Mineral King Group
PO Box 3543
Visalia CA 93278-3543

29-May-06

Theresa Szymanis
Tulare County Resource Management Agency
5961 South Mooney Boulevard
Visalia CA 93277

RE: Notice of Preparation for Tulare County General Plan

The Sierra Club, Mineral King Group, recognizes that past growth has forced major changes in Tulare County and that future growth will continue to exert additional changes in coming decades.  We believe that growth can be managed and directed in a manner where community and quality of life can be preserved and passed on to future generations.  We believe that the county is at a crossroads where it can choose to travel the path towards sprawl, pollution, and loss of wildlife, or travel the path to protect community, clean air, water, and environment.  To that end, we offer our comments in the hope that county decision-makers are as committed as we are to preserving the natural beauty of our county.

Land Use.  The EIR should state as policy that future growth shall be city-centered.  This concept was strongly supported by citizens participating in General Plan Workshops conducted around the county in 2005.  Directing growth towards existing cities and communities will prevent sprawl, which protects unrestricted conversion of agriculture.  Higher density development, including smaller lots, should be emphasized.

Agriculture.  Cattle ranching should be recognized as prime agriculture.  Cattle is consistently among the top 10 crops in the county, and was ranked No. 3 in 2004 and 2005.  The EIR should recognize that cattle ranch land is just as prime as dairy, citrus, and grape farmlands.  The EIR should recognize that conversion of cattle ranch land in foothills rate as critical as conversion of

crop farmlands on the valley floor. 

The EIR should explore farmland conversion mitigation measures, such as mitigation fees and conservation easements.  The impacts of farmland conversion, especially if it is a new town, should be mitigated to the maximum possible.  The EIR should define a policy for General Plan amendments and zone changes from agricultural use to residential use, which should include impact fees for these changes. 

Biological Resources.  Biological diversity should be protected.  The foothills and valley floor contain rivers, creeks, waterways, and remnants of wetlands, woodlands, vernal pools and riparian forests that are habitat to a rich array of plants and animals.  Centuries-old oak trees beautify the landscape as a tribute to our wild land heritage and should be given maximum protection.  In General Plan Workshops and in hearings such as the Tulare Irrigation District canal, citizens have expressed a desire to protect our wildlife legacy.  The EIR should recognize the value of our biological resources, identify critical habitat, and utilize every possible means to avoid disruption to this habitat.  The means could be development fees, land trusts, grants, easements, and acquisition as county parks and preserves as a method of mitigation for development.

Housing.  Principles of smart growth should become a policy and goal statement in the EIR.  Smart growth sustains community identity and nourishes the human environment.  A strong, healthy community is walkable, has green space and parks for recreation, contains mixed-use with shopping, entertainment and restaurants, jobs and a mix of homes for a wide range of residents.  Smart growth is about well-designed higher density that can reduce congestion and commuting time, improve air quality, and protect our natural resources.  Sprawl is expensive due to the cost of infrastructure and services such as fire, police, and schools.  Compact development reduces these costs.  The General Plan policy should strive to attain a specific percentage of growth in communities as smart growth by updating the zoning laws to allow for higher density and mixed use.  It should change the economic climate by tax deferrals and reductions, fee waivers, and density bonuses.  

Energy.  There should be consideration of solar panels and other alternative energy sources.  Solar energy benefits air quality and could generate enough energy to help mitigate the need to build upgraded electric facilities and new power plants.  The use of solar panels can help offset CO2 emissions from new developments and new power plants.  Already, developers in the city of Bakersfield have agreed to install solar in model homes and offer this to potential buyers.  In the city of Fresno, a developer has installed solar in each home in a small subdivision.  The General Plan policy should strive to attain a certain percentage of buildings with solar panels.

There should be consideration of green building design and energy efficient buildings.  Energy conservation should be a primary goal.  This should include water conservation that encourages xeriscaping rather than lawnscaping.

Air Quality.  Air pollution associated with project should be completely mitigated.  The SJVAPCD recently adopted the ISR rule for new projects in the San Joaquin Valley; however, this rule will not completely offset the air pollution associated with the project.  ISR mitigates only 50% of Nox and PM10 emissions and does not mitigate ROG at all.  The EIR should determine mitigation for the other 50% of Nox and PM10 and all of the ROG emissions.  Mitigation measures may include air quality mitigation fees that can be used to fund air pollution reduction projects (such as replacing old school buses) to completely offset the air pollution associated with the project.  The EIR should explore that as a condition of development a requirement that the developer pay a fee into such a fund.  Alternatives to the fund could be including design measures in the project (solar, bikeways, walking trails, etc.) that would reduce air quality impacts and which should be explored in the EIR.

Cumulative Impacts.  The EIR should assess the cumulative impacts, based on different scenarios.  These scenarios could be the city-centered approach, the rural development approach, the new towns approach, etc.  Impacts should be offset with mitigation to the maximum possible.  The scenario with the least impact should be the preferred.

Mary Moy

Conservation Chair

Sierra Club, Mineral King Group