Comment Log Display

Thank you for the chance to comment on the Sept. 12th 2024
discussion with CARB. I appreciate the talks focusing on forests
and wildfire, and the environmental justice questions and comments.
Overall, the approach appeared to favor massive extractions with
little or no carbon accounting conducted by the state or associated
entities. The first speaker and ensuing discussions seem to have
missed relevant discussion points. 

Please see example photos later in the attached document, below the
comments.

Due to the current format for comments submittal, my comments have
also been copied to others present, so that the comments may be
taken into account and to allow for specific responses. 

Regarding the first speaker: Two years ago, North et al wrote a
paper supporting the removal/logging of ~80% of the forests to make
them more "resistant" to climate change (fire, etc.) - i.e. massive
forest extraction to supposedly save forests. The authors based the
idea on "historic forest data." But the data they used in the paper
left out most of the available forest data in the archives. As part
of the work, they took a small subset of the archival data, showing
low forest density, leaving out archival evidence of variable and
higher forest density. 

Several scientific papers disprove a central idea of low-density
forests presented in North et al, 2022
(https://www.yahoo.com/news/uc-researchers-omit-key-evidence-203544768.html).
In addition to the archives, there is an abundance of historic
photographs showing variable and higher forest density.

The first presenter failed to mention the following: 
(a) years of empirical data shows that carbon emissions from
logging consistently exceed wildfire emissions (logging emissions
are 5-10 times greater than wildfire emissions per published
studies by Law and others); 
(b) archival data in about the variable density of historic forests
- which refutes the "low density" idea of "resistant" forests; 
(c) 12 years of data analyzed by Hart and others, showing that
forests with an abundance of bark beetles do not result in a
greater spread of wildfire; 
(d) published work by Meigs, Bond, Hanson, and many others showing
that fire severity is unaffected by beetle-killed trees; 
(e)  large and old growth trees up to ~4 feet DBH are removed
during forest extraction projects ("reducing stand density"/ "fuels
reduction" / "thinning" etc.);
(f ) many dense forests tend to retain adequate moisture to
experience low intensity fire - which defeats the idea that forest
extraction is the way to reduce fire intensity; 
(g) cumulative impacts of tree removals, including tree mortality
caused by "thinning" itself;
(h) well-documented soil drying after removals, which was mentioned
in comments, and even soil destruction;
(i) multiple cases of high intensity fire that occurs in forests
where tree removals were done prior to fire (2021 Dixie Fire is an
example).

One of the presenters even suggested that the removed trees could
be "put in a biomass facility," failing to mention that such
facilities are responsible for some of the worst pollution and
human health impacts that we are witnessing in CA - which are
related to diseases including cancer, and lung and heart diseases.
The person referring to "biomass facility" also failed to mention
that burning biomass releases more emissions than burning coal, for
an equal amount of energy produced
(https://www.biologicaldiversity.org/campaigns/debunking_the_biomass_myth/pdfs/Forest-Bioenergy-Briefing-Book-March-2021.pdf).


The pertinence of carbon emissions from industrial processing and
burning - which are far greater than wildfire emissions - should
not have been ignored in such a meeting. The extent to which
logging related carbon emissions are being routinely ignored by CA,
is addressed in a new 2024 report (cited in
https://shasta-cnps.org/conservation-news-september-2024/ ). 

Another speaker mentioned that "reducing stand density" in the
forest would be made up for "gain all that carbon back" in 10 years
when large trees reabsorb the lost carbon No empirical data was
provided. 

One speaker mentioned the intensity of big fires like the 2021
Dixie Fire but failed to mention that many of the large forest
patches that burned with high severity were previously logged - I
personally surveyed multiple parts of the Dixie and documented the
pre-fire removals of the largest trees in forests areas that burned
with high severity. The 2020 Creek Fire is a similar example.

Much gratitude is owed to Matt Holmes who commented on proposed
wood pellet operations and on the fact that "fuels reduction"
efforts dry out the soils. He mentioned that for forest extraction
results in disturbance to forest floor - this too has been shown in
field studies that were not mentioned at the meeting. Wood pellet
operations (and other "fuels reduction" efforts) routinely remove
the largest trees. 

Much gratitude is owed to one speaker who mentioned that removal of
massive numbers of trees can destabilize the remaining old growth
trees, an astute comment backed up by field data. This comment was
not adequately addressed. 

Astonishingly, there was no mention of snags as nesting, roosting,
denning, resting and other wildlife activities supporting much of
our biodiversity - the main emphasis was on removals without
accounting for the carbon value and wildlife value. The main point
emphasized removals with inadequate data. 

Coincidentally, reducing stand density to the extent being proposed
would most benefit industrial-scale logging in public lands (also
not mentioned). Failing to account for the carbon emissions from
forest extraction would be favored by industries seeking to utilize
the trees and snags for lumber, biomass energy, biofuels, and other
products the state claims are "renewable" and "clean." The public
should have a chance to objectively evaluate presentations, rather
than being exposed to industrial-level forest extraction
perspectives. Future meetings should provide the space for a
balance of scientific findings rather than findings that suit
industrial-scale logging and related removals.

Best regards,
Maya Khosla, MS.
Biologist and Writer