First Name | The |
---|---|
Last Name | Pacific Forest Trust |
Email Address | achiono@pacificforest.org |
Affiliation | |
Subject | Proposed Scoping Plan Language Recommendation |
Comment | Dear Board Members Loveridge and Riordan, Thank you very much for our discussion today. As promised, here is some proposed language that embodies what we discussed, and that PFT would like to see added to the Scoping Plan, either in its text, or in the Resolution for Adoption. 1. Cross Sectoral Accounting: in the Adopting Resolution, we suggest adding “ The Board directs the staff to ensure that transparent, cross–sectoral accounting systems be developed such that stocks and flows of carbon can be tracked readily within and across sectors, as, for example, from forests to landfills to methane emissions” 2. Accounting for Adaptive Management: in the adopting resolution we suggest adding: “ The Board directs staff to ensure that accounting across all sectors provides data sufficient to identify significant changes in carbon stocks and flows at the source of such change, in order to allow for adaptive management to ensure the achievement of AB 32 target goals.” 3. Synergy of Mitigation and Adaptation: we suggest adding in the text of the forest sector “Actions undertaken undertaken pursuant to AB 32 for purposes of mitigation in the Forest Sector are inherently linked to those appropriate for adaptation to support resilient, robust natural forest ecosystems that are more capable of adapting to climate change, especially with regard to watershed and habitat functions. Therefore, ARB will consult with key state entities responsible for the health and functioning of watersheds and habitat for California's plants, fish and wildlife to ensure actions pursuant to AB 32 are also beneficial for adaptation.” 4. Woody biomass combustion: We note that the addenda have changed the definition of woody biomass combustion from anthropogenic to biogenic. ARB should classify woody biomass combustion as an anthropogenic emission. The combustion of biomass vastly speeds up the release of carbon from waste-wood and from slash after harvest. Because there is insufficient waste and slash material available to meet biomass demands, this will result in increased harvest to fulfill that demand, overall emissions from biomass combustion will increase, as will forest –based emissions resultant from increased harvest disturbance. Unless harvest rotations or intervals are held steady, there will be insufficient times to re-absorb those emissions in the forest. This is likely to result in net increased emissions overall. |
Attachment | |
Original File Name | |
Date and Time Comment Was Submitted | 2008-12-04 13:30:03 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.