Comment Log Display

Hon. Mary Nichols
Chair
California Air Resources Board
1101 I Street
Sacramento, CA 95814

Dear Chair Nichols:

California State Parks appreciates the opportunity to provide
comments to the California Air Resources Board on its evolving
Investment Strategy for Cap-and-Trade Auction Proceeds.
 
As a state agency, State Parks is committed to reducing its
Greenhouse Gas (GHG) footprint.  In many respects, the largest
contribution State Parks can provide to our collective efforts to
address climate change is by continuing and expanding the
stewardship of the large natural landscapes under its
jurisdiction.
 
That stewardship has for many years included natural resource
protection and management, including the restoration of degraded
landscapes such as coastal dune and wetland ecosystems, the
protection and maintenance of riparian habitats, treatment and
management of exotic species, and management of forested
ecosystems.
  
Today, our forest management program includes natural management of
extensive groves of old-growth coast redwood and giant sequoia
stands, along with nearly every other major native forest community
in California.  Our efforts to protect these landscapes utilize
tools such as forest thinning and prescribed fire to improve the
natural diversity and resilience of these forests.  An important
co-benefit of this management includes significant GHG benefits.
 
Forest restoration work has been demonstrated to provide GHG
benefits on both sides of the accounting ledger – by improving the
natural uptake of CO2 and by reducing the severity of uncontrolled
wildfires and the concomitant catastrophic release of GHGs during
wildfire events.

Along with the restoration and management of other native
landscapes, State Parks forested landscapes can thus contribute
significantly to California’s plans to mitigate climate impacts
just as they play a key role in our statewide adaptation
strategies. However, our current natural resource management
program is able to restore resilience in only a small percentage of
native ecosystems – and address only a tiny fraction of our at-risk
forests -- each year. The Department’s current budget reductions
hamper our ability to increase these efforts. 

In 2008, State Parks began a reforestation project at Cuyamaca
Rancho State Park that will eventually sequester between
440,000-700,000 metric tons of CO2 equivalents.  While undertaking
many similar  Climate Action Reserve-registered projects at State
Parks is unlikely, this effort has built capacity within State
Parks to quantify GHG reductions that extend to the landscape scale
(i.e., beyond project-specific accounting).
 
As you know, the AB 32 Scoping Plan already includes recognition of
the importance of sustainable forest practices as a GHG reduction
strategy, and the Cap and Trade rule explicitly recognizes
management of public forests as a potential GHG reduction strategy.
Building on these efforts, State Parks believes that investments in
State Park natural resource protection and management are worthy of
a dedicated portion of future auction revenues.  

Many thanks for your continued efforts to address climate change.
We look forward to working with your staff and our collaborating
agencies, NGOs, and members of the research community to more fully
develop the framework for these important investments.
 
Sincerely,




Jay Chamberlin 
Chief, Natural Resources Division