First Name | Laurie & Allan |
---|---|
Last Name | Williams/Zabel |
Email Address | williams.zabel@gmail.com |
Affiliation | Citizens Climate Lobby & as Individuals |
Subject | Comment Regarding Compliance Offset Protocol Urban Forest Projects |
Comment | Urban Forest Protocol – Summary of Evidence AB 32 Offsets Challenge – Public Comments on October 19, 2011 Laurie Williams and Allan Zabel, as individuals and as volunteers for Citizens Climate Lobby Summary of Evidence that Proposed Greenhouse Gas Offset Protocols and Regulations do not meet the AB 32 Integrity Criteria Standard in Protocol: The proposed Urban Forest Protocol would provide offset credits for urban forest project that meet the description of such a project and are by or for a municipality, educational institution, or utility. This is contrary to the AB 32 Integrity Criteria -- the requirement that all emission reductions meet the following criteria (See Section 38562(d)): AB 32 Integrity Criteria: “(d) Any regulation adopted by the state board pursuant to this part or Part 5 (commencing with Section 38570) shall ensure all of the following: (1) The greenhouse gas emission reductions achieved are real, permanent, quantifiable, verifiable, and enforceable by the state board. (2) For regulations pursuant to Part 5 (commencing with Section 38570), the reduction is in addition to any greenhouse gas emission reduction otherwise required by law or regulation, and any other greenhouse gas emission reduction that otherwise would occur. Evidence of Failure to Meet Integrity Criteria 1. Any Net Tree Gain: In the Protocol, the ARB establishes the standard for additionality as any net tree gain. This ignores the creation and maintenance of urban forests by municipalities as ongoing activity which have occurred and are still occurring without an offset incentive. a. San Francisco Urban Forest Program: “This year marked the completion of the Mayor’s Trees for Tomorrow campaign to plant 25,000 trees over a 5-year period. The successful program exceeded its goals by planting 26,408 trees in 5 years. Averaged over the course of the Mayor’s Trees for Tomorrow initiative, the City has been meeting the Urban Forestry Council’s goal of planting 5,000 trees per year for each of the past five years. Additionally, San Francisco Unified School District began its 2012 by 2012 campaign to plant 2012 trees by the end of 2012.” See Attachment 1, p.1. b. Los Angeles One Million Tree Program: “ Mayor Antonio Villaraigosa of the City of Los Angeles has charted a course for sustainable growth, and the region’s community forest is a critical component of that vision. In September 2006, the mayor announced his plan to plant one million trees over the next several years. The Million Trees LA initiative draws attention to the importance of urban forests for the economic, environmental , and social health of Los Angeles.” See Attachment 2, p.1. c. New York City One Million Tree Program: “New York City, the largest city in the United States and one of the world’s major global cities, maintains trees as an integral component of the urban infrastructure (Figure 1). Since 1995, over 120,000 trees have been planted along the streets of the city’s five boroughs.” See Attachment 3, p.1. 2. Urban Forests are Cost Effective for Municipalities: Several studies show that the creation and maintenance of urban forests creates numerous environmental benefits for municipalities and creates economic benefits greater than the costs associated with the urban forest programs. Therefore, these activities are almost certain to continue occurring without an offset incentive program. a. City of Berkeley: “Total annual benefits produced by Berkeley’s street and park trees were estimated to have a value of $3.2 million, about $89 per tree and $31 per resident. Street trees produced benefits valued at $2.8 million ($91/tree, $27/capita), while park tree benefits were valued at about $433,000 ($76/tree, $4/capita). Over the same period, tree-related expenditures were estimated at nearly $2.4 million. Net annual benefits were therefore calculated at $876,000, or $24 per managed tree. The Berkeley municipal forest returned $1.37 to the community for every $1 spent on management.” See Attachment 4, pp. 23-4. b. New York City: “Over the years, the city has invested millions in its urban forest. Citizens are now receiving a return on that investment—trees are providing $5.60 in benefits for every $1 spent on tree planting and care. New York City’s benefit-cost ratio of 5.60 exceeds all other cities studied to date, including Fort Collins, Colorado (2.18), Glendale, Arizona (2.41), and Charlotte, North Carolina (3.25).” See Attachment 3, p.3. 3. Air Quality Planning: The creation and maintenance of urban forests is relied upon by California air pollution control districts in their plans to reduce air pollution. These planning projections do not rely on offset incentives. a. Sacramento Area: “The estimated emission reductions from this urban forest development program for the Sacramento region are summarized in the following table. The estimated 2018 VOC reduction is about 0.8 tpd, but the credited reduction is limited to 0.2 tpd. This is consistent with the EPA policy for incorporating emerging and voluntary measures in a SIP that limits the amount of emission reductions allowed due to the uncertainty and untested nature of the control mechanisms.” See Attachment 5, pp. 7-19, 7-20. 4. Benefits to Utilities: Some utilities already have extensive and long-standing urban forest programs which are of economic benefit to the utility. Therefore, these types of programs occur in the course of business-as-usual. a. Sacramento MUD: “From SMUD’s perspective, the tree-planting program represents a type of Demand Side Management programs that have a tangible economic value to the utility. This value can be quantified based on avoided supply costs of energy and capacity during high cost of summer peak load periods, or the decrease in supply costs to the utility due to reduced electrical loads. SMUD’s total investment in the program since the program inception in 1990 has been about 30 million dollars and approximately 1.5 million dollars for 2008. Through 2008, over 450,000 trees have been planted through the program.” See Attachment 6, p.2. List of Attachments 1. San Francisco Urban Forestry Council Annual Report, September 2009 2. The Benefits of One Million Trees in LA, USDA/Forest Service, undated 3. New York City, New York, Municipal Forest Resource Analysis, March 2007 4. City of Berkeley, California, Municipal Tree Resource Analysis, March 2005 5. Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan, December 19, 2008 6. SMUD Shade Tree and Cool Roof Programs: Case Study in Mitigating the Urban Heat Island Effects, undated |
Attachment | www.arb.ca.gov/lists/capandtrade11/84-urban_forest_protocol_comment.zip |
Original File Name | Urban Forest Protocol Comment.zip |
Date and Time Comment Was Submitted | 2011-10-18 13:41:25 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.