The California Oak Foundation has submitted commentary that challenges the validity of the Gold Rush Ranch and Golf Resort’s DEIR analysis of carbon dioxide emissions that will result from the partial deforestation of the site. The Draft Environmental Impact Report describes its blue/interior live oak resources as covering 700 acres, or 70% of the property. The population of trees measuring six inches in diameter and larger is 31,600, and 13,375 trees, or 42%, will be removed during development, including 1,950 trees that have a diameter of greater than 16 inches. According to the COA, “deforestation accounts for about 20% of the carbon dioxide spewed into the atmosphere each year.” Further, “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 commentary goes on to state that the Gold Rush DEIR assertion that “the net sequestration (of Carbon Dioxide) is expected to be low” due to the relative maturity of the site’s oak woodlands, is “unsupported by scientific data, contrary to the California Forest Protocol and inconsistent with the functional oak woodlands described in the wildlife habitat assessment.” The commentary also says that the DEIR’s findings relative to the analysis of mitigation measures for CO2 emissions as required by the California Environmental Quality Act are insufficient, “In the parlance of climate change, it is infeasible for Gold Rush Ranch to plant enough mitigation oaks to be anywhere near carbon neutral over a 100 year period.” In the document’s conclusion, the COF makes the suggestion that City of Sutter Creek adopt the following single oak woodlands mitigation measure: “Upon the issuance of a certificate of occupancy for the project, the applicant shall preserve off-site by acquisition or funding, in perpetuity…350 acres of contiguous oak woodlands and 50 acres of contiguous oak savanna located within Amador County…” The document finishes with the sentence, “Until these CEQA requirements are met, the California Oak Foundation objects to approval of the project and adoption of the DEIR.”