Comment Log Display

Thank you for this opportunity to provide comments on the Air
Resources Board’s Draft Concept Paper (2/15/13) on proposed
investment of cap-and-trade auction proceeds.  

As you well know, the Sierra Nevada Conservancy (SNC) is a
California state agency within the Natural Resources Agency,
created by bi-partisan legislation and signed into law in 2004. 
The SNC Region constitutes about 25 percent of California’s land
area and is the source of much of the state’s timber yield and over
60 percent of California’s developed water supply, serving end
users throughout the State.

Based on the importance of the Region in meeting the state’s
greenhouse gas (GHG) emission reduction goals under Assembly Bill
(AB) 32, we urge the Air Resources Board to consider the following
additions to the first three-year investment plan for cap-and-trade
auction revenue.

Forest Sector Investment

Almost a third of California (31 million acres) is forested.  These
forests present the safest, most expandable method for actually
removing CO2 from the atmosphere and storing it safely in trees. 
California’s forest sector is specifically identified in the AB 32
Scoping Plan as a means of achieving GHG emission reduction goals
through:

•	Forest conservation (to maintain existing carbon storage and
reduce conversion to more pollution-emitting uses);
•	Forest stand improvement (to improve forest health and increase
the amount of carbon that can be stored in existing forests);
•	Reforestation and afforestation;
•	Urban forestry; and
•	Fuels management (to make existing forests more resilient and
reduce the risk of GHG-emitting wildfire).

The forest sector is also called out in AB 1532, which specifies
using cap-and-trade auction revenues for forestry and other natural
resource management and conservation [Health and Safety Code
§39712(c)(3)].  AB 1532 further states that auction revenues should
be used to achieve specific co-benefits, such as: fostering job
creation; improving air quality; providing opportunities for
businesses, public agencies, nonprofits and other groups to
participate in and benefit from the state’s GHG reduction efforts;
and lessening the impacts of climate change on the state’s
communities, economy and environment. 
 
Investing auction revenue to improve forest condition not only
leads to direct GHG reductions, but it also ensures a long-term
carbon bank; improves air quality by reducing catastrophic wildfire
and open pile burning; provides opportunities to local forest
contracts and businesses that can use the wood waste for energy or
higher value products; provides an incentive for federal, state and
local land managers to coordinate land management to make strategic
investments in hire fire risk areas; protects water quality and
reliability at the source for 23 million Californians; sustains
fish and wildlife habitat; supports recreational uses in our forest
lands; reduces threat of wildfire to life and property; supports
rural forest economies by creating forestry-related jobs; produces
local renewable energy; and, supplies a sustainable source of
lumber and other forest products that continue to sequester carbon
throughout their useful life.  

Recommendation:  Include low-risk, high-return forest sector
investment in the first investment plan, administered through
entities like CalFIRE, state conservancies with forested lands
Resource Conservation Districts, and other entities with existing
programs, to begin achieving direct GHG emission reduction benefits
while supporting DAC investment and multiple co-benefits.

Investment in Bioenergy Production 

Investment in forest restoration provides the opportunity for
renewable energy development through the use of forest waste, or
“biomass,” to produce energy.  Converting forest waste to energy by
burning it in a controlled biomass energy facility achieves air
quality benefits on two levels: 1) it keeps that waste from being
disposed of by open pile burning, and 2) the forest treatments that
produce the biomass reduce the risk of large, damaging wildfires
that also emit substantial GHG.  Use of biomass for energy also
displaces the burning of fossil fuels, which add GHG to the
atmosphere, and provides reliable power when other renewable
sources, such as wind and solar, may be offline.

Investment must be directed to all forest lands, regardless of
jurisdiction, in order to get the full benefit from the sector. 
The 20 million acres of national forest system lands represent a
huge opportunity to reduce fire risk and protect and increase
carbon stores in the state.

Recommendation:  Allow cap-and-trade auction revenue to be spent on
public forest land to achieve critical air quality and renewable
energy benefits.

Forest Conservation

Conservation of forests threatened by conversion or degradation is
a key action that prevents emissions associated with loss of forest
stocks while also securing additional carbon sequestration into the
future.  Protecting and enhancing California’s forest carbon banks
can be achieved through either conservation easements or fee title
purchase. 

Conservation easements allow the state or qualified land trusts to
collaborate with interested landowners to develop site-specific
guidelines for enhancing forest resource values, including
increased carbon storage, while keeping the property in private
ownership and management.  Fee title acquisition allows the state
or non-profit partner to directly manage strategically important
threatened forest for the public good when such conservation cannot
be achieved in a public-private partnership.  Both approaches can
facilitate increased public access and recreation.

Additional co-benefits of forest conservation include:

•	Improved forest management for climate and habitat benefits,
including site-specific conservation prescriptions and support for
adaptation;
•	Watershed conservation to maintain water quality and reliability
at the source; and
•	Prevention of sprawling land use patterns that lead to
auto-dependency, increased CO2 emissions and resource
inefficiencies.

Recommendation:  Include forest conservation investment in the
first investment plan, to be implemented through the Wildlife
Conservation Board, state conservancies with forested lands,
CalFIRE and other entities with existing programs in place, to
begin achieving long-term carbon storage, emission reduction,
climate change adaptation, water reliability and local economic
benefits.

DAC Identification and Mapping

It is clear that the areas identified by the CalEnviroScreen tool
are disadvantaged; but right now the determination criteria fail to
recognize any communities in the rural forested parts of the state
– some of the areas hardest hit by the economic downturn.  The
criteria and formula should not exclude many rural communities that
are disproportionately affected – the ones that are suffering from
environmental pollution and socio-economic ills like declining
personal income, accelerated unemployment, low educational
attainment levels and growing numbers of children living in
poverty.

The DAC definition, for purposes of investment of cap-and-trade
auction revenue, should be further examined and amended so that
vulnerable communities in the rural forested areas are also
recognized and eligible for cap-and-trade funding.  All
Californians will bear the cost of reaching the state’s GHG
emission reduction goals; therefore, the benefits that accrue from
those efforts should apply more broadly. 
 
Recommendation:  Use the Rural Community Focus Group – a diverse
group of experts who understand disadvantaged communities of all
types being convened by the Governor’s Office of Planning and
Research – to refine the definition of DAC so it does not exclude
rural forested communities. 

Conclusion

Early investment of cap-and-trade auction revenue in forest sector
projects, including on public lands and in disadvantaged
communities in the rural forested areas, would fulfill the letter
and the spirit of the AB 32 implementation laws that call for a)
reducing GHG emissions in both the short- and long-term, b)
maximizing additional environmental, economic and public health
benefits (“co-benefits”) for California and c) directing investment
toward disadvantaged communities and households across the state. 

Thank you for the opportunity to contribute to discussions
regarding these important issues.