“…it will be necessary for the Planning Commission and Board of Supervisors to provide a Statement of Overriding Consideration for every significant and unavoidable impact associated with any approved element of this project (see Attachment 6 for a list of significant impacts that cannot be mitigated below significance). This statement must identify, in writing, the specific reasons to support its action (i.e., approval), based on the FEIR and/or other information in the record. This Statement of Overriding Considerations, which must find that specific economic, legal, social, technological, or other benefits of the proposed project outweigh the unavoidable adverse environmental effects, must be supported by substantial evidence in the record. This is in addition to any findings, mitigation measures, and conditions of approval attached to the approvals for this project.”

2.12.09 Planning Commission Staff Report, p. 25-26

  1. Bullet “Smoke and Mirrors” The public debate shifted in November 2007, when the Board of Supervisors voted to revise the Trinitas Draft EIR and evaluate the environmental impacts of building the golf course on Agricultural Preserve land. Since then, the applicants have tried to redirect the public’s attention to the jobs and tax revenues they claim will accompany full project approval. However, as indicated in the Staff Report, CEQA demands that such claims are backed by “substantial evidence.”  The Cirian Villavicencio report*  – “Trinitas - An Essential Investment to Calaveras County’s future” – fails to meet this standard.

*Included in Planning Commission Comments Exhibit 1, pages 19-42

  1. Bullet The applicants have failed to provide a realistic cost/benefit economic analysis. “…if you are dead set on pushing this project forward, it would be prudent to complete an economic and fiscal analysis of the project to assess its alleged benefits. Many golf course centered developments have been unsuccessful in the foothills and elsewhere in California. Other rural communities considering such developments, including Jackson and Sutter Creek, have benefited from such fiscal analyses. For example, the analysis done in Sutter Creek alerted the City to the need for long-term future Mello-Roos payments. Without those, the project did not yield sufficient City revenues to cover City costs.”

Comments by Tom Infusino to the Planning Commission, 2.19.09, (Exhibit 7, p.1)

Examples of such studies were provided  in Exhibit  7B

  1. Bullet Trinitas will not provide “economic benefits” sufficient to overcome 12 significant and unavoidable negative environmental impacts. “Costs are underestimated. Fees and revenue are overestimated. Golf play is overestimated. Revenue will be drawn from existing Calaveras County courses. Based on these facts, it is impossible to conclude that there will be benefits that outweigh the significant adverse environmental impacts. In public the developer has circulated grossly inflated figures that make unrealistic assumptions about market conditions, overestimate benefits, and ignore adverse impacts on existing golf courses. That shallow analysis cannot be allowed to justify approval of the project.”

Planning Commission Exhibit 21 2.19.09 by KIRC attorney Mark V. Connolly

  1. Bullet Golf courses throughout the state are experiencing hard times. Established golf courses with all the amenities are closing, and private clubs are offering public play at low green fees to keep their doors open. It’s unrealistic to assume a new golf course will immediately be profitable in today’s market and economy.

See Planning Commission Hearing Exhibit 15, for news articles on troubled golf courses

  1. Bullet Public benefits cannot be viewed in a vaccuum, without analyzing COSTS to the developer (in mitigations, operating expenses, and debt repayment), the neighbors (in failing wells, traffic accidents and loss of rural way of life), to the County (in staff time, infrastructure maintenance and improvements and services), and to county taxpayers (in traffic slowdowns or bond measures or assessments for infrastructure improvements not implemented because resources were diverted to support a private resort inexplicably approved far from public sewer, water and services.)

  2. Bullet The Trinitas Final EIR lists 73 mitigation measures, many with multiple elements, addressing significant or potentially significant adverse impacts on the environment and the community. According to CEQA, a “Statement of Overriding Considerations” does NOT overcome the developer’s obligation to implement all feasible mitigation measures to lessen the environmental impacts of a project.  Many of the 73 measures listed have significant costs attached, and must be accomplished before any new construction begins, within specified time frames, to the satisfaction of the county, state and federal regulatory agencies responsible for approving or denying the permits necessary to meet conditions of project approval. The applicants do not factor these costs into their analysis.

See Staff Report Appendix 2 - Final Mitigation Measures

  1. Bullet The hidden costs 

  2. • Where is the accounting for the irreversible loss of productive agricultural land likely to result from this leapfrog development?

  3. • Who calculates the cost of turning your back on the County’s “Right to Farm” ordinance?

  4. • What is lost when county Land Use Designations become meaningless, and cease to protect homeowners or inform developers about location-specific opportunities or prohibitions?

  5. • What public benefit is created by unilaterally changing the character of a community without its consultation or consent?

  6. • What will it ultimately cost the County and its citizens to reward the unrepentant violation of  county, state and federal laws in furtherance of a speculative private enterprise?

  7. Bullet A private membership golf club isn’t a public golf course, and isn’t a public benefit. The applicants and those who buy $50,000 memberships enjoy the “benefits,” not the general public. An “event facility” doesn’t belong on Natural Resources Land in an area deficient in road and water infrastructure. The costs of approving any part of this project will far outweigh its economic benefits.


This page is still under construction. More soon.

Overview     Legal     Water     Traffic   Agriculture    Biological/Other    Events/Noise    Services    Economic

Economic Impacts

Masthead photo:

Golfers playing the course in September 2007, after the applicant had been warned that it was not a permitted use under current zoning. Since June 2008, neighbors report regular golfing activity, often on several consecutive days. The applicant acts as if the course has already been approved.

Notable Quotes from

Golf Course Appraisal


  1. Bullet “…a percentage of play at Trinitas will be the result of cannibalization from other courses in the market, not newly created play;…”

  2. Bullet “Typically a new entry in the market will draw play from older existing courses in the area, more so than developing additional tourism in an area…much of the play at Trinitas will be taken away from…La Contenta, Saddle Creek, Greenhorn Creek…”

  3. Bullet “This will also be the case for spending;

  4. Bullet “Green fee estimates are unrealistic, based on regional data for this type of property.…Most courses in this region have average green fee revenue per round of $35 to $50.…very few courses in the state…generate green fee revenue per round in the $125 range.”

  5. Bullet“…operating expenses…are grossly underestimated…expenses for golf courses in this region generally ranges from $2.5 million (for very austere courses) to over $4.0 million (for higher quality venues.”

  6. Bullet “The daily spending per guest, in addition to green fees, of $200 to $500 is grossly overestimated.…the $9.6 million per year figure appears extremely high and unsupported by market data.”

  7. Bullet “the assumption is made that 12,000 to 24,000 rounds can be achieved at the golf course.…the lower level is realistic, with the upper level questionable, and only attainable after several years of operating and marketing…

  8. Bullet“A successful daily fee course in this portion of the state must play from 35,000 to 40,000 to reach a break even point from operations

Ron Carciere, MAI, SGA, Golf Course Appraisal, Feb. 18, 2009 report to Planning Commission  

(pages 15-22 of Exhibit 21)

    “The applicants chose to risk their own, and presumably other people’s money, to build a golf course where it didn’t belong.

    Now they expect the neighbors and the County to bail them out and “correct” their error by approving a zoning adjustment to Recreation with the express goal of making the illegal golf course legal. This would only create more conflicts down the road.

    The Final EIR and the Staff Report agree that the golfing facilities and special events are incompatible with the surrounding uses. If anyone deserves a little overriding consideration today, it’s the neighbors who for years have begged the County to stop this area-changing project

and been repeatedly disappointed. We are looking to you as leaders to have the courage and wisdom to recognize where the greater public benefit really lies in this unique situation, and recommend the “no project” alternative.”

2.19.09 Comments to the Planning Commission by Kathy Mayhew, KIRC

Copyright 2009 - Keep It Rural Calaveras (KIRC)

Unless otherwise noted, all photographs are the property of KIRC.

Documents were obtained from Calaveras County under the Public Records Act, and from cited news sources.