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July 2008
California Oak Report
Forewarned
Carbon storage (sequestration) occurs in forests and soils primarily
through the natural process of photosynthesis. Atmospheric carbon
dioxide (CO2) is taken up through leaves and becomes carbon in the
woody biomass of trees and other vegetation. Approximately half of
vegetation mass is carbon. In terms of its global warming impact, one
unit of CO2 released from burning oak biomass has the same ecological
effect as one unit of CO2 released from a car tailpipe.
The Gold Rush Ranch and Golf Resort project in Sutter Creek (Amador
County) describes its blue/interior live oak resources as covering 700
acres and 70 percent of the site. The population of trees measuring six
inches in diameter and larger is 31,600 and development will remove
13,375 trees or 42 percent, including 1,950 (46 percent) of the trees
greater than 16 inches in diameter.
July 9, 2008
Ms. Mary Beth Van Voorhis
18 Main Street
Sutter Creek, CA 95685
Re: Gold Rush Ranch DEIR Comments
Dear Ms. Van Voorhis:
The California Oak Foundation (COF) appreciates the opportunity to
comment on the Gold Rush Ranch (GRR) DEIR. COF oak woodland review has
identified several DEIR errors of omission and commission, including
failure to analyze substantial carbon dioxide "biological emissions"
due to GRR’s significant impacts to oak resources.
Air Quality
Background: The current carbon dioxide
contribution to global warming is in part a byproduct of mankind's
conversion of the Earth's forest cover to non-forest land use: "In
the last 8,000 years about 45% of the Earth’s original forest
cover has disappeared, cleared mostly during the past century" (Smithsonian 2003). Continuing "deforestation accounts for about 20% of the carbon dioxide spewed into the atmosphere each year" (Wall Street Journal 2008). According to the Intergovernmental Panel on Climate Change, "Carbon
dioxide is the most important anthropogenic greenhouse gas...The global
increases in CO2 concentration are due primarily to fossil fuel use and
land-use change" (2007).
Based on the latest University of California figures (2007), COF
estimates that since 1990 California has converted 325,000 acres of oak
woodlands to non-forest use. This means in California there are
substantially less acres of oak forest to help reduce state CO2
emissions by 2020 to 1990 levels as required by Assembly Bill 32.
Additionally, the escalating deforestation of oak woodlands (25,000
acres annually) will make it that much more difficult and expensive to
meet the AB 32 goal of reducing greenhouse gas emissions to 80 percent
below 1990 levels by 2050.
The California Climate Change Center has reported that "There is
substantial evidence that temperatures in California are projected to
rise 4.7 to 10.5 degrees Fahrenheit by the end of the century [and]
temperatures can increase air quality problems" (2007). A University of California study examining the effects of California temperature increases on blue and valley oaks "found
that the areas of the state where the climate is suitable for these
species to grow will shift northward and could shrink to nearly half
their current size as a result of global warming" (2005). Thus, the
more that oak woodlands are converted to non-forest use, the greater
the rise in California temperatures and the greater the temperature
increases, the faster oaks are extrapolated from the California
landscape.
The peer-reviewed publication "Oaks 2040: The Status and Future of Oaks
in California" (2006) estimates that up to 750,000 acres of oak
resources are at risk of conversion to non-forest use by 2040 and the
companion study, "Carbon Resources in California Oak Woodlands" (2008),
calculates that "California
oak woodlands and forests could sequester a billion tons of carbon
[and] up to 33 million tons of sequestered carbon are at risk [by 2040]
of entering the atmosphere should development processes eliminate these
oak woodlands and forests, and their associated carbon pools."
CEQA, Carbon Dioxide and Climate Change
CEQA requires that the Lead Agency evaluate potential environmental
effects based to the fullest extent possible on scientific and factual
data. In the absence of defined thresholds, significance conclusions
must be based on substantial evidence, which includes facts, reasonable
assumptions predicated upon facts, and expert opinion supported by
facts (CEQA Guidelines §15064).
CEQA review doesn’t require specific CO2 regulations by CARB or
any other state agency; CEQA review requires analysis and proportional
mitigation for "significant
effects on the environment [including] a substantial, or potentially
substantial, adverse change in any of the physical conditions within
the area affected by the project, including...air" (CEQA Guidelines
§15382). The scientific evidence is overwhelming that substantial
CO2 biological emissions will occur from the conversion of GRR oak
woodlands to non-forest use.
DEIR: "The removal of trees and other
vegetation will stop the process of carbon sequestration that this
biomass accomplishes and much of the accumulated carbon in the biomass
will be released into the atmosphere and such releases could occur over
a short time period if the biomass were burned....An estimate of the
total biomass accumulation in trees and other vegetation within the
Project site has not been performed for this analysis. However, the oak
woodlands on the Project site are considered mature, and the net
sequestration is therefore expected to be low."
Comment: COF’s RPF consultants,
certified by the California Climate Action Registry to conduct carbon
sequestration and release analyses, strongly disagree with the GRR low
net sequestration assertion. The DEIR description of a static oak
resource with inconsequential future carbon sequestration from mature,
sapling and regeneration oaks is unsupported by scientific data,
contrary to the California Forest Protocol and inconsistent with the
functional oak woodlands described in the wildlife habitat assessment: "It
is expected that Project construction will result in the removal of
many young or immature native trees less than six inches in
DBH...smaller size trees are an important indicator of woodland health
and the reproductive status of a stand." In addition to the
project’s oak regeneration and smaller trees, the tree inventory
disproves the inference of a declining oak forest, showing good
distribution in all the larger size classes, with over 13 percent of
the trees greater than 16 inches dbh.
The California Forest Protocol was initiated by Senate Bill 812 in
2002, adopted by the California Climate Action Registry in 2005,
incorporated into Assembly Bill 32 in 2006, recognized by Senate Bill
97 in 2007 and approved by CARB on October 25, 2007. This Forest
Protocol designates the conversion of oak woodlands to non-forest use
to be CO2 biological emissions, due to lost oak woodland sequestration
capacity and fuelwood combustion releases. The specific methodology for
measuring oak woodland carbon sequestration or release are described in
the Forest Protocol.
CARB CO2 forest conservation is defined as those "Specific actions
that prevent the conversion of native forest to a non-forest use, i.e.,
residential or commercial development or agriculture." Conversely,
the conversion of oak woodlands to non-forest use represents a
biological emission subject to CEQA analysis and mitigation. The Forest
Protocol establishes the air quality criteria to be used to measure oak
woodland biological emissions for CEQA review: Live tree biomass
(including roots), standing dead tree biomass and wood lying on the
ground.
CEQA CO2 questions to be answered include: (1) how much potential CO2
sequestration over the next 100 years will be lost due to impacts to
live native trees three (3) inches or greater dbh; (2) how much
sequestered CO2 will be released if the live trees, standing dead trees
or woody debris are burned?
DEIR: "Notably, the Project includes
several components that are intended to reduce oak tree/vegetation
loss, promote energy efficiency, and to provide for alternative
transportation (including electric vehicle lanes and bicycle and
pedestrian facilities) within the Project."
Comment: GRR’s proposed tree planting
offers negligible CO2 mitigation value relative to the loss of the
existing oak woodlands. In fact, planted oaks sequester little CO2
until they are at least 20 years old (California Climate Action Team
2008). This point is particularly germane to GRR because slow-growing
blue oak trees will be most impacted by the project. In the parlance of
climate change, it is infeasible for GRR to plant enough mitigation
oaks to be anywhere near "carbon neutral" over a 100-year period.
Project design features that lessen CO2 impacts from fossil fuel use do
nothing to mitigate CO2 biological emissions due to a land-use change
that results in the loss of oak woodland sequestration capacity and CO2
releases from the burning of oak fuelwood. At best, these proposed
measures only moderate the increase in new CO2 emissions; existing oak
woodlands actually reduce CO2 in the atmosphere.
Conclusion
DEIR: "The Project will remove an estimated
403 acres of oak woodland and savanna at full buildout. It is assumed
for illustration purposes that the Project will acquire, in fee or
easement, comparable oak woodlands and savannas for up to 50 percent of
the total mitigation required, and that the other half of the
mitigation will be met through new plantings. Successful implementation
of all three elements of Mitigation Measure 12-2 will reduce Project
impacts on native trees, and oak woodland and oak savanna habitats to a
less than significant level."
The DEIR claim that the proposed mitigation measures reduce oak
woodland effects to less than significant is specious. Moreover, The
DEIR clearly recognized the substantial potential CO2 emission impacts
from the conversion of oak woodlands; then failed to assess lost
photosynthesis due to tree removal or from the burning of GRR oak
resources.
Under CEQA, the only feasible and proportional way to concurrently
mitigate GRR’s significant cumulative oak resource wildlife
habitat and CO2 emission effects is to preserve off site a perpetual
conservation easement equivalent in acreage and ecological function to
the oak resources impacted. COF urges Sutter Creek to adopt the
following single oak woodlands mitigation measure for Mitigation
Measure 12-2:
Condition of Approval to the Project’s Tentative Subdivision Tract Map that Provides:
"Upon the issuance of a certificate of occupancy
for the project, the applicant shall preserve off-site by acquisition
or funding, in perpetuity by grant of conservation easement in a form
acceptable to the Director of Planning to a qualified recipient
approved by the Director of Planning, 350 acres of contiguous oak
woodlands and 50 acres of contiguous oak savanna located within Amador
County, which 400 contiguous woodland and savanna acres shall be
equivalent in ecological function and quality to the oak resources on
the project site."
Until these CEQA requirements are met, the California Oak Foundation
objects to approval of the project and adoption of the DEIR.
Respectfully,
Janet S. Cobb, President
California Oak Foundation
Forest Protocol Key Terms
Biological emissions: For the purposes of the
forest protocol, biological emissions are greenhouse gas emissions that
are released directly from forest biomass, both live and dead,
including forest soils.
Biomass: The total mass of living organisms in a given area or volume; recently dead plant material is often included as dead biomass.
Bole: A trunk or main stem of a tree. For the
purposes of the Protocol, any tree bole with a minimum diameter of
three inches should be included in the inventory to estimate carbon
stocks.
Carbon pool: A reservoir that has the ability
to accumulate and store carbon or release carbon. In the case of
forests, a carbon pool is the forest biomass, which can be subdivided
into smaller pools. These pools may include above-ground or below
ground biomass or roots, litter, soil, bole, branches and leaves, among
others.
References
California Air Resources Board (2008). Climate Change and Forestry in California.
The International Canopy Crane Network (2003). Studying Forest Canopies from Above. Published by the Smithsonian Tropical Research Institute, Panama and the United Nations Environmental Program.
Wall Street Journal (2008). Turning Trees into Money.
Intergovernmental Panel on Climate Change (2007). Summary for Policymakers.
California Agriculture (2007). Research and outreach to prevent woodland loss. Published by the University of California.
California Climate Change Center (Luers and Cayan et. al 2006). Our Changing Climate; Assessing the Risks to California. Published by the University of California.
Proceedings of the National Academy of Sciences (Kueppers, Snyder, Sloan, Zavaleta and Fulfrost 2005). Modeled regional climate change and California endemic oak ranges.
East West Forestry Associates (Gaman and Firman 2006). Oaks 2040: The Status and Future of Oaks in California. Published by the California Oak Foundation.
East West Forestry Associates (Gaman 2008). Oaks 2040: Carbon Resources in California Oak Woodlands. Published by the California Oak Foundation.
California Climate Action Team (2008). Climate Action Initiative.
Announcements
In 2006, the California Legislature passed Assembly Bill 32, the Global
Warming Solutions Act, which requires the State to adopt a greenhouse
gas (GHG) emissions limit equivalent to 1990 levels by the year 2020.
As part of this process, our esteemed colleagues at the Forest
Service's Center for Urban Forest Research have been working with a
dedicated group of stakeholders over the past two years to draft the
Urban Forest GHG Protocol to help meet the target of 169 million metric
tons (Mt) per year. Tree planting is a viable strategy, with 50 million
new trees estimated to reduce carbon dioxide by 6.3 Mt, or 4% of the
state target.
The Protocol has been posted for public comment at the California Climate Action Registry's website. Written comments should be submitted to policy@climateregistry.org by 5pm on August 4, 2008.
Additionally, a public workshop is being held on Tuesday, July 29, 1 - 4pm to discuss the protocol and answer questions:
Byron Sher Auditorium
Cal/EPA Headquarters Building
1001 "I" Street (2nd Floor)
Sacramento, CA 95814
Merchandise
The Life of an Oak by Glenn Keator,
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California Oak Foundation (1998), takes an intimate look at all aspects
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spread around the world of this remarkable, diversified family. 256
pages, 75 full-color photographs, 30 full-color illustrations, 21 black
and white diagrams. Paperback $17.95, Members $16.16 plus local tax,
shipping and handling.
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