Comment Log Display

March 6, 2013

California Air Resources Board
P.O. Box 2815 
Sacramento, CA 95812

RE: Comments on the ARB Draft Investment Plan

Dear Air Resources Board:

Thank you for the opportunity to comment on the Air Resources Board
Cap and Trade Auction Proceeds Investment Plan Draft Concept Paper
(Draft Investment Plan).  We are writing to provide substantive
comments on the Draft Investment Plan as it relates to natural
resources and conservation.

The Puente Hills Habitat Preservation Authority (Habitat Authority)
is a joint powers authority established pursuant to California
Government Code Section 6500 et seq.  with a Board of Directors
consisting of the City of Whittier, County of Los Angeles,
Sanitation Districts of Los Angeles County, and the Hacienda
Heights Improvement Association. According to its mission, the
Habitat Authority is dedicated to the acquisition, restoration, and
management of open space in the Puente Hills for preservation of
the land in perpetuity, with the primary purpose to protect the
biological diversity.  Additionally, the agency endeavors to
provide opportunities for outdoor education and low-impact
recreation.  The Habitat Authority owns and or manages over 3,800
acres which lie within the Cities of Whittier and La Habra Heights,
as well as in the County unincorporated areas of the Puente Hills
known as Hacienda Heights and Rowland Heights.
We support better alignment with AB 1532’s mandates as it relates
to natural resources and conservation strategies as a mechanism to
reduce emissions.  The Draft Investment Plan mentions natural
resources and conservation but does not utilize or identify
appropriate tools that reduce greenhouse gas emissions (GHG)
through conservation and restoration of habitat lands.  AB 1532
states that auction revenues shall be used to facilitate the
achievement of reductions of GHG emissions in California.  These
funds shall be spent in a manner that maximizes economic,
environmental, and public health benefits.  The Act specifically
states the GHG Reduction Fund shall appropriate funds towards one
of several items, including the reduction of GHG emissions
associated with water use and supply, land and natural resources
conservation and management, forestry, and sustainable agriculture.
 However, no conservation strategy is outlined in the Investment
Plan that furthers this mandate.  Please revise the Draft
Investment Plan to include land conservation tools as a strategy
for emissions reductions.


Habitat lands offer carbon sequestration benefits that equate to
removing passenger cars from roadways.  Carbon, found in all living
organisms, primarily exists terrestrially as plant biomass and soil
organic matter (SOM).  Plants naturally absorb carbon dioxide (CO2)
from the atmosphere and through photosynthesis it is stored as
carbon. Plants release oxygen into the atmosphere as a by-product
of this process.  The carbon is stored (or sequestered) in the
plants’ branches, tree trunks and roots.  Carbon is either
transferred to animals when they eat plants or added to the soil
when plants drop their leaves and/or die; decomposing plant and
animal matter stores carbon as SOM.  This process is known as
terrestrial carbon sequestration and soils contain approximately
three times more carbon than is stored in living plants and
animals;   emphasizing the importance of soils in the carbon cycle
and carbon sequestration.  SOM is ultimately derived from
vegetation and habitat management practices can be easily modified
to increase carbon sequestration (see Native Plants for Optimizing
Carbon Sequestration in Reclaimed Lands by Unkefer et al.) at the
following website:
http://www.netl.doe.gov/publications/proceedings/01/carbon_seq/p51.pdf

Research has already been done in California that furthers this
assertion.  East Bay Regional Parks District, for example,
determined the average amount of CO2 sequestered annually by the
District’s 98,600 acres of protected natural lands is estimated to
be 91,157 metric tons (Mt).  This also equates to removing 16,317
passenger cars from the roadways annually.  (See East Bay Regional
Park District (EBRPD).  EBRPD Carbon Sequestration Evaluation.
Retrieved 16 Jan 2013 from the EBRPD website:
http://www.ebparks.org/Assets/files/ebrpd_carbon_seq_study_2008.pdf).


Habitat lands offer carbon avoidance benefits that would NOT have
happened if the land was converted to more urban uses. Our natural
lands are “carbon sinks” storing GHG emissions that would have
otherwise been released into the atmosphere with conversion to more
intensive uses (such as residential, commercial and industrial
development). It seems there is a natural opportunity to use land
conservation to avoid increasing the amount of carbon emissions
from land development and transportation activities (aka carbon
avoidance). Avoidance benefits are multifactorial in origin.  At
the outset, preservation of land averts the release of stored
(sequestered) carbon from vegetation and soil that otherwise would
be released due to grading and land disturbance.  The GHG impacts
from construction are also avoided.  Then, over the long term, the
automotive emissions that would have come from vehicle miles
traveled (VMT) from residential and commercial uses are avoided. 
To this end, environmental documents are analyzing project impacts
pursuant to the California Environmental Quality Act.  Consultants
are more frequently analyzing all of the development related
sources of GHG emissions (construction, household, infrastructure,
etc.) and VMTs.  Utilizing these reports can be the starting point
for understanding what carbon avoidance values could be for a
proposed development.  This analysis was in fact utilized to
understand what the carbon emissions would be for a project in
Fullerton, CA.  The project proposed the conversion of 510 acres of
natural land into 760 houses and a small commercial center.  This
project, if built, is estimated to have generated the following:
•	8,367 tons of CO2e (e=equivalent) for an annualized total
(includes all GHG emitting activities); 
•	33,340 tons of CO2e from construction emissions, 
•	3,987 tons of CO2e from vehicular emissions, and
•	11,686,804 VMT annually. (See West Coyote Hills Recirculated
Draft Environmental Impact Report GHG Emissions Study Completed by
ENVIRON, October 9, 2009).

By protecting natural habitat lands the “threat” of land conversion
to more urban uses is removed and directed at more urban in-fill
areas.  The role of habitat lands in carbon sequestration and the
reduction of GHG emissions is important and not to be overlooked;
especially since it is an effective way to sequester carbon without
negative environmental consequences.

Thank you for your time and the opportunity to provide feedback to
the Air Resources Board on the Draft Investment Plan.

Sincerely,

Andrea Gullo
Executive Director
Puente Hills Habitat Preservation Authority