Comment Log Display

March 3, 2013

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

RE: Comments on 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).  The Endangered Habitats League (EHL) is
Southern California’s only regional conservation group.  We have
been active since 1991 in State of California Natural Communities
Conservation Planning (NCCP).

1.  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.  Yet, not a single 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.

2.  There are numerous benefits and co-benefits associated with
using land conservation as a means to reduce greenhouse gas
emissions.  

•	By protecting natural resource lands the “threat” of land
conversion to more urban uses is removed.  Development is directed
at more urban areas and not at the Wildland-Urban Interface.  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. 

•	Natural lands provide significant abilities to sequester carbon.
In fact, 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% (See Science News
Daily (SND).  “Carbon Sequestration Estimate in US Increasing,
Barring A Drought.” Retrieved 16 Jan 2013 from the SND website:
http://www.sciencedaily.com/releases/2011/04/110414131851.htm). 

•	While existing protected lands offer benefits in terms of
emissions reductions, through appropriate restoration and
enhancement efforts these benefits can be multiplied. The United
States Fish and Wildlife Service through a Climate Change Strategy
studied the effects of extensive restoration on a Southeastern
wildlife refuge. By planting more than 22 million trees, more than
33 million tons of carbon will be captured over the next 90+ years
(See United States Fish and Wildlife Service. “Service Releases
Climate Change Strategy for Public Review and Comment.” Retrieved
16 Jan 2013 from the USFWS website:
http://www.fws.gov/southeast/news/2009/r09-050.html).

3.  Habitat lands offer carbon sequestration benefits that equate
to removing passenger cars from roadways.  

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, roots and in the soil.  This process is known as carbon
sequestration.  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). 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).

4.  Habitat lands offer carbon avoidance benefits that would NOT
have happened if the land was converted to more urban uses. 

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. 

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

Sincerely,


Dan Silver
Executive Director