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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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