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  Attached is a copy of the letter of support. Randall Gould, District Ranger - 3/9/15


  To whom it may concern: I am writing on the behalf of Sierra Pacific Industries (SPI) which owns and manages 138,697 acres of timberland in Butte County and 30,957 acres in Plumas County. The purpose of this letter is to deliver comments on the grant applications filed by the Butte County Public Works Department (BCPWD) to maintain off-highway vehicle trails. The BCPWD is seeking grant funds from the California Off-Highway Motor Vehicle Recreation Division. (OHMVR). These funds will be used on Ground Operations for road and trail maintenance on both Plumas National Forest and 39.7 miles of Butte County road which include the Concow, Dixie and French Creek roads. SPI has a neutral position of the application’s road maintenance activities and the goal to increase recreational opportunities on the Plumas National Forest roads and trails. We do however have concerns regarding the impacts this proposal will have on adjacent SPI properties and resources. The most alarming aspect of this proposal is the proposed 39.7 miles of Butte County roads which the BCPWD wishes to “maintain for OHV use” which bisects many thousands of acres of the Stirling District of SPI in Butte County. SPI is the primary land owner affected by this proposal with 72.68 percent of land ownership adjacent to the 25 miles of the Concow road, lesser amounts adjacent to Dixie road and the French Creek road. All three County roads lead into blocks of our ownership. This road adjacency exposes thousands of acres and many miles of our private road system and forest to trespass. Consequently, this grant proposal will have a significant effect on SPI private roads and timber land resources. SPI will focus on the Factsheet for Grants and Cooperative Agreement Program, and Project Description for Grants and Cooperative Agreement Program. Evaluation Criteria Items 1 – 14 are answered by providing information specific to the United States Forest Service (USFS). The data found in the reports citied are public information. Items 1- thru 14 correspond to the Plumas National Forest (PNF). Item 1. OHV Visitor Opportunity Summary. All data supplied and cited was generated by a report from the PNF. There is no data which supports use of County roads. There is one very important statistic pertaining to total acres of open riding available for OHV recreation accessed from the County road system. There are NO acres of private land available for open riding for OHV recreation. SPI allows no motor vehicles use on our roads or in our forest. Item 2. Quality of OHV Opportunity. All information applies to the PNF. The only value associated with the County roads is the box that was not checked, Land Manager has no legal OHV riding opportunity or none of the above. Items 3 – 6 are not applicable to the County road OHV use. Item 7. Prevention of OHV trespass. Item 7 a. is correctly answered. Items b and c are incomplete. Item 7 b. SPI has a staff member for District Patrol who dives these County roads 2 to 3 times a week. There are 10 other Staff foresters who also drive the County roads and assist in patrol. This patrol includes discouraging trespass, looking for unauthorized camping, campfires and stopping destruction of natural resources from OHV and motor vehicle operation. SPI also reports to local law enforcement the discovery of other illegal activities. BCPWD has no control over the Butte County Sheriff (BCS) patrol schedule. In most cases, the mountain patrol of the BCS was prompted by a phone call from SPI to help us with unauthorized and illegal activities by individuals who refuse to stay on the County roads. SPI has aggressively signed and blocked unauthorized trails. SPI has gated company privately controlled roads adjacent to the County roads to discourage motor vehicles and OHV use on SPI lands. BCPWD has yet to sign or block any of the off- road trails originating from the County road system. All these trails are unauthorized.

BCPWD states they will post signs under this grant. Despite all of our signs, expense and patrol, SPI lands are still experiencing significant resource impacts from unapproved use. Item 8. Natural and Cultural Resources. Item 8 a. is correctly answered for both PNF and SPI. Item 8 b is correctly answered only for the PNF. BCPWD states “on the Concow, Dixie and French Creeks Roads, proposed ground operations would occur within the existing roadway and impacts to the environment are not expected”. The proposed maintenance activities on County roads are adjacent to our timberlands. The work will result in unavoidable contact with SPI property. BCPWD has no information of the natural or cultural resources that might be right next to these County road. When SPI proposes any road maintenance work on our private road system, under California Environmental Quality Act (CEQA), SPI conducts the appropriate survey work to find out if there are any resources which could be impacted by the proposed activities. This includes impacts to water, soil, botanical, terrestrial and aquatic and cultural resources. Our SPI data base lists many natural and cultural resources which can be impacted by road maintenance activities. Biological protection for many species entails curtailment of road work with a ¼ mile of known nesting or denning sites of many protected species BCPWD states they plan to move down trees and rocks, again without any knowledge of the possibility of the impact to natural or cultural resources. Those rocks and down trees belongs to SPI, and the company needs to be consulted before anything get cut and/or moved. The biggest concern with the planned ground operations is the subject of water quality. Areas near Rag Dump, Granite Springs and Ramsey’s Bar are just a few sites were there are watercourses and springs located adjacent to the Concow County road. The statement by the BCPWD,” impacts to the environment are not expected”, is not accurate. Many segments of the County road system have been discharging sediment into the state’s watercourses for years, impacting both aquatic life and negatively effecting water quality. Item9. Soil Management. a and b. BCPWD has addressed the USF soil issues and admits that they have not addressed soil management issues on the County roads. Yet they claim credit for 10 points. Item 10. , Sound Level Testing. BCPWD has answered correctly. Road use and road construction noise are a concern with nesting wildlife. Item 11. OHV Education. The answers only apply to USF. The BCPWD plans to use grant funds to produce a brochure and provide information at the County web site with information about County road use and OHVs. SPI has produced a brochure and has provided information about OHV use on the SPI web site. The information lets the public know SPI policy pertaining to public access and OHV use. On gated/ blocked roads, the following activities are allowed: walking, hiking in the forest and on roads. Bike riding on company controlled roads. Horseback riding in the forest and on company controlled roads. Hunting and fishing is allowed on company property as long as all State laws are followed. SPI policies include a prohibition of the unauthorized use of motor vehicles and OHVs on our private gated roads and the exclusion of camping or camp fires anywhere on SPI properties. We do not control road use on open company roads. This information has been available for over 10 years. Even though SPI provides individuals with this information and staff speaks with people they contact during patrol, SPI is still experiencing unapproved use of the property adjacent to the County roads. Item 12 Website. Correct information for USFS land only. BCPWD takes credit for all 5 points, but it doesn’t account for the private land impacted by County roads. Item 13 OHV Outreach. SPI was not contacted directly. That might have been a sensible thing to do considering the amount SPI property that is potentially impacted by OHV use. SPI and BCPWD did meet to discuss the County road issue last spring. SPI voiced the same concerns that are being raised in this letter. SPI is looking forwards to continuing this discussion. Item 14 Sustaining ONV Recreation. Same as above, no meeting was requested. The General Application only addressed the USFS concerns, and none of the private landowners in Butte County. Project Description for Grants and Cooperative Agreement Program. Ground Operations Statement of GO Activities. Work. BCPWD has demonstrated that they are unwilling or unable to recognize the extent of the maintenance issues which exist on the Concow, Dixie and French Creek roads. SPI is also troubled with the stated “trail and route repair” and “maintaining road treads” There are no BCPWD “trails”, only the native surface roads. SPI is also concerned with ground operations which “repair or perform heavy-duty tasks, and how this will impact our land and resources adjacent to these County roads. The recent 2014 “road maintenance” completed by the BCPWD resulted in the road surface, soil, being directed into watercourses.

There are many outlets of dips draining directly into the streams without any sediment barriers or energy dissipation which results in soil moving directly into watercourses and accelerated erosion of fill slopes. There are many locations on these County roads which have tall cut banks on both sides of the road. Over time, these sections of road have been graded down below the water table, and sink holes have developed. This situation does not allow for the proper drainage of water off the roads, which in some cases leads to rills and ruts, and sediment delivering directly in to watercourses. The past maintenance activities do not demonstrate “adequate drainage”. Road rerouting or road abandonment and deactivation are the only long term solutions to this type of chronic sediment discharge. BCPWD states ground operations will replace signs and mitigate the illegal trespass of OHV’s onto adjacent private properties by installing and maintaining barriers. If there are any current signs or barriers, they have been provided by SPI. These signs and barriers are located on SPI private property. BCPWD should concentrate all their work on the road prism. Method and Performance of Ground operations. The proposal states that volunteers will help BCPWD with repair and maintenance of the County roads in question. These individuals will be using hand tools and chainsaws. Some of the listed tasks include sign repair and installation, campground maintenance and installing and maintaining barriers. SPI would once more note that are no USFS campgrounds associated with these County roads and unauthorized camping on SPI property is not allowed. Barriers controlling private roads and unauthorized trails on private property are the responsibility of the private landowner. SPI will make the assumption that any activities performed by a volunteer work force would have the appropriate work and safety training and that these groups meet SPI insurance and fire preparedness standards. Heavy-duty tasks. SPI has already addressed the problems associated with moving fallen trees, and work which is outside the road prism. BCPWD states all ground-disturbing road work will be conducted in a manner consistent with the Plumas National Forest standard template (“T Specs”) for haul roads. There are many portions of the Concow road which cannot be used as a haul road. SPI is unsure why this standard is being used. BCPWD also states that the work on Concow, Dixie and French Creek Roads would proceed pursuant to the CEQA Guidelines Section 15301 Class I Categorical Exemption for routine maintenance of existing trails. Are these haul roads or trails? Is the planned maintenance routine? SPI has evaluated many segments of the Concow road and has decided that they are unfit for use as haul roads. SPI has analyzed these segments during the preparation of a Timber Harvest Plan (THP). SPI planned to overhaul these County road segments, but after conducting a feasibility analysis, the cost of such work was too expensive. Any work on these segments of the Concow road would not be classified as routine maintenance. SPI is familiar with Article 19 Categorical Exemptions, 15301. Existing Facilities. Class 1 consists of the operation, repair, maintenance, permitting, leasing, licensing, or minor alteration of existing public or private structures, facilities, mechanical equipment, or topographical features, involving negligible or no expansion of use beyond that existing at the time of the lead agency's determination. The types of "existing facilities" itemized below are not intended to be all-inclusive of the types of projects which might fall within Class 1. The key consideration is whether the project involves negligible or no expansion of an existing use. Examples include but are not limited to: (a) Interior or exterior alterations involving such things as interior partitions, plumbing, and electrical conveyances; (b) Existing facilities of both investor and publicly-owned utilities used to provide electric power, natural gas, sewerage, or other public utility services; (c) Existing highways and streets, sidewalks, gutters, bicycle and pedestrian trails, and similar facilities (this includes road grading for the purpose of public safety). (d) Restoration or rehabilitation of deteriorated or damaged structures, facilities, or mechanical equipment to meet current standards of public health and safety, unless it is determined that the damage was substantial and resulted from an environmental hazard such as earthquake, landslide, or flood; (e) Additions to existing structures provided that the addition will not result in an increase of more than: (1) 50 percent of the floor area of the structures before the addition, or 2,500 square feet, whichever is less; or (2) 10,000 square feet if: (A) The project is in an area where all public services and facilities are available to allow for maximum development permissible in the General Plan and (B) The area in which the project is located is not environmentally sensitive. (f) Addition of safety or health protection devices for use during construction of or in conjunction with existing structures, facilities, or mechanical equipment, or topographical features including navigational devices; (g) New copy on existing on and off-premise signs; (h) Maintenance of existing landscaping, native growth, and water supply reservoirs (excluding the use of pesticides , as defined in Section 12753, Division 7, Chapter 2, Food and Agricultural Code); (i) Maintenance of fish screens, fish ladders, wildlife habitat areas, artificial wildlife waterway devices, stream flows, springs and waterholes, and stream channels (clearing of debris) to protect fish and wildlife resources; (j) Fish stocking by the California Department of Fish and Game; (k) Division of existing multiple family or single-family residences into common-interest ownership and subdivision of existing commercial or industrial buildings, where no physical changes occur which are not otherwise exempt;

(l) Demolition and removal of individual small structures listed in this subdivision; (1) One single-family residence. In urbanized areas, up to three single-family residences may be demolished under this exemption. (2) A duplex or similar multifamily residential structure. In urbanized areas, this exemption applies to duplexes and similar structures where not more than six dwelling units will be demolished. (3) A store, motel, office, restaurant, or similar small commercial structure if designed for an occupant load of 30 persons or less. In urbanized areas, the exemption also applies to the demolition of up to three such commercial buildings on sites zoned for such use. (4) Accessory (appurtenant) structures including garages, carports, patios, swimming pools, and fences. (m) Minor repairs and alterations to existing dams and appurtenant structures under the supervision of the Department of Water Resources. (n) Conversion of a single family residence to office use. (o) Installation, in an existing facility occupied by a medical waste generator, of a steam sterilization unit for the treatment of medical waste generated by that facility provided that the unit is installed and operated in accordance with the Medical Waste Management Act (Section 117600, et seq., of the Health and Safety Code) and accepts no offsite waste. (p) Use of a single-family residence as a small family day care home, as defined in Section 1596.78 of the Health and Safety Code. Note: Authority cited: Section 21083, Public Resources Code; References: Sections 21084, Public Resources Code; Bloom v. McGurk (1994) 26 Cal.App.4th 1307 BCPWD must be assigning the planed work under (c). Existing highways and streets, sidewalks, gutters, bicycle and pedestrian trails, and similar facilities (this includes road grading for the purpose of public safety). and , (B) The area in which the project is located is not environmentally sensitive. SPI is unsure how these assertions are tested or validated. The native surface roads segments targeted in this grant proposal mostly likely do not qualify for CEQA Categorical Exemptions as defined in 15300.1. SPI supports BCPWD in their desire to improve the native surface road network. As a landowner with thousands of miles of native surface roads, SPI fully understand the challenge and the expense of maintaining roads. SPI spends hundreds of thousands of dollars each year on the Stirling District road system for maintenance and drainage improvements. The BCPWD should be encouraged to up-grade their road maintenance practices to Best Management Practices (BMPs) standards. B. Relation of the Proposed Project to OHV Recreation The desire of the BCPW to provide OHV use on the native surface County road system will result in the continuation of the current road surface drainage problems. Providing the County roads as OHV routes will result in more impacts to the natural environment, and more users created trails on private property. C. Describe the size of the specific Project Area(s) in acres and/miles The roads and trails in the Plumas Nation Forest are stated to provide access to some 612 square miles of “terrain”. The 39.7 miles of County road does not list any acres of terrain. That is because most of the lands which these roads pass through are privately owned. If these County roads are promoted as OHV routes, many thousands of acres of SPI and other private property will be “accessed and used” C. Location and description of OHV opportunities. BCPWD description is accurate. 2. Rerouting Requirement. As SPI has stated, road rerouting or road abandonment and deactivation are the only long term solutions to the established sediment discharge found on these County roads. This question should be answered yes. To summarize, SPI is concerned that the promotion of authorized OHV recreational use on Concow, Dixie and French Creek roads may result in significant natural resource degradation and damage to timberlands owned by SPI. SPI supports BCPWD in their desire to improve the native surface road network. The BCPWD should be encouraged to up-grade their road maintenance practices to Best Management Practices (BMPs) standards. SPI would again like to meet to discuss County road issues with BCPWD. SPI appreciates the opportunity to comment on this grant proposal. Please contact me if you have any further questions. Sincerely; Steve Roberts Sierra Pacific Industries District Manager, Stirling District - 4/6/15


  To whom it may concern: I am writing on the behalf of Sierra Pacific Industries (SPI) which owns and manages 138,697 acres of timberland in Butte County and 30,957 acres in Plumas County. The purpose of this letter is to deliver comments on the grant applications filed by the Butte County Public Works Department (BCPWD) to maintain off-highway vehicle trails. The BCPWD is seeking grant funds from the California Off-Highway Motor Vehicle Recreation Division. (OHMVR). These funds will be used on Ground Operations for road and trail maintenance on both Plumas National Forest and 39.7 miles of Butte County road which include the Concow, Dixie and French Creek roads. SPI has a neutral position of the application’s road maintenance activities and the goal to increase recreational opportunities on the Plumas National Forest roads and trails. We do however have concerns regarding the impacts this proposal will have on adjacent SPI properties and resources. The most alarming aspect of this proposal is the proposed 39.7 miles of Butte County roads which the BCPWD wishes to “maintain for OHV use” which bisects many thousands of acres of the Stirling District of SPI in Butte County. SPI is the primary land owner affected by this proposal with 72.68 percent of land ownership adjacent to the 25 miles of the Concow road, lesser amounts adjacent to Dixie road and the French Creek road. All three County roads lead into blocks of our ownership. This road adjacency exposes thousands of acres and many miles of our private road system and forest to trespass. Consequently, this grant proposal will have a significant effect on SPI private roads and timber land resources. SPI will focus on the Factsheet for Grants and Cooperative Agreement Program, and Project Description for Grants and Cooperative Agreement Program. Evaluation Criteria Items 1 – 14 are answered by providing information specific to the United States Forest Service (USFS). The data found in the reports citied are public information. Items 1- thru 14 correspond to the Plumas National Forest (PNF). Item 1. OHV Visitor Opportunity Summary. All data supplied and cited was generated by a report from the PNF. There is no data which supports use of County roads. There is one very important statistic pertaining to total acres of open riding available for OHV recreation accessed from the County road system. There are NO acres of private land available for open riding for OHV recreation. SPI allows no motor vehicles use on our roads or in our forest. Item 2. Quality of OHV Opportunity. All information applies to the PNF. The only value associated with the County roads is the box that was not checked, Land Manager has no legal OHV riding opportunity or none of the above. Items 3 – 6 are not applicable to the County road OHV use. Item 7. Prevention of OHV trespass. Item 7 a. is correctly answered. Items b and c are incomplete. Item 7 b. SPI has a staff member for District Patrol who dives these County roads 2 to 3 times a week. There are 10 other Staff foresters who also drive the County roads and assist in patrol. This patrol includes discouraging trespass, looking for unauthorized camping, campfires and stopping destruction of natural resources from OHV and motor vehicle operation. SPI also reports to local law enforcement the discovery of other illegal activities. BCPWD has no control over the Butte County Sheriff (BCS) patrol schedule. In most cases, the mountain patrol of the BCS was prompted by a phone call from SPI to help us with unauthorized and illegal activities by individuals who refuse to stay on the County roads. SPI has aggressively signed and blocked unauthorized trails. SPI has gated company privately controlled roads adjacent to the County roads to discourage motor vehicles and OHV use on SPI lands. BCPWD has yet to sign or block any of the off- road trails originating from the County road system. All these trails are unauthorized. BCPWD states they will post signs under this grant. Despite all of our signs, expense and patrol, SPI lands are still experiencing significant resource impacts from unapproved use. Item 8. Natural and Cultural Resources. Item 8 a. is correctly answered for both PNF and SPI. Item 8 b is correctly answered only for the PNF. BCPWD states “on the Concow, Dixie and French Creeks Roads, proposed ground operations would occur within the existing roadway and impacts to the environment are not expected”. The proposed maintenance activities on County roads are adjacent to our timberlands.

The work will result in unavoidable contact with SPI property. BCPWD has no information of the natural or cultural resources that might be right next to these County road. When SPI proposes any road maintenance work on our private road system, under California Environmental Quality Act (CEQA), SPI conducts the appropriate survey work to find out if there are any resources which could be impacted by the proposed activities. This includes impacts to water, soil, botanical, terrestrial and aquatic and cultural resources. Our SPI data base lists many natural and cultural resources which can be impacted by road maintenance activities. Biological protection for many species entails curtailment of road work with a ¼ mile of known nesting or denning sites of many protected species BCPWD states they plan to move down trees and rocks, again without any knowledge of the possibility of the impact to natural or cultural resources. Those rocks and down trees belongs to SPI, and the company needs to be consulted before anything get cut and/or moved. The biggest concern with the planned ground operations is the subject of water quality. Areas near Rag Dump, Granite Springs and Ramsey’s Bar are just a few sites were there are watercourses and springs located adjacent to the Concow County road. The statement by the BCPWD,” impacts to the environment are not expected”, is not accurate. Many segments of the County road system have been discharging sediment into the state’s watercourses for years, impacting both aquatic life and negatively effecting water quality. Item9. Soil Management. a and b. BCPWD has addressed the USF soil issues and admits that they have not addressed soil management issues on the County roads. Yet they claim credit for 10 points. Item 10. , Sound Level Testing. BCPWD has answered correctly. Road use and road construction noise are a concern with nesting wildlife. Item 11. OHV Education. The answers only apply to USF. The BCPWD plans to use grant funds to produce a brochure and provide information at the County web site with information about County road use and OHVs. SPI has produced a brochure and has provided information about OHV use on the SPI web site. The information lets the public know SPI policy pertaining to public access and OHV use. On gated/ blocked roads, the following activities are allowed: walking, hiking in the forest and on roads. Bike riding on company controlled roads. Horseback riding in the forest and on company controlled roads. Hunting and fishing is allowed on company property as long as all State laws are followed. SPI policies include a prohibition of the unauthorized use of motor vehicles and OHVs on our private gated roads and the exclusion of camping or camp fires anywhere on SPI properties. We do not control road use on open company roads. This information has been available for over 10 years. Even though SPI provides individuals with this information and staff speaks with people they contact during patrol, SPI is still experiencing unapproved use of the property adjacent to the County roads. Item 12 Website. Correct information for USFS land only. BCPWD takes credit for all 5 points, but it doesn’t account for the private land impacted by County roads. Item 13 OHV Outreach. SPI was not contacted directly. That might have been a sensible thing to do considering the amount SPI property that is potentially impacted by OHV use. SPI and BCPWD did meet to discuss the County road issue last spring. SPI voiced the same concerns that are being raised in this letter. SPI is looking forwards to continuing this discussion. Item 14 Sustaining ONV Recreation. Same as above, no meeting was requested. The General Application only addressed the USFS concerns, and none of the private landowners in Butte County. Project Description for Grants and Cooperative Agreement Program. Ground Operations Statement of GO Activities. Work. BCPWD has demonstrated that they are unwilling or unable to recognize the extent of the maintenance issues which exist on the Concow, Dixie and French Creek roads. SPI is also troubled with the stated “trail and route repair” and “maintaining road treads” There are no BCPWD “trails”, only the native surface roads. SPI is also concerned with ground operations which “repair or perform heavy-duty tasks, and how this will impact our land and resources adjacent to these County roads. The recent 2014 “road maintenance” completed by the BCPWD resulted in the road surface, soil, being directed into watercourses. There are many outlets of dips draining directly into the streams without any sediment barriers or energy dissipation which results in soil moving directly into watercourses and accelerated erosion of fill slopes. There are many locations on these County roads which have tall cut banks on both sides of the road. Over time, these sections of road have been graded down below the water table, and sink holes have developed. This situation does not allow for the proper drainage of water off the roads, which in some cases leads to rills and ruts, and sediment delivering directly in to watercourses. The past maintenance activities do not demonstrate “adequate drainage”. Road rerouting or road abandonment and deactivation are the only long term solutions to this type of chronic sediment discharge. BCPWD states ground operations will replace signs and mitigate the illegal trespass of OHV’s onto adjacent private properties by installing and maintaining barriers. If there are any current signs or barriers, they have been provided by SPI. These signs and barriers are located on SPI private property.

BCPWD should concentrate all their work on the road prism. Method and Performance of Ground operations. The proposal states that volunteers will help BCPWD with repair and maintenance of the County roads in question. These individuals will be using hand tools and chainsaws. Some of the listed tasks include sign repair and installation, campground maintenance and installing and maintaining barriers. SPI would once more note that are no USFS campgrounds associated with these County roads and unauthorized camping on SPI property is not allowed. Barriers controlling private roads and unauthorized trails on private property are the responsibility of the private landowner. SPI will make the assumption that any activities performed by a volunteer work force would have the appropriate work and safety training and that these groups meet SPI insurance and fire preparedness standards. Heavy-duty tasks. SPI has already addressed the problems associated with moving fallen trees, and work which is outside the road prism. BCPWD states all ground-disturbing road work will be conducted in a manner consistent with the Plumas National Forest standard template (“T Specs”) for haul roads. There are many portions of the Concow road which cannot be used as a haul road. SPI is unsure why this standard is being used. BCPWD also states that the work on Concow, Dixie and French Creek Roads would proceed pursuant to the CEQA Guidelines Section 15301 Class I Categorical Exemption for routine maintenance of existing trails. Are these haul roads or trails? Is the planned maintenance routine? SPI has evaluated many segments of the Concow road and has decided that they are unfit for use as haul roads. SPI has analyzed these segments during the preparation of a Timber Harvest Plan (THP). SPI planned to overhaul these County road segments, but after conducting a feasibility analysis, the cost of such work was too expensive. Any work on these segments of the Concow road would not be classified as routine maintenance. SPI is familiar with Article 19 Categorical Exemptions, 15301. Existing Facilities. Class 1 consists of the operation, repair, maintenance, permitting, leasing, licensing, or minor alteration of existing public or private structures, facilities, mechanical equipment, or topographical features, involving negligible or no expansion of use beyond that existing at the time of the lead agency's determination. The types of "existing facilities" itemized below are not intended to be all-inclusive of the types of projects which might fall within Class 1. The key consideration is whether the project involves negligible or no expansion of an existing use. Examples include but are not limited to: (a) Interior or exterior alterations involving such things as interior partitions, plumbing, and electrical conveyances; (b) Existing facilities of both investor and publicly-owned utilities used to provide electric power, natural gas, sewerage, or other public utility services; (c) Existing highways and streets, sidewalks, gutters, bicycle and pedestrian trails, and similar facilities (this includes road grading for the purpose of public safety). (d) Restoration or rehabilitation of deteriorated or damaged structures, facilities, or mechanical equipment to meet current standards of public health and safety, unless it is determined that the damage was substantial and resulted from an environmental hazard such as earthquake, landslide, or flood; (e) Additions to existing structures provided that the addition will not result in an increase of more than: (1) 50 percent of the floor area of the structures before the addition, or 2,500 square feet, whichever is less; or (2) 10,000 square feet if: (A) The project is in an area where all public services and facilities are available to allow for maximum development permissible in the General Plan and (B) The area in which the project is located is not environmentally sensitive. (f) Addition of safety or health protection devices for use during construction of or in conjunction with existing structures, facilities, or mechanical equipment, or topographical features including navigational devices; (g) New copy on existing on and off-premise signs; (h) Maintenance of existing landscaping, native growth, and water supply reservoirs (excluding the use of pesticides , as defined in Section 12753, Division 7, Chapter 2, Food and Agricultural Code); (i) Maintenance of fish screens, fish ladders, wildlife habitat areas, artificial wildlife waterway devices, stream flows, springs and waterholes, and stream channels (clearing of debris) to protect fish and wildlife resources; (j) Fish stocking by the California Department of Fish and Game; (k) Division of existing multiple family or single-family residences into common-interest ownership and subdivision of existing commercial or industrial buildings, where no physical changes occur which are not otherwise exempt; (l) Demolition and removal of individual small structures listed in this subdivision; (1) One single-family residence. In urbanized areas, up to three single-family residences may be demolished under this exemption.

(2) A duplex or similar multifamily residential structure. In urbanized areas, this exemption applies to duplexes and similar structures where not more than six dwelling units will be demolished. (3) A store, motel, office, restaurant, or similar small commercial structure if designed for an occupant load of 30 persons or less. In urbanized areas, the exemption also applies to the demolition of up to three such commercial buildings on sites zoned for such use. (4) Accessory (appurtenant) structures including garages, carports, patios, swimming pools, and fences. (m) Minor repairs and alterations to existing dams and appurtenant structures under the supervision of the Department of Water Resources. (n) Conversion of a single family residence to office use. (o) Installation, in an existing facility occupied by a medical waste generator, of a steam sterilization unit for the treatment of medical waste generated by that facility provided that the unit is installed and operated in accordance with the Medical Waste Management Act (Section 117600, et seq., of the Health and Safety Code) and accepts no offsite waste. (p) Use of a single-family residence as a small family day care home, as defined in Section 1596.78 of the Health and Safety Code. Note: Authority cited: Section 21083, Public Resources Code; References: Sections 21084, Public Resources Code; Bloom v. McGurk (1994) 26 Cal.App.4th 1307 BCPWD must be assigning the planed work under (c). Existing highways and streets, sidewalks, gutters, bicycle and pedestrian trails, and similar facilities (this includes road grading for the purpose of public safety). and , (B) The area in which the project is located is not environmentally sensitive. SPI is unsure how these assertions are tested or validated. The native surface roads segments targeted in this grant proposal mostly likely do not qualify for CEQA Categorical Exemptions as defined in 15300.1. SPI supports BCPWD in their desire to improve the native surface road network. As a landowner with thousands of miles of native surface roads, SPI fully understand the challenge and the expense of maintaining roads. SPI spends hundreds of thousands of dollars each year on the Stirling District road system for maintenance and drainage improvements. The BCPWD should be encouraged to up-grade their road maintenance practices to Best Management Practices (BMPs) standards. B. Relation of the Proposed Project to OHV Recreation The desire of the BCPW to provide OHV use on the native surface County road system will result in the continuation of the current road surface drainage problems. Providing the County roads as OHV routes will result in more impacts to the natural environment, and more users created trails on private property. C. Describe the size of the specific Project Area(s) in acres and/miles The roads and trails in the Plumas Nation Forest are stated to provide access to some 612 square miles of “terrain”. The 39.7 miles of County road does not list any acres of terrain. That is because most of the lands which these roads pass through are privately owned. If these County roads are promoted as OHV routes, many thousands of acres of SPI and other private property will be “accessed and used” C. Location and description of OHV opportunities. BCPWD description is accurate. 2. Rerouting Requirement. As SPI has stated, road rerouting or road abandonment and deactivation are the only long term solutions to the established sediment discharge found on these County roads. This question should be answered yes. To summarize, SPI is concerned that the promotion of authorized OHV recreational use on Concow, Dixie and French Creek roads may result in significant natural resource degradation and damage to timberlands owned by SPI. SPI supports BCPWD in their desire to improve the native surface road network. The BCPWD should be encouraged to up-grade their road maintenance practices to Best Management Practices (BMPs) standards. SPI would again like to meet to discuss County road issues with BCPWD. SPI appreciates the opportunity to comment on this grant proposal. Please contact me if you have any further questions. Sincerely; Steve Roberts Sierra Pacific Industries District Manager, Stirling District - 4/6/15


  Sierra Access Coalition supports this project and will provide volunteers to work on road and trail maintenance. Sierra Access Coalition - 4/6/15