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Comment 83 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameKaren
Last NameMaki
SubjectMore Forest Carbon Sequestration & Storage is Needed and Possible

The Draft 2022 Scoping Plan should enable the removal of more carbon dioxide by forests than it does.  The carbon removal should happen now.

The preferred NWL alternative 3 calls for more forest thinning as the only forest-related action.  In the short-term thinning will result in more greenhouse gas emissions.  Every tree removed is carbon lost.  Were there to be a fire, only roughly 3% of the tree carbon burns.  Thinning removes far more carbon than if all the thinned areas burned.

Furthermore, fuel reduction may or may not reduce fire intensity.  Many studies have shown it doesn’t.  The plan assumes that fuel reduction will result in more resilient carbon-rich forests in the long-term, but it’s not proven. If it were successful, the improvement would happen to late for us to address the climate crisis.

Forest management practices should be modified so that they don’t produce dense young flammable stands of trees and can begin to increase carbon storage rather than detract from it by:

·        Increasing the length of plantation rotation cycles

·        Reducing or eliminating the amount of new even-aged harvesting such as clearcut

·        Eliminating salvage logging and instead retaining dead trees, which store carbon for decades, retain moisture, provide habitat for more wildlife than live trees.

·        Retaining more mature trees.

 Lastly, electric utilities should be required to insulate their bare wire distribution lines rather then remove millions of trees that could be sequestering and storing carbon.


In summary, many existing forest management practices as well as our preferred ways of responding to fire and antiquated utility equipment increase carbon dioxide. Instead California needs to stop thinning forests and prohibit salvage logging and the removal of millions of trees by electric utilities. California should promote forest management practices that result in more stored and sequestered carbon now.

Original File Name
Date and Time Comment Was Submitted 2022-06-23 13:11:23

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