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National Park Service
Pacific West Region
1111 Jackson Street, Suite 700
Oakland, California  94607-4807

N3615 (PWR-NR)

September 30, 2008

Memorandum



To:  Mary Nichols, Chairwoman, California Air Resources Board	

From: Jonathan B. Jarvis, Regional Director, Pacific West Region	
Subject:NPS Draft AB 32 Scoping Plan Comments Downloaded to ARB
Website	


Dear Chairwoman Nichols:

The National Park Service (NPS) appreciates the opportunity to
comment on the California Air Resources Board’s (ARB) AB 32 Global
Warming Solutions Act Draft Scoping Plan.  AB 32 mandates the
reduction of 169 million metric tons of carbon dioxide equivalent
(MMT CO2e) by 2020, which will bring the state back to 1990 CO2
levels.  The goal of the forestry sector is to maintain the
current annual sequestration potential of approximately 5 MMT CO2e
through 2020.

We commend CARB for its leadership in defining global warming
solutions and for your attention to details in documenting the
complex role forests play in sequestering and emitting greenhouse
gases.  NPS agrees healthy forests maximize carbon sequestration;
however effective models are needed to quantify carbon fluxes and
stocks on park lands.

We would note that, first and foremost, the NPS is committed to
forest and fire management practices that maintain the integrity
of our forested ecosystems.  These practices, which include the
reintroduction of natural fire cycles to forested landscapes,
increase resiliency to drought and fire disturbances that climate
change will likely exacerbate.   They also may have the co-benefit
of reducing landscape emissions of greenhouse gases and criteria
pollutants while increasing carbon sequestration.  Although such
co-benefits are not the primary NPS mission, we believe that it is
in the mutual interest of both the NPS and ARB to investigate and
quantify those benefits.

To that end, we would like to participate in an AB32 Forestry
Protocol "Public Lands Work Group" whose objectives would include;
developing carbon inventories on public lands, identifying forest
and fire management research (or pilot) projects needed to
increase our understanding of carbon sequestration on forested
lands, and identifying national park projects eligible for funding
from carbon offsets purchased by other parties. 

Some other questions of interest to the NPS include (but are not
limited to):

•What accounting
procedures are being developed so that public land managers may
participate in the growing carbon market?

•What are the trade-offs
between managed fires vs. wildfires, in terms of greenhouse gases,
criteria air pollutant emissions, and carbon/biomass stocks?  Is
there a way to allow more managed fires (instead of waiting for
wildfires) to help increase overall carbon storage and reduce
overall criteria air pollutant emissions?
 
We look forward to further exploring these mutual interests and
welcome further collaboration with ARB in implementing AB 32
forestry objectives and facing the challenges of climate change
impacts and sequestration potential on public lands.  Please
contact Judy Rocchio, Regional Air Quality Coordinator at
510-817-1431 if you have questions regarding our comments.
 

/s/ Patricia L. Neubacher for

 Jonathan B. Jarvis