BIO-4: 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 wildlife nursery sites (No impact)
Under the No Project Alternative, existing conditions would remain the same, and there would be no introduction of any new impermeable barriers to the landscape or waters. Therefore, the No Project Alternative would not result in substantial adverse effects involving the movement of native resident or migratory fish or wildlife species, or migratory wildlife corridors or nursery sites, resulting in no impact.

The level of impact would be the same as that for the Proposed Project because there would be no impact on the movement of species, wildlife corridors and nursery sites under the No Project Alternative and the Proposed Project.

Mitigation. No mitigation required.

Impact BIO-5: Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance (No Impact) Under the No Project Alternative, existing conditions would remain the same, and no ground disturbance would occur. Therefore, the No Project Alternative would not result in substantial adverse effects involving local policies or ordinances protecting biological resources, resulting in no impact. The 657
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 478
level of impact would be the same as that for the Proposed Project because there would be no impact from conflicting with local policies or ordinances protecting biological resources under the No Project Alternative and the Proposed Project.

Mitigation. No mitigation required.

Impact BIO-6: 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)
Under the No Project Alternative, existing conditions would remain the same, and no ground disturbance would occur. Therefore, the No Project Alternative would not result in substantial adverse effects involving the provisions of any Habitat Conservation Plan; Natural Community Conservation Plan; or other approved local, regional, or state conservation plan, resulting in no impact. The level of impact would be the same as that for the Proposed Project because neither the Proposed Project nor the No Project Alternative would result in impacts on a Habitat Conservation Plan or Natural Community Conservation Plan.

Mitigation. No mitigation required.

5.5.3.2 Entler Avenue Hybrid Alternative
Impact BIO-1: 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 CDFW or USFWS (Less than Significant Impact with Mitigation Incorporated)
The Entler Avenue Hybrid Alternative would result in similar impacts as those discussed for the Proposed Project in Section 3.4, Biological Resources. The Entler Avenue Hybrid Alternative would cross approximately 0.4 mile of additional valley-foothill riparian habitat between Butte Creek and SR 99 than the Proposed Project. Valley-foothill riparian is suitable habitat for multiple special-status species of plants and wildlife and is often utilized by wildlife as a movement corridor. During the field studies in spring 2021, the valley-foothill riparian habitat between Butte Creek and SR 99 along the Entler Avenue Hybrid Alternative could not be examined closely during due to the lack of public access to this area. However, elderberry shrubs, which are the host plant of the federally threatened valley elderberry longhorn beetle, could be present in the valley-foothill riparian habitat along this alternative.

Although suitable habitat for special-status plant and wildlife species would be avoided as much as possible, construction of the Entler Avenue Hybrid Alternative may result in adverse impacts on these species should they be present in areas proposed for disturbance. This is considered a potentially significant impact. The Entler Avenue Hybrid Alternative will implement the same mitigation measures as the Proposed Project (MM-BIO-1: Minimize Disturbance Footprint, MM-BIO-2: Special-status Plant Surveys, MM-BIO-3: Special-status Plant Avoidance, MM-BIO-4: Biological Monitoring and Worker Environmental Awareness Training, MM-BIO-5: Restoration of Temporarily Disturbed Areas and Invasive Weed Control, MM-BIO-9: Mapping of Elderberry Shrubs and Section 7 Consultation, MM-BIO-10: No Net Loss of Elderberry Shrubs, MM-BIO-11: Elderberry Transplanting, MM-BIO-12: Avoidance Areas, MM-BIO-13: Chemical Use, and MM-BIO-14:
658
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 479
Mowing), which would reduce impacts on special-status plants and wildlife species during construction to less than significant. Operation and maintenance of this alternative would not include ground disturbing activities and would result in no impacts on special-status plant and wildlife species.

The level of impact would be the same as that for the Proposed Project, except that the Entler Avenue Hybrid Alternative would cross approximately 0.4 mile of additional valley-foothill riparian habitat, which is a sensitive community, between Butte Creek and SR 99. Therefore, impacts from the Entler Avenue Hybrid Alternative would be considered greater than impacts from the Proposed Project Entler Avenue alignment on this criterion. Both Proposed Project and the Entler Avenue Hybrid Alternative would require mitigation to reduce impacts to a less than significant level.

Mitigation. To minimize potentially significant impacts on special-status plant and wildlife species during construction of the Entler Avenue Hybrid Alternative to a less than significant level, mitigation measures MM-BIO-1 through MM BIO-5 and MM-BIO-9 through MM-BIO-14 will be implemented.

MM-BIO-1: Minimize Disturbance Footprint (see Section 3.4, Biological Resources, for description) MM-BIO-2: Special-status Plant Surveys (see Section 3.4, Biological Resources, for description) MM-BIO-3: Special-status Plant Avoidance (see Section 3.4, Biological Resources, for description) MM-BIO-4: Biological Monitoring and Worker Environmental Awareness Training (see Section 3.4, Biological Resources, for description)
MM-BIO-5: Restoration of Temporarily Disturbed Areas and Invasive Weed Control (see Section 3.4, Biological Resources, for description)
MM-BIO-9: Mapping of Elderberry Shrubs and Section 7 Consultation (see Section 3.4, Biological Resources, for description)
MM-BIO-10: No Net Loss of Elderberry Shrubs (see Section 3.4, Biological Resources, for description)
MM-BIO-11: Elderberry Transplanting (see Section 3.4, Biological Resources, for description) MM-BIO-12: Avoidance Areas (see Section 3.4, Biological Resources, for description) MM-BIO-13: Chemical Use (see Section 3.4, Biological Resources, for description) MM-BIO-14: Mowing (see Section 3.4, Biological Resources, for description) Significance after Mitigation. With the implementation of MM-BIO-1 through MM BIO-5 and MM-BIO9 through MM-BIO-14, impacts on special-status plant and wildlife species during construction would be less than significant.
659
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 480
Impact BIO-2: Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the CDFW or USFWS (Less than Significant Impact with Mitigation Incorporated) As described under Impact BIO-1, the Entler Avenue Hybrid Alternative would cross approximately

0.4 mile of additional valley-foothill riparian habitat between Butte Creek and SR 99 than the Proposed Project. Valley-foothill riparian habitat is considered a sensitive natural community. No aquatic features are present within the Entler Avenue Hybrid Alternative footprint. Although sensitive natural communities would be avoided as much as possible, construction of the Entler Avenue Hybrid Alternative may result in adverse impacts on sensitive natural communities in the area between Butte Creek and SR 99. This is considered a potentially significant impact. The Entler Avenue Hybrid Alternative would implement the same mitigation measures as the Proposed Project (MM-BIO-1:

Minimize Disturbance Footprint, MM-BIO-5: Restoration of Temporarily Disturbed Areas and Invasive Weed Control, MM-BIO-7: Sensitive Community Fencing, and MM-BIO-8: Dry Work Areas), which would reduce impacts on sensitive natural communities during construction to less than significant. Operation and maintenance of this alternative would not include ground disturbing activities and would result in no impacts on sensitive natural communities.

The level of impact would be the same as that for the Proposed Project, except that Entler Avenue Hybrid Alternative would cross approximately 0.4 mile of additional valley-foothill riparian habitat, which is a sensitive community, between Butte Creek and SR 99. Therefore, impacts from the Entler Avenue Hybrid Alternative would be considered greater than impacts from the Proposed Project Entler Avenue alignment on this criterion. Both the Proposed Project Entler Avenue alignment and the Entler Avenue Hybrid Alternative would require mitigation to reduce impacts to less than significant level.

Mitigation. To minimize potentially significant impacts on sensitive natural communities during construction of the Entler Avenue Hybrid Alternative to a less than significant level, mitigation measures MM-BIO-1, MM-BIO-5, MM-BIO-7, and MM-BIO-8 will be implemented.

MM-BIO-1: Minimize Disturbance Footprint (see Section 3.4, Biological Resources, for description) MM-BIO-5: Restoration of Temporarily Disturbed Areas and Invasive Weed Control (see Section 3.4, Biological Resources, for description)
MM-BIO-7: Sensitive Community Fencing (see Section 3.4, Biological Resources, for description) MM-BIO-8: Dry Work Areas (see Section 3.4, Biological Resources, for description) Significance after Mitigation. With the implementation of MM-BIO-1, MM-BIO-5, MM-BIO-7, and MMBIO-8, impacts on sensitive natural communities during construction would be less than significant.

Impact BIO-3: Have a substantial adverse effect on state or federally protected wetlands (No Impact)
Since the Entler Avenue Hybrid Alternative was not accessible during the field studies in spring 2021, a desktop review was conducted to determine if aquatic features are present within the Entler Avenue Hybrid Alternative. Based on a desktop review of aerial images and other information as described in 660
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 481
Section 3.4.3, Methods of Analysis, no aquatic features are present within the Entler Avenue Hybrid Alternative footprint. Therefore, construction, operation, and maintenance of the Entler Avenue Hybrid Alternative would result in no impacts on state or federally protected wetlands.

The level of impact would be less than that for the Proposed Project because vernal pools were mapped within 250-feet of Skyway for the Proposed Project and the Proposed Project Entler Avenue alignment would result in less-than-significant impacts with mitigation incorporated on federally protected wetlands.

Mitigation. No mitigation required.

Impact BIO-4: 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 wildlife nursery sites (No impact)
Consistent with the analysis for the Proposed Project, the Entler Avenue Hybrid Alternative would not interfere with movement of any fish or wildlife species because none of the Entler Avenue Hybrid Alternative components involve the introduction of any new impermeable barriers to the landscape or waters. All new infrastructure associated with the Entler Avenue Hybrid Alternative would be placed below ground. Additionally, none of the Entler Avenue Hybrid Alternative components would impede the use of wildlife nursery sites. Therefore, construction, operation, and maintenance of the Entler Avenue Hybrid Alternative would have no impact on the movement of any native resident or migratory fish or wildlife species, wildlife corridors, or wildlife nursery sites.

The level of impact would be the same as that for the Proposed Project because neither the Entler Avenue Hybrid Alternative nor the Proposed Project Entler Avenue alignment would impact the movement of species, wildlife corridors, or wildlife nursery sites.

Mitigation. No mitigation required.

Impact BIO-5: Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance (No Impact) The Butte County General Plan 2030 (Butte County 2012), Town of Paradise General Plan (Town of Paradise and Quad Consultants 2008), and Chico 2030 General Plan (City of Chico 2017) include policies to protect water resources, wetland and riparian areas, fish and wildlife habitat, wildlife movement corridors, vegetation communities, open space for the preservation of natural resources, threatened and endangered species, and aquatic habitats. Additionally, the general plans include specific measures to preserve and protect oak trees and oak woodlands. A review of the policies included in the Butte County General Plan 2030, Town of Paradise General Plan, and Chico 2030 General Plan resulted in the determination that the Entler Avenue Hybrid Alternative activities are consistent with these policies. Therefore, construction, operation, and maintenance of the Entler Avenue Hybrid Alternative would not conflict with any local policies or ordinances protecting biological resources, resulting in no impact.
661
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 482
The level of impact would be the same as that for the Proposed Project because neither the Entler Avenue Hybrid Alternative nor the Proposed Project Entler Avenue alignment would conflict with local policies or ordinances protecting biological resources.

Mitigation. No mitigation required.

Impact BIO-6: 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)
Consistent with the analysis for the Proposed Project, a portion of the Entler Avenue Hybrid Alternative area overlaps with BRCP, which had not been formally adopted as of summer 2021, though it was in the final phase of development. Species analyzed and discussed in this document that are covered species under the BRCP include Hoover’s spurge, Butte County meadowfoam, hairy Orcutt grass, Butte County checkerbloom, Greene’s tuctoria, Conservancy fairy shrimp, vernal pool fairy shrimp, vernal pool tadpole shrimp, valley elderberry longhorn beetle, Central Valley steelhead, Central Valley spring-run Chinook salmon, giant garter snake, western pond turtle, foothill yellow-legged frog, western spadefoot, tricolored blackbird, burrowing owl, California black rail, Swainson’s hawk, and white-tailed kite. Construction, operation, and maintenance of the Entler Avenue Hybrid Alternative may be covered under the Waste and Wastewater Management Facility Permanent Development Projects component of the BRCP. However, these activities do not conflict with the BRCP. Therefore, construction, operation, and maintenance of the Entler Avenue Hybrid Alternative would not conflict with an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. As a result, no impacts would occur.

The level of impact would be the same as that for the Proposed Project because neither the Entler Avenue Hybrid Alternative nor the Proposed Project Entler Avenue alignment would conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

Mitigation. No mitigation required.

5.5.3.3 Crouch Avenue Alternative
Impact BIO-1: 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 CDFW or USFWS (Less than Significant Impact with Mitigation Incorporated)
The Crouch Avenue Alternative would result in similar impacts as those discussed for the Proposed Project in Section 3.4, Biological Resources. The Crouch Avenue Alternative would cross valley-foothill riparian habitat along Little Chico Creek. Valley-foothill riparian habitat is suitable habitat for multiple special-status species of plants and wildlife and is often utilized by wildlife as a movement corridor.

During the field studies in spring 2021, elderberry shrubs, which are the host plant of the federally threatened valley elderberry longhorn beetle, were found to be present in valley-foothill riparian habitat along the Little Chico Creek at the Crouch Avenue Alternative crossing. Although suitable habitat for special-status plant and wildlife species would be avoided as much as possible, construction of the 662
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 483
Crouch Avenue Alternative may result in adverse impacts on these species should they be present in areas proposed for disturbance. This is considered a potentially significant impact. The Crouch Avenue Alternative would implement the same mitigation measures as the Proposed Project (MM-BIO-1:

Minimize Disturbance Footprint, MM-BIO-2: Special-status Plant Surveys, MM-BIO-3: Specialstatus Plant Avoidance, MM-BIO-4: Biological Monitoring and Worker Environmental Awareness Training, MM-BIO-5: Restoration of Temporarily Disturbed Areas and Invasive Weed Control, MM-BIO-9: Mapping of Elderberry Shrubs and USFWS Section 7 Consultation, MM-BIO-10: No Net Loss of Elderberry Shrubs, MM-BIO-11: Elderberry Transplanting, MM-BIO-12: Avoidance Areas, MM-BIO-13: Chemical Use, and MM-BIO-14: Mowing), which would reduce impacts on special-status plants and wildlife species during construction to less than significant. Operation and maintenance of this alternative would not include ground disturbing activities and would result in no impacts on special-status plant and wildlife species.

The level of impact would be the same as that for the Proposed Project because both the Crouch Avenue Alternative and the Proposed Project Entler Avenue alignment would result in a less than significant impact with mitigation incorporated on this criterion.

Mitigation. To minimize potentially significant impacts on special-status plant and wildlife species during construction of the Crouch Avenue Alternative to a less than significant level, mitigation measures MM-BIO-1 through MM BIO-5 and MM-BIO-9 through MM-BIO-14 will be implemented.

MM-BIO-1: Minimize Disturbance Footprint (see Section 3.4, Biological Resources, for description) MM-BIO-2: Special-status Plant Surveys (see Section 3.4, Biological Resources, for description) MM-BIO-3: Special-status Plant Avoidance (see Section 3.4, Biological Resources, for description) MM-BIO-4: Biological Monitoring and Worker Environmental Awareness Training (see Section 3.4, Biological Resources, for description)
MM-BIO-5: Restoration of Temporarily Disturbed Areas and Invasive Weed Control (see Section 3.4, Biological Resources, for description)
MM-BIO-9: Mapping of Elderberry Shrubs and USFWS Section 7 Consultation (see Section 3.4, Biological Resources, for description)
MM-BIO-10: No Net Loss of Elderberry Shrubs (see Section 3.4, Biological Resources, for description)
MM-BIO-11: Elderberry Transplanting (see Section 3.4, Biological Resources, for description) MM-BIO-12: Avoidance Areas (see Section 3.4, Biological Resources, for description) MM-BIO-13: Chemical Use (see Section 3.4, Biological Resources, for description) MM-BIO-14: Mowing (see Section 3.4, Biological Resources, for description) 663
Paradise Sewer Project | Final Program Environmental Impact Report Alternatives
hdrinc.com
Final Program Environmental Impact Report 484
Significance after Mitigation. With the implementation of MM-BIO-1 through MM BIO-5 and MM-BIO9 through MM-BIO-14, impacts on special-status plant and wildlife species during construction would be less than significant.

Impact BIO-2: Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the CDFW or USFWS (Less than Significant Impact with Mitigation Incorporated) As discussed under Impact BIO-1, the Crouch Avenue Alternative would cross valley-foothill riparian habitat along Little Chico Creek. Additionally, the Crouch Avenue Alternative area includes aquatic resources, specifically Little Chico Creek. Valley-foothill riparian habitat and aquatic resources are considered sensitive natural communities. Although sensitive natural communities would be avoided as much as possible, construction of the Crouch Avenue Alternative may result in adverse impacts on sensitive natural communities along Little Chico Creek. This is considered a potentially significant impact. The Crouch Avenue Alternative would implement the same mitigation measures as the Proposed Project (MM-BIO-1: Minimize Disturbance Footprint, MM-BIO-5: Restoration of Temporarily Disturbed Areas and Invasive Weed Control, MM-BIO-6: No Net Loss of Aquatic Resources, MM-BIO-7: Sensitive Community Fencing, and MM-BIO-8: Dry Work Areas), which would reduce impacts on sensitive natural communities during construction to less than significant.

Operation and maintenance of this alternative would not include ground disturbing activities and would result in no impacts on sensitive natural communities.

Paradise City CouncilNovember 7, 2022

Paradise City Council
November 7, 2022