October 22, 2003

Mary Jane Fagalde
Kyrsten Shields
Community Development Department
255 North Forbes Street
Lakeport, CA 95453

Dear Ms. Fagalde:

I have reviewed the pertinent parts of the Project, and have the following comments.

Lake County has passed a resolution (Resolution 95-211) recognizing the existence of numerous land use activities that threaten the survival of oak woodlands in California, and in Lake County in particular. Those threats, as Lake County itself has identified, include urban development, fuel harvesting, and intensive agriculture. Intensive agriculture includes vineyard conversions, such as the Project. Recognizing these threats to the survival of California's oak woodlands, Lake County has resolved to document the remaining oak woodlands as a means to monitor and protect them. Approval of large-scale destruction of oak woodlands, as proposed in the Project, is inconsistent with the County's stated goals.

The Project will remove at least 1,100 oak trees during development of 130 acres of vineyard associated with the Project. Oak woodlands that include mature trees and a range of age classes are increasingly rare in California, and provide an exceptionally diverse ecological community. Replacing such woodland with planted acorns cannot be scientifically justified as adequate mitigation for destruction of the woodland.

The Project’s impact can only be properly evaluated when a site-specific evaluation of distribution of tree size, age, density, and diversity are considered. The Project application does not give any site specific information with respect to the oak woodlands that will be destroyed.

In addition, the cumulative impacts this vineyard development project will have on the remaining oak woodlands in the region has not been properly described or evaluated. No mitigation in this mitigated negative declaration has adequately addressed the loss of significant oak woodland.

Vineyard conversions are irreversible. The conversion process eradicates virtually all native organisms through deep ripping of the soil, and soil fumigants designed to sterilize the soil. Since oak woodlands profoundly affect the variety and abundance of California’s wildlife, such irreversible conversion should be carefully considered before being approved.

The destruction of oaks at the scale proposed by the Project significantly compromises the opportunity for oaks in the region to withstand the threats to their survival, some of which have been outlined above. Impacts associated with the Project’s clearing operation on the remaining oak woodlands in this region and in California be will be significant.

For the County to act in a manner consistent with its stated policy goals, it must not permit the destruction of this woodland for vineyard until such time as the full impacts have been evaluated and adequate mitigations, if they exist, are required.

I believe that the County must require a full environmental impact report (EIR) before approving this project. A mitigated negative declaration is irresponsible, inconsistent with County policy, and possibly illegal.

Thank you,

Pamela Muick, Executive Director, California Native Plant Society