Comment Log Display

California Licensed Foresters Association (CLFA) comments on AB 32
Draft Forest Sector Scoping

Printed copies of the following letter, including citations of
data sources, were delivered to the ARB on 8/1/08.

August 1, 2008

Ms. Mary D. Nichols, Chairman			
California Air Resources Board
1001 I Street PO Box 2815
Sacramento, CA 95812

Reference:  AB 32 Draft Scoping Plan:  Sustainable Forests

Dear Chairman Nichols,     

	CLFA appreciates the opportunity to comment on the above
referenced planning document.  We note, with pride, that forestry
is the only sector under AB 32 that is identified as a net carbon
sink.  California’s forested ecosystems, properly managed, offer
the potential to both mitigate and adapt to potential climate
change.  The purpose of this letter is to identify possible
shortcomings in the Draft and to suggest ways to meet and exceed
forest sector targets.
	We commend you for your decision to turn to the Board of Forestry
and Fire Protection (BOF) for assistance in meeting your AB 32
responsibilities.  The BOF is uniquely suited to this task. 
Fortunately, forestry’s unique suite of ecosystem services –
including carbon sequestration – can be expected to help attract
financing in an increasingly carbon constrained economy.
	CLFA agrees with the Draft that catastrophic wildfire and forest
conversion are two risks to AB 32 targets that need to be
addressed.  California foresters welcome the discussion.

Catastrophic Wildfire and Increasing Deforestation.  California’s
forests are estimated to store 1 Billion Tons of carbon.   The
importance of managing these lands to minimize uncontrolled
emissions of greenhouse gases is just beginning to be recognized. 

Unfortunately, the current trend line is poor.  Wildfires in
California and other western states are on the increase.  Already
in 2008, an unprecedented 1.1 million acres of forest and
wildlands have burned in the Golden State.   Hundreds of thousands
of these acres are on national forest lands.	
National forests in California hold greater than 50% of all live
tree carbon  in the state.  Deforestation is increasing on these
lands due to destructive wildfires converting extensive stands of
trees into fields of brush.  Last year alone, over 100,000 acres
of California national forests were burned into a deforested
condition.   This year that figure seems likely to be exceeded.	
Deforestation is a grave threat to forest sector targets, and not
adequately represented in ARB estimates.  When forests burn, there
are the immediate (and potentially massive) emissions of pollutants
and greenhouse gases that we see – and breathe – in smoke.  But
that’s just the beginning:  timber stands that are burned,
neglected and allowed to convert to brush fields slowly decay over
a period of decades, resulting in releases of methane, a very
potent greenhouse gas.  Because of the buildup of dead fuels and
brush, these areas often times reburn, again releasing CO2 and
other greenhouse gases.  Although more research needs to be done,
it appears probable that the emissions related to national forest
wildfires in California have not been properly quantified in the
Draft.  
Prompt reforestation following a wildfire is an established
practice on private lands, but sadly has become a rarity on
national forests.  Dead trees removed and utilized for forest
products also contain carbon that is sequestered for long time
periods or utilized as biomass energy, reducing fossil fuel
combustion.
Deforestation of national forest lands resulting from wildfire
must be stopped, and the trend reversed.  To do this will require
greater public awareness and support for active management by
qualified resource professionals.  We request the BOF and ARB
convey to the Forest Service that the status quo is not acceptable
and to enlist the cooperation of your federal partners in helping
the state meet its AB 32 targets.  
Clearly, the 2050 emission reduction goal can be greatly
facilitated by aggressive reforestation/afforestation efforts
between now and 2020.  These efforts include urban tree planting,
which CLFA strongly supports.   
Besides reversing deforestation, there is the need to prevent the
occurrence of catastrophic, stand replacing wildfires in the first
place.  Reducing high levels of flammable woody fuels in the forest
does not completely prevent wildfires, but lessens their size and
severity.  
Professional foresters can help California convert today’s brush
fields to tomorrow’s forests and transform unnaturally overstocked
forests from a fire-prone to fire adapted condition.  Required will
be new funding mechanisms and an investment in 21st century
infrastructure, discussed below.
	 
Forest Loss Through Conversion to Other Uses.  CLFA recognizes the
legitimate role of permitting and mitigation when it comes to
proposals to convert privately owned forestland to other uses such
as development or intensive agriculture.  Conversion decisions,
however, are often a consequence of a landowner’s inability to
make a reasonable profit on his or her timberland property. 
Forest management requires long term investments in land tenancy,
cultural improvements, and stewardship.  Faced with California’s
costly and duplicative forest practice regulations and declining
market conditions, many landowners feel driven to pursue other
options.
	The Draft suggests a need for more stringent forest conversion
permitting requirements as a means of conserving carbon sinks. 
CLFA agrees that this should be explored.  However, we feel that
the Draft does not go far enough in recognizing the role that
innovative public policy could play in encouraging stabilization
and new investment in the forest sector, promoting economic
incentives and sustainable forest management.

California Forestry in 2050 and Beyond:  Infrastructure for
Sustainability.  What kind of forests will we leave for our
grandchildren in 2050, or theirs in 2100?  CLFA believes that the
answer to this question must be, “Healthy, diverse, ecologically
resilient, fully stocked and growing.”
We believe that our profession, allied with related natural
resource disciplines, can get us there.  Given predictions that
climate change will impact our forests, CLFA believes that
science-based management is all the more essential to conserve
resources while facilitating ecosystem adaptation.  
But we need help in terms of public understanding and support. 
Doing nothing needs to be understood as the most devastating
course of action.
	Investment will also be needed in new technology and processing
facilities.  Although traditional sawmilling and lumber products
will remain part of the industrial mix, the potential exists for a
rural network of bioenergy facilities designed to convert woody
wastes from forest fuel treatments into carbon-neutral energy
products such as electricity, syngas and liquid transportation
fuels.     
The potential for this type of development is large and increasing
with advancing technology.  California currently produces 1,000 MW
(2%) of our electricity from biomass.  Estimates are that this
level can be sustainably raised to 4,700 MW,  as part of a larger
strategy to meet the state’s Renewable Portfolio Standard goals. 

Removing barriers to the development of biomass and other forms of
bioenergy will be critical to improving the health of our forests
and their ability to store atmospheric carbon.  There is hope that
revenue from capped sectors will play an important role in the
future, stimulating new investment and increasing opportunities
for forest stewardship on both public and private lands.     
CLFA is committed to helping the ARB and BOF in achieving – and
exceeding – AB 32 targets for the forest sector.  We hope this
correspondence will be helpful as you revise the Scoping Draft,
enlisting the carbon sequestration potential of the Golden State’s
vast forests and wildlands to the fullest possible extent.  
  		  
Sincerely yours, 
					 
Charll K. Stoneman, RPF #2375
President 

Cc:  	Mr. Stan Dixon, Chairman, and Members, California Board of
Forestry and Fire Protection (BOF).
        Mr. Tony Brunello, Deputy Secretary, Resources Agency.
	Mr. Richard Bode, Air Resources Board (ARB).
	Ms. Linda Murchison, ARB.
	Ms. Jeanne Panek, ARB.
	Mr. Randy Moore, Regional Forester, Pacific Southwest Region,
USDA Forest Service.
        CLFA Board of Directors.


The California Licensed Foresters Association, with a membership
responsible for the sustained management of millions of acres of
California forestland, represents the common interests of
California Registered Professional Foresters.  The Association
provides opportunities for continuing education and public
outreach to its membership, which includes professionals
affiliated with government agencies, private timber companies,
consultants, the public, and the academic community.  Governed by
an elected Board of Directors, CLFA was established in 1980 after
the passage of the landmark California Professional Foresters
Law.