Comment Log Display

The California Farm Bureau Federation has been very active in the
AB 32 implementation process. One of our senior staff sits on the
Economic and Technology Advancement Advisory Committee. We have
fully supported her activities as the Co-chair of the Agriculture
and Forestry sector. She has spent significant amount of time
working with the agriculture and forestry communities to obtain
their input for an important report the ETAAC committee will
complete by January 2008.

During the ETAAC process, we have heard loud and clear from the
working foresters that there are barriers for use and technical
shortcomings with the forestry protocol developed by the
California Climate Action Registry. The dialogue at the September
6th CARB forestry protocol public consultation meeting made clear
to the CARB staff and participants that there are serious
inadequacies in the existing forestry protocol that need to be
addressed. 

As previously requested of Governor Schwarzenegger and CARB Chair
Mary Nichols, we ask CARB members to publicly acknowledge that
additional forestry protocols need to be developed that will
reflect a “working forest” and will allow the majority of the
forest community to participate in a valid greenhouse reduction
effort. When CARB considers Agenda item 07-10-3 on October 25,
2007, we ask that the need for development of a “working forest”
protocol with a completion deadline of August 2008 be included in
any resolution that is adopted regarding the current CCAR forestry
protocol.

The existing CCAR forestry protocol has been in-place for nearly
three years.  There has been only one registrant to date with a
second registrant in process.  These two registrants represent
less than 1/10 of 1 percent of California’s forestlands.  Unless
another forestry protocol is developed that reflects working
landscapes, nearly all of California’s forest landowners will have
to seek carbon-marketing opportunities elsewhere out-of-state. 

Specific areas of concern that we would like to see addressed in a
workable forestry protocol are:
·	Baseline.  California forestry should be able to compete on a
level playing field in the global economy.  At minimum, our forest
protocols need to integrate with emerging regional and national
standards.  It makes no sense to reward states that have lower
regulatory baselines with higher levels of tradable carbon
credits.   
·	Permanence.  The requirements of SB 812, as carried into the
current protocols, require CCAR forestry participants to secure a
permanent conservation easement. We believe this requirement is
unrealistic and a huge deterrent to willing landowner
participation. The issue can be handled in a number of fiscally
sound, legally binding ways. An example would be a long-term
agreement between a forest landowner and credit purchaser.
·	Forest Products.  In the current protocols when a tree is cut it
is treated as an emission.  We know this not to be the case in the
real world.  There needs to be a proper accounting of products and
end uses of wood fiber. Wood is the most climate friendly building
commodity, comparing extremely favorably in total product life
cycle with non-renewables such as steel and concrete.  Forest
protocols that discourage the use of wood products actually
encourage product substitutes carrying larger carbon footprints. 

·	Inventory Expense.  Foresters are highly qualified to make
measurements necessary to estimate forest carbon.  Statistical
sampling schemes should be rigorous and verifiable, but
cost-effectiveness is always a consideration.  If sampling
expenses are too high in relation to expected landowner benefits,
the work will not be done and opportunities lost.  
·	National Forests.  National forests contain approximately half
of the high quality timberland in the state representing a huge
potential carbon sink, if properly managed.  Fuel treatment
efforts are lagging, contributing to the increasing occurrence of
catastrophic forest fires and greenhouse gas emissions.  Many
areas also lack adequate reforestation after wildfires leading to
brush fields and long term forest loss.  

We take our role in the AB 32 implementation process very
seriously and are seeking economical and effective GHG reductions
that agriculture and forestry can provide. Our livelihoods depend
on these biological ecosystems; thus, we understand their
complexity and the need to have a diverse set of approaches to
reach the AB 32 GHG reduction goals in a sustainable manner.  

We look forward to continued dialogue with CARB members on this
issue of great importance to implementing the Global Warming
Solutions Act of 2006 and thank you for consideration of our
request.