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Comment 579 for General Comments for the GHG Scoping Plan (sp-general-ws) - 1st Workshop.


First Name: Barbara
Last Name: Rivenes
Email Address: brivenes@sbcglobal.net
Affiliation: Sierra Nevada Group/Sierra Club

Subject: AB 32 Draft Scoping Plan comments
Comment:
Thank you for the opportunity to submit comments on the future
goals and implementation of AB 32 - one of the most important
legislative opportunities to address climate change and greenhouse
gas emissions in our state.  The goals and implementation measures
must be stringent and yet attainable. I am submitting these
comments on behalf of the Sierra Nevada Group of the Sierra Club. 
Members of our Group reside in Nevada County and parts of Yuba and
Sierra counties.  And I am submitting these remarks in the General
Comment category as they overlap and do not easily fit into the
more specific sections. Further I would like to acknowledge the
Sierra Nevada Alliance for their help in developing comments for
those of us living in the Sierra.

Below are my comments.




October 1, 2008
California Air Resources Board
Re: AB 32 Draft Scoping Plan comments
I am commenting on behalf of the Sierra Nevada Group of the Sierra
Club.  We represent Sierra Club members living in the foothills of
the Sierra Nevada encompassing Nevada county and parts of Yuba and
Sierra counties.  AB 32 provides the opportunity to be proactive
about climate change and the role of greenhouse gas emissions in
the environment.  The goals and implementation must be stringent
and yet attainable.  The following are some points 
1)Our priority recommendation is that the Sierra Nevada region be
included in the Plan and in any Regional Planning Framework. Any
vehicles for developing regional targets for reducing GHG
emissions should include the Sierra Nevada region.  The Sierra
Nevada is the third fastest growing region of the state of
California. We supply over 65% of the state’s developed water. Our
region houses half the animal and plant life of the state. Millions
of people visit the Sierra Nevada every year. The use of
Metropolitan Planning Organizations would virtually exclude 20 of
the 22 counties within the Sierra Nevada region and not fully
address the land-use related greenhouse gas emissions to which
they both contribute to and are affected by.  Though we do support
regional planning, but feel strongly that a regional approach
beyond the MPO’s needs to be recognized.   We recommend that CARB
create a  mechanism for geographic implementation of AB 32 in the
Sierra Nevada.
2)We further recommend strong and enforceable mechanisms for
reducing greenhouse gas emissions through improved land use and
transportation policies and including a larger target.  Improving
land use planning is important for the Sierra Nevada. The
population of some counties in the Central Sierra is expected to
increase by 40 to 84% over 2000 levels by 2020. If current trends
continue, much of this new population will be accommodated by low
density residential development, a dominant development pattern
throughout the region that consumes valuable habitat, working
landscapes, watershed infrastructure, and increases per capita
vehicle miles traveled. Land use and city and county general plan
decisions should be elevated to a central focus of the Plan.  We
support efforts to make sure the Scoping Plan for AB 32 includes a
better framework for land use and transportation, and believe that 
the 2 million metric target set for land use is far too low to
effectively reduce carbon emissions associated with vehicle miles
traveled. The “Climate Action Team Proposed Early Actions to
Mitigate Climate Change in California, Draft for Public Review,”
allotted 18 MMT by 2020 to “regional transportation/smart growth
land use measures.”  Surely the draft Scoping Plan can match this
target.  We would urge CARB to prioritize policies to fund public
transportation, ensure creation of “walkable” communities,
reduction of vehicle miles traveled even in our rural areas,
support adoption of a statewide Indirect Source Rule for carbon
emissions and assign value to natural landscapes that sequester
carbon which would encourage planning entities to adopt land use
plans that conserve such landscapes.
3)Also important to consider are the implications land use
planning has for wildfire hazard. Evidence suggests that
residential and commercial structures in the wildland urban
interface exacerbate the likelihood of wildfire. In the Sierra 94%
of all new projected development is expected to take place in areas
of very high or extreme wildfire hazard.   Wildfires can be a major
source of carbon emissions and particulate matter during the summer
months throughout the state. AB32 can provide a framework for rural
counties to improve land use planning and not only further reduce
carbon emissions, but also would serve as a valuable means for
protecting working landscapes and local food sources, and
preserving watershed infrastructure. Watershed protection will
become an issue of greater importance as global warming begins to
affect the snow storage capacity provided by the mountains of the
High Sierra. AB32 is an opportunity to encourage better planning
throughout the state, including, if implemented carefully, better
planning for the watersheds of the Sierra Nevada that are
essential to the health and security of our water supply.  
4)It is important to dedicate water saved from water efficiency
for drought and in-stream flows can help with climate adaption
strategies.  The Scoping Plan should be applauded for promotion of
water efficiency as a means to save energy.  More detail on how
water efficiency will be implemented is needed. We encourage CARB
to note, however, that these water savings should not be used to
support new growth and expanded development, but to support
existing development and agriculture in times of drought and to be
allocated back to the environment for in-stream flows. In the past,
water savings have been used to support new growth and development,
instead of being returned as in-stream flows for habitat needs or
saved for existing development and agriculture to create a buffer
in times of drought. However, if the saved water was allocated to
existing communities for times of drought, and/or allocated for in
stream flows to reduce the stress to aquatic habitat, then these
water savings would lead to a reduction in greenhouse gases
overall.  All Sierra Nevada streams and rivers have been impacted
over the past 150 years through a series of human development. 
5)We commend CARB for acknowledging the need to maintain current
carbon stocks in forests. We encourage you to develop a
sophisticated approach to sustaining forests and conducting fuel
load reduction to address catastrophic fire. This approach is more
than locking up forests in their current condition (overstocked and
lacking naturally-occurring fire regimes to maintain their health)
– and more than taking out trees to reduce fuel load, irrespective
of tree diameter and greater ecological functions.  The Plan should
recognize that fire is a natural and necessary part of California’s
environment and will be an important part of how our natural
systems adapt to a changing climate. Suppressing all natural fire
to achieve greenhouse gas emissions is not an effective tool for
our future. Our forests need fire to be healthy. We encourage the
state to focus fuels reduction efforts (and other proactive fire
planning activities) on protecting communities from fire.  
6)We also encourage CARB to address other carbon sinks beyond pine
trees. This includes oak woodlands, grasslands, soil, wetlands and
other vegetation. To focus simply on forests and not address
carbon sequestration through these other habitats and vegetation
misses an important part of the carbon cycle. The California Oak
Foundation is a great resource on oak sequestration.
We recommend that CARB and the Department of Conservation create a
statewide program to inventory and assess the carbon sequestration
and storage of natural and working landscapes across the state,
and develop protocols for measuring carbon sequestration and
stocks.

Sincerely,
Barbara Rivenes

  

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Date and Time Comment Was Submitted: 2008-10-01 14:36:06



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