Comment Log Display

COMMENTS in OPPOSISION TO Adoption of the Climate Action Reserve
Updated Forest Project Protocol for Greenhouse Gas Accounting     
 
Deadline for Comment: September 23, 2009 by 12 Noon or at the
Board hearing.

Comments made by
Mauro Oliveira, 
a representative of the following groups:
SOL Communications Inc (501c3)
Battle Creek Alliance (Citizen Group)
Northern California Citizens for Clean Air (Citizen Group)
Mailing address:
Box 225
Montgomery Creek CA 96065

The comments are both statements and question.

Either or both may have a preface used to give context to the
statement or question.

Please address both questions and statements.  
Attached with comments is the Center for Biological Diversity
Lawsuit/Comments that include the science Air Resources MUST
consider.

_____________________________________________________


SECTION ONE: GREENHOUSE GAS EMISSIONS AND CLEARCUTTING
A: The Government’s Responsibility
B: Preface to Questions
C: Question



The Government’s Responsibililty

This THP (and THP applicant- the OWNER(s), Managers and Corporate
body of Sierra Pacific Industries) is in violation of the
California Environmental Quality Act (CEQA) and the Forest
Practices Act, because Sierra Pacific Industries does not analyze
the greenhouse gas emissions of the planned clearcutting. 

California Department of Forestry (CDF) is also in violation of
CEQA and the Forest Practices Act, because its REPRESENTATIVES and
the Agency body fails to force the timber company to adhere to the
law AND because CDF DOES NOT ANALYZE THE EMISSIONS ITSELF. ALL THPs
approved by CDF are approved without ANY idea OR CONCERN of what is
really “going on” with greenhouse gas emissions in timber
management.  

And in the ongoing struggle to gain attention to this dangerous
forestry practice, it has become clear that the Shasta County Board
of Supervisors is also in violation of CEQA and the Forest
Practices Act for failing to act on the reasonable representation
by Citizens that this violation of the CEQA law etc. was taking
place in their jurisdiction.

The California Attorney General intends to close the gates on all
industrial greenhouse gas emissions in the state and he EXPECTS the
counties to follow the law:
			
Landmark CEQA/Climate Change Settlement
August 2007

On August 21, 2007, California’s Attorney General Jerry Brown
announced a settlement of the recent controversial CEQA lawsuit his
office brought against San Bernardino County, involving the extent
to which the County’s EIR for its General Plan update should
address impacts on climate change.  The settlement is important
because it requires a California agency for the first time to
inventory historical (as of 1990), current, and projected
greenhouse gas (“GHG”) emissions, to set a target for reducing GHG
emissions, and to develop measures to reduce such emissions. –
(Morrison Foerster)

The “Spirit” of CEQA and its relationship to the Citizenry is
partly stated in the legislative intent: 

“Citizens, ALL governing bodies and industry HAVE the
responsibility to fulfill the acts objective of protecting the
future’s resources. “

Therefore, however unfortunate, it becomes the RESPONSIBILITY of
the Citizen to see to it that the government (CDF) does its job of
applying the law on the industry, which fails to do its job (SPI).
By making these comments in the public comment period, our
organizations are now eligible to proceed with legal tools to
remedy the unjust.

As stated on the website, www.stopclearcuttingcalifornia.org,
clearcutting produces, and /or releases tremendous amounts of
carbon dioxide, methane and other greenhouse gases into the
atmosphere AND California state officials fail to take that into
consideration when approving clearcutting operations by timber
companies. Approving this THP will show total disregard for the
scientific facts and worse yet, for the welfare of ALL FUTURE
GENERATIONS OF HUMANS AND WILDLIFE.


B: PREFACE TO SECTION ONE QUESTIONS:

The Timber industry commonly states THEIR ARGUMENT, that ALL
carbon that is lost during clearcutting is recaptured in the
approximate 100-year cycle of their tree plantations (though they
occasionally admit that some plantations take much longer to reach
THIS POINT). 

Though it would be prudent to challenge that generalized statement
on many different and distinct scientific points, AND WE DO SO at
stopclearcuttingcalifornia.org, we will allow their argument ONLY
for the purpose of demonstrating the irrelevance of their argument,
further collapsing their moral and legal right to this THP.

CDF cannot rely on a POSSIBILITY that ANY forest will recover its
greenhouse gas emissions within ANY timeframe. Monocropped
plantations are commonly crippled by beetles, draught and wildfire
(even aged crowning) as well as scores of other problems that will
increase in the future climate conditions.

SPI and CDF rely upon reports that project 100 years as the time
frame of plantation carbon RECOVERING and arriving at carbon
neutral. But no one can ignore the IMMEDIATE AND DANGEROUS
consequences of NOT REIGNING IN greenhouse gas emissions in the
next 10-20 years. CEQA, AB32 are ALL ABOUT this time frame. 

The world’s nation’s, including the United States, has recognized
the consensus of the International Panel on Climate Change (IPCC)
findings, reports and recommendations.
As part of the IPCC findings, scientists have determined that
deforestation is the third leading cause of greenhouse gas
emissions. The IPCC is stressing urgency and co-operation in the
all out effort to avert disaster.

The Center for Bio-diversity has stated that globally,
deforestation accounts for about a quarter to one half of all
greenhouse emissions. (Other notable sources put that up to 50%) 

A key player in the IPCC is the United States Department of
Energy. The Department of Energy’s 2001 Northwest Report, states
that the northern California region will suffer major temperature
increases with drier and longer draught conditions over the next
100 years. Chapters Nine and Ten of that REPORT IS ATTACHED AND IS
SPECIFIC TO THESE THPs. 

In the 9th Chapter (Potential Consequences of Climate Variability
and Change For The Pacific Northwest), WHICH IS INCLUDED BECAUSE OF
ITS SPECIFIC RELEVANCE to THIS THP, it is stated:

•Regional warming is projected to continue at an
Increased rate in the 21st century, in both summer
and winter. Average warming over the
region is projected to reach about 3°F (1.7°C) by
the 2020s and 5°F (2.8°C) by the 2050s.

• Annual precipitation changes projected through
2050 over the region range from a small decrease
(-7% or 2”) to a slightly larger increase (+13% or
4”).

• Projected precipitation increases are concentrated
in winter, with decreases or smaller increases
in summer. Because of this seasonal pattern,
even the projections that show increases in
annual precipitation show decreases in water
availability.

It should be noted that the DOE report considers Northern
California’s Sierra and Cascade Range as having the characteristics
of both the Pacific Northwest and the Pacific Southwest, but
trending towards desertification.

Dr James Hansen, Director of GISS at NASA had stated several YEARS
ago that the world had about ten years to curb and curtail human
generated green-house gas emissions or humanity would suffer
runaway global warming. This would directly cause massive species
die-offs, worldwide migrations and economic and political
collapse.

Therefore it is far SAFER to say the conservative approach is the
ONLY approach. The world cannot afford timber, oil and coal to be
wrong, ALTHOUGH the world COULD afford the IPCC and the leading
climate scientists who have called for a halt to emissions to be
wrong. The uncertainty of too many known variables and UNKNOWN
variables weighs too heavy to be dismissing the facts at hand. And
to be sure that at least some of the facts, NOT YET AT HAND, will
most certainly be working against us.

This is clearly stated in the IPCC Summary of Policymakers (2001
report):
Climate change decision making is essentially a
uncertainty. Decision making has to deal with uncertainties
or irreversible changes, entails balancing the risks of either
involves careful consideration of the consequences (both
likelihood, and society’s attitude towards risk.



The SCIENCE SUMMARY BEHIND THE LAW:

A standing forest will be a carbon sink most of its “life” as
photosynthesis absorbs CO2 and then “banks” the CO2 into is bark,
wood, leaves, root systems and even transferring CO2 into the
surrounding soils. 

Clearcutting disturbs the forest more negatively than any other
form of logging. Each square inch of living tissue in a clearcut is
removed above the soil. All the leaves and lesser foliage rots or
is burned and ALL the CO2 and other greenhouse gases are released
into the atmosphere. The soil is both poisoned with herbicides and
/ or tilled in preparation for plantation trees (primarily a single
species). The herbicides kill any remaining vegetation above the
soil and kill living tissue, microorganisms, mycelium and other
“life” below the soil. This of course releases more greenhouse gas
emissions.
Tilling the soil also breaks free loosely bound CO2 (and other
greenhouse gases) from the soil itself, releasing it into the
atmosphere.


B: QUESTIONS THAT NEED TO BE ANSWERED ABOUT GREENHOUSE GAS
EMISSIONS AND THIS THP

It is CDF’s responsibility to answer these questions ABOUT ALL
THPs:

1-	How much CARBON will be released by the decay created (and
other adverse affects of the herbicide) by the FIRST herbicide
application, PRIOR to the cutting phase of all planned cuts? (this
application usually happens a season or two before cutting)

2-	How much METHANE will be released by the decay created (and
other adverse affects of the herbicide) by the FIRST herbicide
application, PRIOR to the cutting phase of planned cuts? (this
application usually happens a season or two before cutting)

3-	There will be below-the soil decay as a result of this
application of herbicide therefore a release of greenhouse gas
emissions. What will be the CARBON emissions from below-the-soil
decay?

4-	What will be the METHANE emissions from below-the-soil decay?

5-	During the cutting phase, much debris will be created and end
up decaying as matter, including STUMPS and ROOT SYSTEMS. How much
CARBON will be released by the decay of surface AND
below-the-surface “forest”?

6-	How much METHANE will be released by the decay of surface AND
below-the-surface “forest”?

7-	And much of the debris created by the cutting phase will be
piled up and burned during the rainy season. How much CARBON will
be released by the slash-burning phase in this planned operation?

8-	How much METHANE will be released by the slash-burning phase in
planned operations?

9-	After the cutting operation, in preparation for replanting, the
land is “tilled” down sometimes to three feet. This phase creates
MAJOR disturbance to the soil and releases loosely bound greenhouse
gases into the atmosphere (out of the soil). How much CARBON will
be released by the prepping for the replanting phase of all planned
cuts? 

10-	How much METHANE will be released by the prepping for the
replanting phase of planned cuts?

11-	 How many YEARS before the SOIL again sequesters the SAME
amount of CARBON that it does on the date of THIS COMMENT?

12-	How many YEARS before the SOIL again sequesters the SAME
amount of METHANE that it does on the date of THIS COMMENT (IE
PRIOR TO ANY DISTURBANCE? HERBICIDE USE)?

13-	 What study are you referencing in the calculations and
answers required for the above questions?

14-	Wood products, such as homes, more often than not, last less
than one hundred years. Older homes burn or are torn down and
occasionally are partially recycled. Therefore the sequestered
carbon is then lost, OFFSETTING an unknown percentage of carbon
stored in that homes original forest (where the wood products were
timbered). Please reveal any studies that THPs rely upon to
mitigate, BUT DIRECTLY ADDRESSES this negative aspect of the carbon
cycle.

 Temperate forests trump rainforests when it comes to storing
carbon, reports a new assessment of global forest carbon stocks
published July 14th in Proceedings of the National Academy of
Sciences (PNAS). The findings have important implications for
efforts to mitigate climate change by protecting forests. This
study has been adopted by the IPCC as new and revealing data.
  
 



QUESTION
15-	How have THPs, Sierra Pacific and CDF moved to “plug in” the
data found in this study (published July 14th in Proceedings of the
National Academy of Sciences {PNAS})? 




The FOLLOWING SECTION CHALLENGES SPI’s stance that old growth
forest (AND second growth mature) does not maintain ENOUGH carbon
sequestration to NOT CUT. This challenge is here because of the
obvious…SPIs claims are bogus and the more bogus is revealed the
more uncertainty is cast upon the remaining claims. The future of
the planet cannot be handed to the Blackwaters and Halliburtons of
this world. SPI has misrepresentation, fraudulent claims and heavy
investments in contrived science. For instance…(1) The
long-standing view that old-growth forests are carbon neutral was
originally based on ten years' worth of data from a single site and
has been supported by research that shows a decline in net primary
productivity with age in plantations, according to the authors. SEE
BELOW

The following exists on this website:
http://news.mongabay.com/2008/0911-forests.html

Old growth forests are important carbon sinks that help global
warming, reports a study published in the journal Nature. The
results run counter to claims by the forestry industry that old
growth forests are carbon neutral or even net emitters of carbon
dioxide.

Analyzing 519 studies of plots from forests around the world,
Sebastian Luyssaert of the University of Antwerp and colleagues
found that old growth forests in boreal and temperate zones of the
Northern Hemisphere alone — about 15 percent of global forest cover
— sequester 0.8 to 1.8 billion tons of carbon per year.

"Old-growth forests accumulate carbon for centuries and contain
large quantities of it," the authors write. "We expect, however,
that much of this carbon, even soil carbon, will move back to the
atmosphere if these forests are disturbed."

The findings — which are based on a broader data set than prior
studies1 — are significant because old-growth forests worldwide are
being replaced by forest plantations 2. Previous research has shown
that once plantations reach maturity, they become net emitters of
carbon. In contrast, old-growth forests continue to accumulate
carbon in their vegetation and soils.

"In fact, young forests rather than old-growth forests are very
often conspicuous sources of CO2 because the creation of new
forests (whether naturally or by humans) frequently follows
disturbance to soil and the previous vegetation, resulting in a
decomposition rate of coarse woody debris, litter and soil organic
matter... that exceeds the net primary production of the regrowth,"
Luyssaert write.

"The current data now makes it clear that carbon accumulation can
continue in forests that are centuries old," added co-author
Beverly Law, a professor of forest science at Oregon State
University and director of the AmeriFlux network, a group of 90
research sites in North and Central America that is monitoring the
current global "budget" of carbon dioxide.

The authors end by arguing for the inclusion of old-growth forests
in climate change mitigation programs.

"Carbon-accounting rules for forests should give credit for
leaving old-growth forest intact," they conclude.

CITATION: Sebastiaan Luyssaert et al (2008). Old-growth forests as
global carbon sinks. NATURE| Vol 455| 11 September 2008

(1) The long-standing view that old-growth forests are carbon
neutral was originally based on ten years' worth of data from a
single site and has been supported by research that shows a decline
in net primary productivity with age in plantations, according to
the authors.
(2) U.N. data shows that more than 15 million hectares of forest
were destroyed each year during the 1990s, including 6 million
hectares of primary forests. Meanwhile tropical forest plantations
expanded by almost 5-fold since 1980. In 2006 alone Brazil planted
more than 627,000 hectares of industrial forest plantations.

QUESTION:
16- What CURRENT STUDY does Air Resources, the Board of Forestry,
SPI, Roseburg (and others) and CDF use to REFUTE THE STUDY BY
Sebastiaan Luyssaert of the University of Antwerp?




Attached are chapters 9 and 10 of the Department of Energies 2001
Northwest Report. This report projects EXTREME temperature rises,
increased draught and declining water availability in the Northern
California, Oregon and Washington Region. DOE reports and other
reports, have shown that the South West region will suffer hotter,
drier and extreme water availability problems. All DOE reports
indicate desertification headed north.
Based on the DOE Northwest Report:

QUESTION:
17- Where are the timber industry, Air Resource, Board of Forestry
etc.  studies to show that reforestation, water availability,
increased wildfires and GLOBAL WARMING EMISSIONS won't INCREASE
(get worse) in the hotter, drier Sierra, that is already being
impacted by climate change? They are required by CEQA to maintain
functional wildlife habitat-- Where are the surveys, studies,
population counts from their lands, where it has been clearcut, to
prove that they calculated future projections into current
clearcutting operations? Do NOT use DiTomaso’ study from over a
decade ago, WHICH NO LONGER APPLY. Please show the published
research.

18- Please show ALL the studies the timber industry, Air Resource,
Board of Forestry etc.  are using to prove that Climate Change WILL
NOT affect forest growth in a NEGATIVE way in the Sierras and
Cascade Range where SPI makes forests disappear and plantations
appear.


__________________________________________________________

SECTION TWO: LACK OF UNDERSTORY RECOVER AFTER CLEARCUTTING

A: Preface to Questions
B: Question

Preface: 

Do Appalachian Herbaceous Understories Ever Recover from
Clearcutting?

DAVID CAMERON DUFFY
Institute of Ecology
University of Georgia
Athens, GA 30602, U.S.A.

ALBERT J. MEIER
Institute of Ecology
University of Georgia
Athens, GA 30602, U.S.A.

Abstract: Life history characteristics of many herbaceous
understory plants suggest that such species recover slowly from
major perturbations such as clear cutting. We examined herbaceous
cover and richness in the understories of nine primary
("old-growth'? Forests in the southern Appalachian Mountains and of
nine comparable secondary forests, ranging in age from 45 to 87
years since clear cutting. Neither cover nor richness increased
with age in the secondary forests. This suggests three
possibilities: (I) that r e c o v q is so slow or variable among
sites that 87 years is insufficient time to detect it; (2) that
such forests will never recover to match remnant primary forests
because climatic conditions are different today than when the
forests became established; or (3) that herbaceous plants colonize
pit and mound micro topography caused by the death of trees, so
that recovery must await the growth, death, and decomposition of
the trees of the secondary forest. Whatever the mechanism,
herbaceous understory communities in the mixed-mesophytic forests
of the Appalachians appear unlikely to recover within the present
planned logging cycles of 40-150 years, suggesting a future loss of
diversity of understory herbaceous plants.

STUDY ATTACHED

QUESTIONS:

19- Show the published studies that SPI and CDF have that
CONTRADICT or OPPOSE the above study. 

20- Show the studies or research published that SPI and CDF use to
determine that herbaceous understory plant species recover
completely from clearcutting.

21- Show that the studies you are citing reflect up to date
climate information, enough to “trump” the above study.

22- If you attempt to dismiss this study because it refers to
Appalachian forest, then show the WESTERN study you rely upon to
show that climate affects understory species growth different in
the west, FROM THE EAST.


___________________________________________________________

SECTION THREE: WILDLIFE AND BIODIVERSITY DECREASE AFTER
CLEARCUTTING

A: Questions


23- Since there is diminishing biodiversity after the logging of
primary forests, how much worse will the loss of biodiversity be
after clearcutting secondary forests? Show the research.

24- SPI and CDF claim “wildlife thrives in wildlife retention
areas” {Redding Record Searchlight January 2006}. Yet we cannot
find a SINGLE satellite image (they are ALL daytime) with a single
deer, bear, turkey or any other animal in it. Show the research and
photographs of THRIVING wildlife. We are all certain that animals
pass thru clearcuts to get to other forested areas, so the
photographic evidence would contain nesting sites, animals feeding
in herds, mating etc. Show these photographs. The question is
“where are the photographs and research that shows retention areas
are thriving with wildlife.