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February 2002
California Oak Report
Unsmart Growth
In a joint expression of alarm about the loss of oak woodlands to development, the California Oak Foundation, Sierra Club and Audubon Society have joined forces in filing a lawsuit against Placer County over its approval of the Bickford Ranch residential development project. The groups' primary concern is that even when general plans provide adequate protection for oak woodlands, local jurisdictions like Placer County seek ways to bypass their own regulations.
Janet Cobb, president of the California Oak Foundation, believes that it is important that her statewide organization challenges Placer County in order to protect the vital oak resources of the Sierra foothills. "Developers cannot plant their way out of destroying 12,000 blue oaks and 960 acres of blue oak habitat," Cobb said. "Blue oaks are one of the only oaks not yet found to be susceptible to Sudden Oak Death disease."
In approving Bickford Ranch, the county violated its own General Plan. While the General Plan protects ecologically significant blue oak woodlands, the Board of Supervisors unnecessarily allowed the project to decimate the blue oak habitat on the site. "We offered the county alternative Bickford designs that would have protected the blue oak woodland but they were rejected," said Terry Davis of the Sierra Club. "That refusal constitutes a breach of public trust and is in violation of the county's own policies."
"What is really at issue here is the future of Placer County," states Sierra Foothills Audubon Conservation Chair Ed Pandolfino. "Will we follow the example of Los Angeles and the Bay Area and allow the entire western county to become an unbroken stretch of sprawl, or will we follow the County's General Plan which supports tremendous growth while still preserving open space and habitat for wildlife and people to enjoy?"
Placer County/Bickford Ranch Lawsuit: www.californiaoaks.org/html/current_issues.html
Bickford Ranch:
Blue Oak Woodlands Profile
Placer County
Total land base = 960,024 acres.
Total blue oak woodland = 15,390 acres or 1.6% of the Placer County land base
Bickford Ranch blue oak woodland = 1,416 acres or 9% of Placer County blue oak habitat.
Bickford Ranch blue oak woodland removed = 960 acres or 68% of site blue oak habitat.
Bickford Ranch blue oak woodland retained = 456 acres or 32% of site blue oak habitat.
Ecological Setting
The 1,416 acres of blue oak habitat located at Bickford Ranch represent one of only two remaining blue oak woodland resource areas in Placer County containing sufficient contiguous acreage and the variety of ecological elements vital to the normal life cycle needs of local special status species and hundreds of other "common" amphibian, bird, mammal and reptile species.
Relevant County General Plan Policies
6.C.1. The County shall identify and protect significant ecological resource areas and other unique wildlife habitats critical to protecting and sustaining wildlife populations. Significant ecological resource areas include the following...Large areas of non?fragmented natural habitat, including Blue Oak Woodlands...
6.D.4. The County shall ensure that landmark trees and major groves of native trees are preserved and protected. In order to maintain these areas in perpetuity, protected areas shall also include younger vegetation with suitable space for growth and reproduction.
6.D.6. The County shall ensure the conservation of sufficiently large, continuous expanses of native vegetation to provide suitable habitat for maintaining abundant and diverse wildlife.
6.D.8. The County shall require that new development preserve natural woodlands to the maximum extent possible.
General Plan Inconsistency
Do the performance standards of the relevant Placer County General Plan (GP) policies actually protect any "significant [blue oak woodland] ecological resource area" (6.C.1); "major grove of native trees" (6.D.4); "sufficiently large, continuous expanses of native vegetation" (6.D.6) or "natural woodlands" (6.D.8)? No.
The GP does not define a significant blue oak woodland ecological resource area or describe the criteria for determining blue oak woodland ecological significance. The relevant GP policies are not guided by any credible blue oak habitat protection or conservation performance standards. The 6.C.1, 6.D.4, 6.D.6 and 6.D.8 performance standards are contained in the Tree Preservation Ordinance. However, the Tree Preservation standards are focused solely on individual tree protection measures; no tree habitat protection standards are included. For example, the Tree Preservation Ordinance characterizes native trees, but there are no definitions for the terms blue oak woodland, natural woodlands, sufficiently large, major grove of native trees or any description of feasible blue oak woodland habitat mitigation measures to reduce resource impacts. An ecological resource which is not even defined cannot be preserved in accordance with the expressed intent of the relevant GP policies.
The insufficiency of the Tree Preservation Ordinance provisions as blue oak habitat conservation performance standards is demonstrated by the fact that the project site contains 78,700 oak trees of which 11,700 will be removed. This is a 15% reduction in the number of oak trees. The site contains 1,420 acres of blue oak woodland, of which 960 acres of woodland would be lost because of project construction. This is a 67.6% reduction in the number of oak woodland habitat acres. Plainly, the current Tree Preservation Ordinance provisions are bereft of performance standards for distinguishing the blue oak forest from the blue oak trees.
Placer County admits that the Tree Preservation Ordinance "does not place any limitations on the number of trees that may be removed" or the amount of oak woodland habitat that may be removed. Under current conditions, Placer County could remove all of its blue oak woodland resource (ecologically significant or otherwise) and the preservation standards of the relevant General Plan policies would still be met. The County would have no blue oak habitat, but still have blue oak woodland protection measures on the books.
While the tree ordinance is satisfactory for individual tree evaluations, it is insufficient as a California Environmental Quality Act performance standard. CEQA is concerned with environmental impacts to tree habitats with greater than 10% blue oak canopy cover; not impacts to individual blue oak trees. For the purpose of a CEQA blue oak woodland ecological analysis and habitat impact mitigation measures, the Tree Preservation Ordinance doesn't cut it.
Summary
Ecologically functional oak woodlands are those that allow for all of the normal life cycle including, cover, denning, nesting, foraging, migration corridors and other functions necessary to complete a life cycle. Essential habitat elements must be in sufficient quantities and arrangement to support the diverse assemblage of wildlife species that are normally found on or use oak woodlands within Placer County. Of the 456 acres of residual blue oak woodland at Bickford Ranch, most is retained in "natural open space" areas. In fact, these open space areas are composed of fragmented and isolated blue oak woodland segments, often forming tree cul-de-sacs bordered by dense development. The design of the Bickford Ranch Specific Plan fails to provide habitat continuity for resident or migratory wildlife, instead either destroying or fragmenting the existing high-quality blue oak woodland habitat.
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