Comment Log Display
Below is the comment you selected to display.
Comment 20 for Draft Proposed First Update to the Climate Change Scoping Plan (proposed-sp-ws) - 1st Workshop.
First Name: Jim
Last Name: Downing
Email Address: jbdown@gmail.com
Affiliation: Private citizen
Subject: Fact on page 69: GHG emissions 70x greater from urban land than ag
Comment:
Dear CARB, Thank you for your excellent work on the updated scoping plan. I request that the following sentence on page 69 of the Scoping Plan be removed or amended: "Recent research has shown that GHG emissions from urban areas are approximately 70 times greater than those from agricultural lands on a per-acre basis." While this sentence correctly cites peer-reviewed information (the 70x fact is from page 562 of Haden et al. 2013. Journal of Environmental Planning and Management 56(4):553-571), I contend that it is misleading, in that it greatly overstates the emissions cost associated with the conversion of agricultural land to urban land uses. In calculating this 70:1 ratio, the authors count nearly all emissions related to human activities (all electricity and transportation emissions, for instance) as "belonging" to developed acreage, while emissions from agricultural land are calculated as only those emissions stemming from farming. Thus, on a per-acre basis, emissions from urban land are determined to be much greater than emissions from farmland. The problem is that the urban emissions have very little to do with the fact that the urban land is covered with houses and businesses. Nearly all of the emissions arise from human activities (driving, using electricity, industrial activities, etc). If an acre of developed land was converted back to agriculture, those emissions would remain; the people who previously lived there would be continuing to conduct these activities, just in a different place. While higher-density development could reduce both electricity and transportation emissions somewhat, the net result would be nothing approaching a 70:1 reduction. To close, I am commenting because I have now seen this misleading 70:1 figure cited in multiple places -- CARB could contribute to the understanding of the emissions implications of land use change by not repeating it, and by citing (or developing) a more realistic figure to replace it. Disclosure: I am a consultant to environmental groups that generally favor the conservation of agricultural land. These comments are entirely my own. Thank you, Jim Downing Oakland, Calif.
Attachment:
Original File Name:
Date and Time Comment Was Submitted: 2014-04-02 13:40:50
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.