Comment Log Display

SOCIETY FOR CONSERVATION BIOLOGY
COMMENTS ON THE PROPOSED
CALIFORNIA CAP ON GREENHOUSE GAS EMISSIONS
AND MARKET-BASED COMPLIANCE MECHANISMS

December 15, 2010


The Society for Conservation Biology is a global network of nearly
10,000 conservation professionals with policy leaders drawn from
all continents on the globe and numerous disciplines relevant to
conservation science and practice. Over half of our members are
from the United States, however, and a large portion of our policy
work is focused on the conservation of the American West.

Our top priority issue since early 2007 has been climate change and
we have submitted testimony, comments and other papers in Federal
and international proceedings. 

Our North America Section President, Dominick DellaSala, joined by
several other senior members and staff of SCB and others coauthored
a groundbreaking book demonstrating the heretofore
under-appreciated carbon storage services of temperate rainforests
such as exist from northern California to Alaska.  Our letter to
Cancun cites this research and related studies.  We also cite Dr.
DellaSala’s testimony to the U.S. House Committee on Natural
Resources on the management of public lands with regard to climate
change.

Our Policy Director participated this September in workshop of
scientists and policy makers, including senior officials of
California, at the University of California at Davis’ John Muir
Institute of the Environment, which is headed by a former board
member of SCB, Professor Mark Schwartz.  The workshop focused on
greenhouse gas sequestration effects of different ecosystems in
California and in areas that may be included in your cap and trade
system.  The scientists issued a succinct statement noting the very
substantial and in some cases, surprising, capacity of grasslands,
marine marshes and kelp forests, and forests of different sorts to
sequester greenhouse gases if managed properly and protected from
excessive anthropogenic stresses.

 	We are submitting these comments and attachments today by way of
your web-based form  as our comments on your proposed cap and trade
regulations as we believe you will find these submissions useful in
your consideration of the California draft rules -- Subchapter 10
Climate Change, Article 5, Sections 95800 to 96022, Title 17,
California Code of Regulations, (--:  Article 5: CALIFORNIA CAP ON
GREENHOUSE GAS EMISSIONS AND MARKET-BASED COMPLIANCE MECHANISMS).

We are submitting our letter to the conveners and delegates of the
UNFCCC Conference of the Parties in Cancun, which references our
letter to the COP in Copenhagen, both of which cited recent
research that should directly help to shape your regulations. These
are available also at www.conbio.org/resources/policy.

A fundamental point of our letters and testimony is that
governments have an obligation to require the most rapid reduction
possible in human-caused greenhouse gases and other forcing agents,
such as black carbon or soot, and to combine that with bio-diverse
ecosystem conservation and restoration.  Nothing short of the
combination will be likely to avoid highly dangerous climate change
and accelerating losses in biodiversity and ecosystem service. 

The second point is that these mitigating steps should not be
undercut by reliance upon offsets when any other approach is
available. Otherwise, the heat and drought and other climate driven
stresses threaten to repeat the experience of the Amazon which in
the drought of 2005 tipped for one year to not only fail to
sequester its usual 2-3 billion tons of CO2, but to become a source
of carbon nearly as large, with a net loss in planter sequestration
as large as the European Union and Japanese emissions combined.  US
forests are also stressed and the California system must take that
into account dynamically in its approach.

In the US system, states have the greatest array of tools available
under our Constitution – from common law to legislation to protect
public health using all of the powers not preempted by the Federal
government, and in fact, California is the prime example of a state
that uses its freedom to lead and help other states join in the
process, even when the Federal government is far behind in
controlling air pollution.  We hope that you will protect and
exercise those powers and stand ready to help you do that in the
future as we are today with the attached submissions.

Thank you.



John M. Fitzgerald
Policy Director