This is resend of comment sent as pdf. I am not sure if
you received it.
June 22nd 2022
Liane M. Randolph
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812
RE: Comment on CARB’s 2022
draft scoping plan update
applaud CARB for having a much more extensive approach to Natural
and Working Lands [NWLs] than in the previous update. This
includes having shrubland / chaparral, grasslands, wetlands, and
sparsely vegetated lands as separate categories to forests and
having a very extensive and complex modeling appendix for NWLs.
The California Habitat Conservation Planning Coalition
focuses on the oak woodland component of forests, on shrublands /
chaparral, grasslands and wetlands because these categories are the
main components of our conservation plan preserve systems.
Our Natural Community Conservation Plans [NCCPs] and Habitat
Conservation Plans [HCPs] are located around the state, especially
next to the urban edges of major metropolitan areas. When all
of our plans are fully implemented, they will permanently protect
over two million acres, with in perpetuity management and
monitoring. While primarily focused on the conservation of
biodiversity and ecosystem functioning, they also address carbon
storage and sequestration. For example, they protect natural
and working lands from carbon-emitting land conversion and seek to
minimize vegetation loss to wildfires. Our plans are well
positioned to manage significant landscapes in critical areas of
the state for carbon storage if funding is available to help
facilitate that management.
We note that the primary
approach of this Scoping Plan Update’s NWL component is to
focus on the impacts of management strategies on carbon emission
and carbon sequestration, addressing carbon pools for which there
is sufficient data and ongoing carbon measurements, and dealing
with ongoing land management methods.
We just have a few
comments on the preferred scenario.
A. It states that current wildfire and other
issues will make NWLs a net emitter of 8 million metric tons of
carbon dioxide equivalent per year from 2025-2045 [Page 72].
But on page 71 it states that “the results of the modeling
demonstrate that regular NWL management over the next two decades
can increase carbon stocks from the Reference Scenario trajectory,
reduce GHG emissions from lands, and improve ecosystem and public
health.” Also, table 3-5 on page 112 states there will
be average GHG emission reductions for forests / shrublands /
grasslands. Items 2 and 3 contradict item 1 above. We need
clarification and consistency.
states that there will be 2 to 2.5 million acres of treatment
annually [forests, shrublands / chapparal and grassland
combined]. Page 64 states treatments will be “through
regionally specific management strategies that include prescribed
fire, thinning, harvesting and other management
actions”. Other information in the NWL modeling
appendix states that shrubland / chaparral management will be
through “bioChemHer, mastication, other mechanical,
prescribed burns” and grassland management will be through
“bioChemHer and prescribed burning.”
[BioChemHer is a catch all phrase encompassing chemical treatment
to inhibit biological growth of target organisms, NWL Modeling
Appendix, Page 54.]
available and appropriate, the dominant treatment should be annual
well managed grazing, such as rotational grazing. This will
remove all but a short stubble of annual grasses. It will
encourage reappearance of native perennial grasses and forbs
[annual flowering plants]. In much of southern California,
the absence of livestock prevents grazing. Mechanical removal
should be used adjacent to human communities and along
roadways. Prescribed burning is an option where
appropriate. Chemical treatments should only be used in
very localized areas and as a last result.
Shrubland / Chaparral treatments
Currently, there is extensive ecological
damage to these lands by mechanical removal, including
bulldozing. Most of this should stop. Construction of
firebreaks adjacent to human communities is often appropriate.
C. The actions for the proposed scenario
include “no land conversions of forests, shrublands/chaparral
or grasslands” [Pages 63-64]. This would include
conversion of the natural lands to various types of human
development and conversion between types. Examples of the
latter are conversion of grasslands to vineyards or orchards, and
conversion of chaparral and coastal sage scrub to non-native
grasslands and weeds through too-frequent, severe wildfires.
While “no conversion” is
ideal, it is unrealistic. Instead, there should be very
robust goals for major reductions in urban / suburban / rural
sprawl and in carbon emitting conversions of natural lands to
Thank you for the opportunity to
John Hopkins, Ph.D.
California Habitat Conservation Planning Coalition