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Thursday, September 6, 2007

Fool’s Gold Mitigation for Oak Trees in Amador County?

Below are comments submitted by California Oak Foundation for the Gold Rush Ranch and Golf Resort project in the Sierra foothill city of Sutter Creek, Amador County:

August 2, 2007

Jeff Kelly, Director
Sutter Creek Community Development
18 Main St
Sutter Creek, CA 95685

Re: Gold Rush Ranch and Golf Resort Specific Plan

Dear Director Kelly:

The California Oak Foundation writes with comments regarding the Gold Rush Ranch and Golf Resort Specific Plan (SP):

1. The SP correctly notes that the trunk diameter for all trees under City Code Chapter 13.24 are to be measured “at forty-eight inches above natural grade,” yet the SP also states that “The survey used the State and industry forester standard of measuring 54 inches above grade” (p. 82).

Chapter 13.24 specific provisions supersede state and industry general standards. Gold Rush consultants had no authority to use a tree diameter measure inconsistent with the standard established by city code. Consequently, the SP Tree Inventory Report is unlawful.

2. The proposed “active” oak reserve has marginal residual oak habitat value. A more accurate characterization of this group of remaining oak trees would be a remnant oak stand encircled on three sides by residences and roads, bisected by a golf course and adjacent to property that will be developed in the near future.

Moreover, this oak preserve doesn’t constitute an oak habitat mitigation measure. Preservation of existing oaks in no way mitigates for project removal of 12,350 oak trees (41 percent), direct impacts to 185 oak woodland acres (44 percent) and indirect habitat degradation of 235 oak woodland acres (56 percent).

Impact avoidance through on-site oak woodlands conservation easement serves only to limit the degree of significant oak woodland impacts and the project applicant’s oak woodlands mitigation responsibilities. Gold Rush’s oak preserve amounts to nothing more than a promise not to further remove or fragment the remnant oak resource; this preserve does nothing to mitigate the actual impacts from removing over 40 percent of project site oak trees and oak habitat.

3. Gold Rush’s “comprehensive” oak woodlands mitigation plan relies on planting three oaks for every oak removed and a monitoring program to ensure a 90 percent survival rate after 10 years. This approach represents blind faith mitigation, a hope that after 10 years a vibrant oak forest will begin to rise and in another century or two replace the habitat values of their long-gone brethren.

The Gold Rush draft EIR needs to present peer-reviewed information documenting projects that have successfully created mature oak woodland habitat for California Environmental Quality Act (CEQA) mitigation purposes on the scale proposed by Gold Rush.

4. CEQA requires that the Gold Rush draft EIR produce a comprehensive cumulative impacts list of past, present and probable future projects impacting oak resources in the Sutter Creek region, including quantifying the extent and severity of those oak habitat impacts.

Gold Rush advertises that the project “is designed to fit sensitively into the gently rolling foothills.” COF finds that the project design in fact directly or indirectly destroys oak habitat connectivity and functionality across 420 acres of oak woodlands, without providing proportional habitat mitigation.

To provide proportional mitigation for Gold Rush’s significant direct and indirect oak resource impacts, COF suggests that the proposed SP tree planting program be supplemented by the following oak habitat mitigation measure, which is similar to Roseville’s 2004 West Roseville Specific Plan model:

“A fee of 0.25 percent of the gross sales price on every resale of a single family home in Gold Rush Ranch and Golf Resort for 20 years following the initial sale. New home sales are not subject to the fee. This conveyance fee shall be paid annually to the state Oak Woodlands Conservation Fund, Wildlife Conservation Board with the stipulation that the conveyance fee will be used to purchase oak woodland conservation easements in close proximity to the City of Sutter Creek.”

Thank you for your consideration and cooperation in conserving Sutter Creek’s very important oak resources for future generations.

Sincerely, Janet S. Cobb, President -- California Oak Foundation

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