In the attached comment letter, we have summarized
several ongoing concerns we have with CARB’s modeling and
analyses; we also summarize several issues we have uncovered during
our review of the Draft SPU (we have not had adequate time to fully
review the entire Draft SPU, including the technical appendices).
We intend to provide further comments and technical review as well
as propose recommendations for moving forward in the SPU process,
both in writing and during forthcoming meetings with CARB and other
state agency staff (CDFA, CNRA, and CALEPA).
Sincerely,
Jeffrey Creque, Ph.D., Director of Rangeland and
Agroecosystem Management
Torri Estrada, M.S., Executive Director and Policy
Director
Jonathan Wachter, Ph.D., Lead Soil Scientist
Carbon Cycle Institute
245 Kentucky Street, Petaluma, CA 94952
Email:
testrada@carboncycle.org
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