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BEC Letter to the Butte County Planning CommissionSubmitted on the Oct. 28, 1999 Dear Commission Members: There is a serious problem that I would like to bring to the attention of the Planning Commission regarding the proposal for a Research and Business Park designation to the General Plan. Butte County has a seriously deficient general plan. A general plan is a state requirement defined as "a comprehensive, long-term general plan for the physical development of the county or city, and any land outside its boundaries which in the planning agency’s judgment bears relation to its planning." It is intended to provide the residents of this County with a comprehensive analysis of the areas best suited for housing, industry, agriculture, recreation, etc. while adequately protecting the environment. State law requires that counties project their long-term goals and objectives as well as the policies, principles, and standards that will be used to attain them. The Butte County General Plan is internally inconsistent and inadequate for the challenges our County will face in the coming decades. The disparate elements have no consistency due to the lack of a comprehensive update. The adoption dates (see below) clearly illustrate the lack of connection between the required and optional elements currently acting as the Butte County General Plan. "Because no element is legally subordinate to another, the general plan must resolve potential conflicts between or among the elements through clear language and policy consistency" (State of California General Plan Guidelines).
A General Plan must be internally consistent by law. The Butte County General Plan seriously violates this requirement. For example, it is quite impossible to have a circulation element from 1971 consistent with a land use element from 1991. The current Development Services Director, Tom Parilo, has proposed to remedy the General Plan inconsistencies and inadequacies by slowly revising each element separately without a comprehensive update or legally adequate environmental review. He also continues to propose incremental zoning changes to the General Plan, without environmental review as witnessed by this item before you today. The input from Mr. Parilo is continuing to leave Butte County in legal jeopardy and without the benefit of a planning document to guide Butte County’s future. Under CEQA, this is a project and it does have the potential to "significantly effect" the environment (21068). The inadequate negative declaration with mitigation measures accompanying this Research and Business Park proposal does not address the growth inducing impacts or the cumulative impacts of this zoning change. If you continue to proceed down the legally precarious path laid out for you by Tom Parilo, you must conduct adequate environmental review with an Environmental Impact Report. My hope is that you will finally realize the legal jeopardy the County is in with these incremental general plan amendments and zoning changes and recommend to the Board of Supervisors that they initiate a comprehensive general plan update with full environmental review. Thank you for your the opportunity to comment. |
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