Comment Log Display

Urban Forest Protocol – Summary of Evidence

AB 32 Offsets Challenge – Public Comments on October 19, 2011

Laurie Williams and Allan Zabel, as individuals and as volunteers
for Citizens Climate Lobby

Summary of Evidence that Proposed Greenhouse Gas Offset Protocols
and Regulations do not meet the AB 32 Integrity Criteria

Standard in Protocol:
The proposed Urban Forest Protocol would provide offset credits for
urban forest project that meet the description of such a project
and are by or for a municipality, educational institution, or
utility.  This is contrary to the AB 32 Integrity Criteria -- the
requirement that all emission reductions meet the following
criteria (See Section 38562(d)): 

AB 32 Integrity Criteria:

“(d) Any regulation adopted by the state board pursuant to this
part or Part 5 (commencing with Section 38570) shall ensure all
of the following:
(1) The greenhouse gas emission reductions achieved are real,
permanent, quantifiable, verifiable, and enforceable by the state
board.
(2) For regulations pursuant to Part 5 (commencing with
Section 38570), the reduction is in addition to any greenhouse
gas emission reduction otherwise required by law or regulation,
and any other greenhouse gas emission reduction that otherwise
would occur.

Evidence of Failure to Meet Integrity Criteria

1.  Any Net Tree Gain: In the Protocol, the ARB establishes the
standard for additionality as any net tree gain.  This ignores the
creation and maintenance of urban forests by municipalities as
ongoing activity which have occurred and are still occurring
without an offset incentive.

	a.  San Francisco Urban Forest Program: “This year marked the
completion of the Mayor’s Trees for Tomorrow campaign to plant
25,000 trees over a 5-year period. The successful program exceeded
its goals by planting 26,408 trees in 5 years. Averaged over the
course of the Mayor’s Trees for Tomorrow initiative, the City has
been meeting the Urban Forestry Council’s goal of planting 5,000
trees per year for each of the past five years. Additionally, San
Francisco Unified School District began its 2012 by 2012 campaign
to plant 2012 trees by the end of 2012.”  See Attachment 1, p.1.

	b. Los Angeles One Million Tree Program: “ Mayor Antonio
Villaraigosa of the City of Los Angeles has charted a course for
sustainable growth, and the region’s community forest is a critical
component of that vision. In September 2006, the mayor announced
his plan to plant one million trees over the next several years.
The Million Trees LA initiative draws attention to the importance
of urban forests for the  economic, environmental , and social
health of Los Angeles.”  See Attachment 2, p.1.

	c.  New York City One Million Tree Program: “New York City, the
largest city in the United States and one of the world’s major
global cities, maintains trees as an integral component of the
urban infrastructure (Figure 1). Since 1995, over 120,000 trees
have been planted along the streets of the city’s five boroughs.” 
See Attachment 3, p.1.

2.  Urban Forests are Cost Effective for Municipalities: Several
studies show that the creation and maintenance of urban forests
creates numerous environmental benefits for municipalities and
creates economic benefits greater than the costs associated with
the urban forest programs.  Therefore, these activities are almost
certain to continue occurring without an offset incentive program.

	a.  City of Berkeley: “Total annual benefits produced by
Berkeley’s street and park trees were estimated to have a value of
$3.2 million, about $89 per tree and $31 per resident. Street trees
produced benefits valued at $2.8 million ($91/tree, $27/capita),
while park tree benefits were valued at about $433,000 ($76/tree,
$4/capita). Over the same period, tree-related expenditures were
estimated at nearly $2.4 million. Net annual benefits were
therefore calculated at $876,000, or $24 per managed tree. The
Berkeley municipal forest returned $1.37 to the community for every
$1 spent on management.”  See Attachment 4, pp. 23-4.

	b.  New York City: “Over the years, the city has invested millions
in its urban forest. Citizens are now receiving a return on that
investment—trees are providing $5.60 in benefits for every $1 spent
on tree planting and care. New York City’s benefit-cost ratio of
5.60 exceeds all other cities studied to date, including Fort
Collins, Colorado (2.18), Glendale, Arizona (2.41), and Charlotte,
North Carolina (3.25).”  See Attachment 3, p.3.

3.  Air Quality Planning: The creation and maintenance of urban
forests is relied upon by California air pollution control
districts in their plans to reduce air pollution.  These planning
projections do not rely on offset incentives.

	a.  Sacramento Area: “The estimated emission reductions from this
urban forest development program for the Sacramento region are
summarized in the following table. The estimated 2018 VOC reduction
is about 0.8 tpd, but the credited reduction is limited to 0.2 tpd.
This is consistent with the EPA policy for incorporating emerging
and voluntary measures in a SIP that limits the amount of emission
reductions allowed due to the uncertainty and untested nature of
the control mechanisms.”  See Attachment 5, pp. 7-19, 7-20.

4.  Benefits to Utilities: Some utilities already have extensive
and long-standing urban forest programs which are of economic
benefit to the utility.  Therefore, these types of programs occur
in the course of business-as-usual.

	a.  Sacramento MUD: “From SMUD’s perspective, the tree-planting
program represents a type of Demand Side Management programs that
have a tangible economic value to the utility.  This value can be
quantified based on avoided supply costs of energy and capacity
during high cost of summer peak load periods, or the decrease in
supply costs to the utility due to reduced electrical loads. SMUD’s
total investment in the program since the program inception in 1990
has been about 30 million dollars and approximately 1.5 million
dollars for 2008. Through 2008, over 450,000 trees have been
planted through the program.”  See Attachment 6, p.2.

List of Attachments
1.  San Francisco Urban Forestry Council Annual Report, September
2009
2.  The Benefits of One Million Trees in LA, USDA/Forest Service,
undated
3.  New York City, New York, Municipal Forest Resource Analysis,
March 2007
4.  City of Berkeley, California, Municipal Tree Resource Analysis,
March 2005
5.  Sacramento Regional 8-Hour Ozone Attainment and Reasonable
Further Progress Plan, December 19, 2008
6.  SMUD Shade Tree and Cool Roof Programs: Case Study in
Mitigating the Urban Heat Island Effects, undated