|
|
 |
|
|
|
|
November 2006
California Oak Report
COF Opposes Tehama County’s Plan to Destroy 100,000 Oak Trees
On November 17, 2006 the California Oak Foundation filed a lawsuit against the Sun City Tehama subdivision near Red Bluff on grounds the Project has not complied with the Oak Woodlands Conservation Act (SB 1334) enacted into state law in 2004. The Project proposes to destroy 774 acres of oak woodlands containing nearly 100,000 oak trees. The County’s Final Environmental Impact Report recognizes this loss of oak woodlands as a significant adverse impact despite the fact that the Project will protect 1,397 acres of oak woodlands through a conservation easement. Tehama County did not require any additional measures to mitigate the loss of the 774 acres of oak woodlands based on the County’s view that the Oak Woodlands Conservation Act does not require full mitigation of significant impacts on oak woodlands. This is an important case for the COF because the County’s view provides less protection to oak woodlands than to other resources, thereby defeating the purpose of the Act to provide greater protection to oak woodlands than they previously received.
Oaks 2040 Online
The Oaks 2040 summary is now available online (hard copies available for $6.00 including tax, shipping and handling). Oaks 2040 is based on objective oak data and is designed to serve local and regional decision makers in oak woodland planning and the development of conservation strategies. COF members will receive one free copy in the mail.
Oaks 2040 builds upon a statewide map of oak distribution and inventory created by state and federal researchers by adding new layers of oak information. The results are comprehensive regional analyses of forest structure and oak types, including regional and county oak inventory summaries. By evaluating these new maps and inventories against current State of California economic growth projections, Oaks 2040 identifies the location and extent of oaks most at risk of development.
Note: Use of State Development Standards most likely means the Oaks 2040 projection of 750,000 acres of California oak woodlands at risk of development in the next 35 years is conservative. Forthcoming studies using alternative criteria may reflect much greater impacts to regional and rural oak woodlands because of poorly-planned development.
Professional Oak Woodland Assessments
Summary: The oak health and tree form criteria used by arborists reflect values germane only to human habitation; they have minimal import for California Environmental Quality Act (CEQA) oak habitat assessments or the development of feasible and proportional mitigation. Professional oak woodland evaluations do not base CEQA biological evaluations on the national standards of the Council of Tree and Landscape Appraisers or International Society of Arboriculture. California has its own standards for oak woodlands habitat review.
October 16, 2006
City of Rocklin
Planning Division
3970 Rocklin Road
Rocklin, CA 95677
Re: Sierra College Center DEIR
Planning Division:
The California Oak Foundation (COF) appreciates the opportunity to comment on the Sierra College Center draft EIR (DEIR) oak woodlands planning. COF review finds that the DEIR doesn’t provide any oak habitat mitigation and after various Oak Tree Preservation Ordinance guideline "incentives" and "discounts" are factored in, just a fraction of the oak trees removed will actually be mitigated:
1. The DEIR is biased against Sierra foothill old growth oak trees and woodlands, which are the most biologically valuable. For example, 73 living oaks are classified as "hazardous or dangerous" and another 133 trees were deemed in "poor" health; only 6 oaks (1%) are rated as being in the best quality health. Notably, these supposedly decrepit oaks, nearly half the trees, require no mitigation under the Ordinance.
This bias is further demonstrated by the arborist assessment that of 382 removed trees, 181 are considered healthy, while 201 trees were found to be unhealthy. The fitness standards used to denigrate the value of old growth oaks fail to recognize that these "unhealthy" qualities are what provide sustenance for many resident and migrating wildlife species. The ability to survive hundreds of years with tree decadence is oaks greatest habitat value.
2. The Ordinance fails to protect critical advanced oak regeneration under 6 inches diameter at breast height. The arborist report notes, "There are many young Oaks on this property that have a DBH smaller than 6" but are much larger than a seedling. The ordinance does not protect these trees yet they would be rated a 5 [highest] if it did." With only 6 oaks on-site carrying the highest rating, it makes no sense that advanced oak regeneration of equal value is left unprotected and unmitigated.
3. The DEIR contention that the proposed mitigation measures "would reduce long-term impacts to native oak trees on the project site to a less-than-significant level" is absurd. Let’s review: The Ordinance doesn’t mitigate for removal of old oaks or regenerating oaks, requires no mitigation for multiple trunk oaks 6 inches or more in diameter and then further reduces mitigation by adding unwarranted incentives and discounts. In reality, another 10 acres of dense old growth Interior live oak woodlands will be lost forever in Placer County and mitigation for the lost oak habitat values is negligible.
Sincerely,
Janet S. Cobb, President
California Oak Foundation
Professional Oak Planting Mitigation
Where the planting of oaks is chosen as a California Environmental Quality Act mitigation measure, the following professional planning standards must be part of an oak planting mitigation plan:
1. The specific locations and protections for planting oaks on-site or off-site that will ensure oak woodland habitat mitigation over time.
2. An oak planting mitigation plan consistent with the standards established in the 2004 University of California publication, Regenerating Rangeland Oaks in California. Planted oaks must be monitored and maintained for at least seven years.
3. An annual oak planting mitigation monitoring and maintenance report.
4. An estimation of the total costs associated with oak planting mitigation.
5. A posted bond to ensure oak planting mitigation compliance.
True Then, True Now
With the recent conclusion of the 6th Oak Woodlands Symposium we look back on a finding from the initial 1990 oak conference, Proceedings of the Symposium on Oak Woodlands and Hardwood Rangeland Management. Revisited are the negative aspects associated with on-site oak woodland conservation easements for California Environmental Quality Act (CEQA) mitigation purposes.
Disadvantages of On Site Conservation Easements
In most cases, these mitigation measures involve the dedication of [on site] land as an open space easement. The disadvantages with this process are that open space easements may end up as "postage stamp preserves" rather than biologically viable habitats. Such preserves are inefficient and poorly able to protect woodland resources in perpetuity and they are likely to be affected by impacts from the surrounding developed uses and by an inability to control illegal activities.
Postage stamp preserves result from the fact that the creation of open space easements are often the result of political decisions rather than biological tenets. The area of an open space easement is frequently a compromise between the desires of an applicant, the staff recommendation, and the tolerance of the political decision makers.
Finally, the fire management issue can be a problem. Placement of open space easements within a subdivision or some other type of development creates a potentially hazardous fire condition. Fire protection requirements and areas to be cleared around structures are under the control of fire protection agencies. Such developments may eventually degrade the woodland resource due to the need for fire controls at a later time (Oberbauer 1990).
Merchandise
A Field Guide to Insects and Diseases of California Oaks, written by Ted Swiecki and Elizabeth Bernhardt, published by USDA. This publication focuses on the relatively small number of microorganisms (primarily fungi) and arthropods (primarily insects) that are capable of causing noticeable damage to oaks in California. These books have been donated to COF by USDA and we offer them free of charge. Soft back, full color, 151 pages. Media Mail shipping and handling will cost $2.50 each. First-class shipping and handling on request will cost $5.00 each. One free book per request, limited to stock on hand. Mail-in form or call 510/763-0282 with VISA or MasterCard.
New to Our Website
Acorns and Eat’em by Suellen Ocean, published on-line by California Oak Foundation. Includes complete acorn leaching instructions, nutritional information and 35 acorn recipes (illustrated) as well as interesting historical oak and acorn trivia. Free download in PDF format. 50-pages -- print in landscape orientation for most efficient use of page, and bon appetite.
|
|
|
|
|
|
|
|
[Home] [Current_Issues] [Conservation] [Oak_Tree_Care] [How_To_Help] [Links] [Reference] [Newsletter] [Merchandise]
1212 Broadway, #842 Oakland, CA 94612 Tel. 510-763-0282
Fax: 510-208-4435 oakstaff@californiaoaks.org
|
|
