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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:

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Date and Time Comment Was Submitted: 2014-04-02 13:40:50



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