First Name | Joshua |
---|---|
Last Name | Buswell |
Email Address | josh@forestethics.org |
Affiliation | ForestEthics |
Subject | Commens on Forestry Section in Proposed Scoping Plan |
Comment | Re: ForestEthics Comments on Proposed Scoping Plan ForestEthics appreciates the opportunity to provide comments on the Proposed Scoping Plan (PSP) for meeting the goals of AB 32. We will be limiting our comments to the PSP’s section on forestry. We are grateful that the Air Resources Board (ARB) is including a section on forestry, as this is an often overlooked, but incredible important component toward meeting our state’s commitment to solving the climate crisis. As is acknowledge in the scoping plan, deforestation accounts for 20% of global greenhouse gas emissions. We believe the goal of maintaining the current 5 MMTCO2E is certainly doable and would urge ARB to set an even more robust target moving forward. We would also urge the following recommendations: 1). Shift the emphasis towards measuring average carbon stocks in a forest instead of rates of uptake and release. With limited funds, trying to account for the rate of carbon uptake or release is not the most judicious use of taxpayer dollars and is irrelevant. Rates of uptake and release are of less concern from a carbon perspective than the average amount of carbon the forests is storing. For example, if one cuts an old growth forest and replaces it with a sapling, there may be faster growth from the sapling after several years. However, the forest is still in a carbon deficit due to the logging of the old growth forest that had years and years of accumulated carbon. To emphasize throughout the PSP the rate at which California’s forests are growing is less relevant than how much carbon these forests are maintaining on average. Until there is accurate accounting of average carbon stocks, ARB will not be able to tell whether California’s forests are even meeting the goals of AB 32. 2). Reduce the PSP’s emphasis on fire emissions There is no question that communities should be protected from wildfires and studies by the Forest Service have shown that logging within 100 feet of a home to reduce fuel loads from brush and small trees can protect property. However, from a carbon perspective, the more important point is that focusing on fires once again puts the emphasis on rates of carbon release instead of overall carbon stores for unless the forested area never grows back, the carbon will be reabsorbed. Additionally, just because a forest burns, even a high intensity fire does not translate into immediate and total carbon losses, and as the wood decays, rigorous post fire growth recovers much of the carbon that is lost. 3). Encourage and create incentives for landowners to produce multi-aged and diverse forests Appendix B says, “There are significant opportunities to increase the carbon storage on managed forest lands over the next few decades by increasing forest growth through healthy and fully stocked stands that utilize site potential for growth while resisting or minimizing emissions from fire, insects and disease.” (C-169) There is no guarantee that vigorous tree growth will result in stands better able to withstand fire, insects and disease. In fact, the California Climate Change Center with staff from Berkeley and Cal EPA said of global warming, “Monodominant stands are at most risk. Designing diverse forest structures with multiple species where appropriate alleviates some risk associated with even-aged, single-species stands. A spatially mixed forests limits the spread of both pathogens and insects.” The same study showed that pine plantations would also face a 31% reduction in yield due to global warming as compared to 18% for mature forest stands. The science is also quite clear that certain logging methods release more carbon than others. For example, clearcutting releases more carbon than any other forest disturbance, including fire. Yet, the closest forest management prescription the PSP will make is encouraging “sustainable forestry practices.” Indeed, where the PSP says, “Providing incentives to developing countries to help cut emissions by preserving standing forests, and to sequester additional carbon through the restoration and reforestation of degraded lands and forests and improved forest management practices, will be crucial in bringing those countries into the global climate protection effort,” could no doubt apply to our own state as well. 4). Shift away from encouraging biomass until proper accounting is done that ensures it is carbon negative It may be possible that biomass may help to reduce carbon emissions, but there must be transparent and rigorous accounting that considers all elements of the energy production including transportation, milling, and logging before it is regarded a worthwhile solution. 5). Make sure reforestation and afforestation is scientifically sound. Reforestaton and afforestation are important, but ARB must ensure credit is only given for genuine carbon reductions. For example, the science is far from clear that salvage logging and replanting post fire is a carbon benefit. To give credit carte blanche for such activities will not necessarily result in carbon gains. We appreciate the opportunity to comment on this historic piece of legislation. Joshua Buswell Sierra Campaigner, ForestEthics 1 Haight Street San Francisco, CA 94114 415-863-4563 ext 328 |
Attachment | www.arb.ca.gov/lists/scopingpln08/661-comments-scoping_plan-forestethics.doc |
Original File Name | Comments-Scoping Plan-ForestEthics.doc |
Date and Time Comment Was Submitted | 2008-11-19 18:46:10 |
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