The Project poses significant  air and noise pollution risk to local communities that are already suffering from high pollution rates from other industries and port operations, not the least of which are petroleum and biofuels refineries and already existing biomass and fossil gas burning power plants. These impacts come with associated health risks. Some of the communities where project components will be sited are also highly impoverished. 

The Tuolumne wood pellet production site has a higher-than-average pollution burden and high rates of asthma and cardiovascular disease. The proposed wood pellet production facility will only exacerbate these harms, given that such operations emit toxic and hazardous air pollutants  linked to increased rates of premature death and serious illnesses such as cancer, respiratory diseases, and heart disease. Further, trucks will be needed to deliver wood to the mills, causing noise and diesel pollution in the communities they pass through.

The proposed inland port location of Stockton is a low-income community of color that suffers some of the greatest pollution burdens in California, including high exposure to particulate matter. The transport and shipping of wood pellets from GSNR’s facilities through Stockton  – by truck and/or rail and ocean-going vessels – would worsen the community’s exposure to PM and NOx. An estimated 40-48 truck trips/day or over 7,000 rail cars/year, or any combination of the two, would be used by GSNR to transport material to the port. 

Further, the storage of wood pellets in Stockton poses a serious fire hazard to residents.  Wood pellet piles are prone to spontaneous combustion, with fires and explosions erupting at pellet storage locations in at least five states. In 2017, a wood pellet storage silo in Port Arthur, Texas, caught fire and burned for more than 100 days, sending many local residents to the hospital.  

Inadequate stakeholder engagement

Throughout the environmental review process, GSNR has failed to engage with impacted stakeholders – most notably, the communities near the Port of Stockton where the wood pellets would be stored and exported.  GSNR’s first Notice of Preparation (NOP) proposed that the wood pellets travel through two ports: the Port of Richmond and the Port of Stockton. However, GSNR failed to directly engage with either Port community during the initial scoping process. This, combined with community opposition and a lack of interest from the private port terminal operator in Richmond, led GSNR to drop Richmond from the proposal and to issue a new NOP focused solely on Stockton. However, GSNR has continued to ignore opposition from the Stockton community and to exclude the community from the decision making process. Indeed, as of November 2023 GSNR has not held any sort of community outreach meeting with Stockton residents.

Poor working conditions

Working conditions for forestry service workers are incredibly dangerous, with forestry services and logging suffering the highest fatality rate of any major industry in California. Research and news articles have also revealed allegations of worker mistreatment, including wage theft, by forestry companies. Forestry workers in California have increasingly been migrants who suffer from poor job quality and who often work for private contractors that are difficult to trace. However, GSNR does not seem to care about these issues. For example, recently, GSNR unsuccessfully requested that California’s governor veto state legislation requiring a prevailing wage for forestry workers. 

Wood pellets are a highly carbon-intensive, polluting, expensive, and inefficient energy source. Burning wood to generate electricity produces more carbon emissions at the smokestack than coal per unit of electricity produced. Greenhouse gas emissions and air pollution would be emitted at every step of the project—from cutting forests, producing pellets, transporting pellets, and burning them at smokestacks. This Project could incentivize a massive ramp-up of logging of California’s forests, releasing their stored carbon and preventing them from sequestering carbon in the future at a time when forests are critical to combating climate change.

The Project poses a severe threat to California’s forest ecosystems due to its creation of ongoing demand for logging to produce one million tons of wood pellets per year. GSNR initially suggested that it would only use dead wood, forest residues, and other waste materials to make pellets, thus strengthening forest resiliency against wildfires – a problematic activity which has been criticized. However, GSNR has since broadened its sourcing plans to include any type of tree of any size within a 100-mile radius of each pellet facility. This includes 18 of California’s national forests and treasured places like Yosemite National Park, Lake Tahoe, Mono Lake, June Lake, Mammoth, Lassen Volcanic National Park, Mount Shasta, and Shasta Lake. GSNR anticipates relying heavily on roundwood (i.e., whole trees)  to make pellets. This type of intensive logging results in the destruction and fragmentation of forest habitats, soil compaction, and water pollution, among other impacts. This will also negatively impact sensitive and endangered species located in these forests.

This Project would divert political resources and public attention from the pressing need to reform industrial forestry practices in the state in a manner that conserves ecological functions and processes while increasing the long term capacity of the landscape to provide climate stability. The project  is currently creating a policy distraction that reduces attention on known solutions to create equitable economic opportunity implementing necessary actions designed to protect communities from extreme wildfire behaviours. If GSNR intends to support rural communities in California facing wildfires that could impact their health and safety, putting political and technical capital into aggressive logging and wood pellet production is a distraction away from proven fire-safety solutions focused on homes and communities.

Furthermore, the governance of GSNR provides possible investors some reasons to pursue serious due diligence. GSNR is essentially an offshoot of an organization called Rural County Representatives of California (RCRC), a grouping of county officials from the rural regions of California. Interestingly enough, RCRC is also the entity that formed the Golden State Finance Authority (GSFA), a ‘joint powers authority’ that provides a vehicle for advancing multi-jurisdictional projects within the state. GSFA had made an original $10 million dollar loan as ‘seed capital’ to GSNR. GSFA also has assumed responsibility as the ‘lead agency’ overseeing and managing the environmental review of the GSNR project. In this way, the agency responsible for environmental review also has a financial stake in the project that it is assessing. GSFA has made another loan to GSNR since the environmental review process was initiated, as the financial state of GSNR in 2023 is not that strong.  It’s worth noting that the only way for GSFA to recoup the millions it has loaned GSNR is if the project goes through a successful CEQA review.  At this stage we have calculated that GSFA has provided nearly $12 million worth of loans to GSNR.