Comment Log Display

Dear Air Resources Board:

We appreciate the opportunity to comment on the Air Resources Board
Cap and Trade Auction Proceeds Investment Plan Draft Concept Paper
(Draft Investment Plan).  The California Native Plant Society
(CNPS) works to protect California's native plant heritage and
preserve it for future generations. CNPS promotes sound plant
science as the backbone of effective natural areas protection. We
work closely with decision-makers, scientists, and local planners
to advocate for well informed and environmentally friendly
policies, regulations, and land management practices.  We are
writing to provide substantive comments on the Draft Investment
Plan as it relates to natural resources and conservation.

We support better aligning the Draft Investment Plan with AB 1532’s
mandates relating 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
through conservation and restoration of habitat lands.  AB 1532
states that auction revenues shall be used to facilitate the
achievement of reductions of greenhouse gas emissions in
California.  These funds shall be spent in a manner that maximizes
economic, environmental, and public health benefits.  The Act
specifically states the greenhouse gas Reduction Fund shall
appropriate funds towards one of several items, including the
reduction of greenhouse gas emissions associated with water use and
supply, land and natural resources conservation and management,
forestry, and sustainable agriculture.  

Unfortunately, not a single conservation strategy is outlined in
the Draft Investment Plan to further this mandate.  Please revise
the Draft Investment Plan to include land conservation tools as a
strategy for emissions reductions.  Doing otherwise is
shortsighted.  There are numerous benefits and co-benefits
associated with using land conservation as a means to reduce
greenhouse gas emissions.  

To pick one obvious example, California is home to some of the
biggest trees in the world: redwoods, sequoias to name just a few. 
Why not invest in them?  Why not invest in the over 7000 California
native plant species that are adapted to every different habitat
that the diverse state of California offers? It is so much cheaper
than performing the research to find agricultural substitutes for
this diversity.  In many cases there are existing conservation
plans and programs that are supported at the local, regional,
statewide and national levels by agencies, landowners and
non-profit organizations that provide a suitable framework to
achieve habitat conservation. 

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’ tissues and up to
20% of the plants' total carbon intake ends up bound in the soil
through root exudates.  Our natural lands are capture and store
carbon dioxide that would have otherwise been released into the
atmosphere.  When these lands are converted to more intensive uses,
including agriculture, development, and even frequent fires, this
carbon is rapidly lost back to the air, through soil disturbance,
oxidation, and burning.  Research has already been done in
California supports this claims.  East Bay Regional Parks District,
for example, estimated the average amount of CO2 sequestered
annually by the District’s 98,600 acres of protected natural lands
to be 91,157 metric tons, the equivalent of  removing 16,317
passenger cars from the roadways annually. 
(http://www.ebparks.org/
Assets/files/ebrpd_carbon_seq_study_2008.pdf, retrieved 1/16/2013).
 On a bigger scale, the National Science Foundation and U.S.
Department of Energy commissioned a study that showed forests and
other terrestrial ecosystems can sequester 40% of the nation’s
carbon emissions—up from the previous estimate of 30%
(http://www.sciencedaily.com/releases/2011/04/ 110414131851.htm,
Retrieved 1/16 2013). 

Wildlands offer carbon avoidance benefits that would not have
happened if the land was converted to more urban uses. Carbon
avoidance offers manifold benefits. 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 greenhouse gas impacts from construction are also
avoided.  Automotive emissions that would have come from vehicle
miles traveled  from residential and commercial uses are also
avoided.  This also ignores the other benefits that wildlands
provide, such as trapping air pollutants, reducing noise,
recharging groundwater, providing homes for sensitive species, and
last but not least, providing cheap areas for recreation,
education, and research.  

Given that conservation managers are routinely underfunded and
therefore extraordinarily efficient at leveraging funds to many
purposes, any investment of cap and trade revenues in conservation
issues will go much further than it would in the commercial sector.
 CNPS, for example, has partnered with agencies for years to
provide low cost, high quality research and conservation activities
throughout the state both with paid and volunteer staff, and we are
just one of the many entities that work in the conservation sector.
 

We urge you to amend the Draft Investment Plan to incorporate
conservation.  It is productive, cost effective, and produces many
benefits.  Thank you for consideration of our comments. 

Sincerely

Frank Landis, PhD
Conservation Chair
California Native Plant Society, San Diego Chapter