Comment Log Display

On behalf of the Carbon Cycle Institute, we are writing to offer
comments, suggestions, and amendments to the Discussion Draft of
the 2030 Target Scoping Plan Update, with emphasis on agriculture
and working lands.  We would like to direct you to our December
2016 comments on the earlier draft of the Scoping Plan Update and
our comments in response to “Carbon Sequestration Modeling Methods
and Initial Results for the Natural and Working Lands Sectors”, as
those comments are still highly germane and should be reflected in
this latest version.  We will provide further comment and
suggestions related to the proposed actions to “enhance” and
“innovate” in the Natural and Working Lands sectors (Chapter IV,
Section D4).

We want to highlight our disappointment that this Final Draft of
the Scoping Plan Update does not take appropriate and reasonably
achievable efforts to define robust goals, actions, and strategies
for the 2030 timeframe for Natural and Working Lands.  We strongly
feel that the lack of completion of the modeling efforts for
baseline for the Natural and Working Lands sector should not
preclude the development and discussion of near-term goals and
actions, including setting a robust overall goal.  To that point,
there are considerable existing and near-term efforts on carbon
sequestration and management of working and agricultural lands that
alone could make significant contributions to the 2030 Target, as
well as help advance our knowledge and on-the-ground impacts on
climate change, resilience, and the drought.

The Carbon Cycle Institute’s mission is to stop and reverse climate
change by advancing natural, science-verified solutions that remove
atmospheric carbon while promoting environmental stewardship,
social equity and economic sustainability. To that end, we support
projects that promote climate-beneficial management practices on
working lands throughout California, work to build the technical
capacity of land managers and producers to plan and implement
impactful projects that reduce GHGs and sequester carbon in the
lands base, and are heavily engaged in gathering scientific data on
the important role these practices can play in sequestering carbon
from the atmosphere.

California’s working lands and rangelands naturally capture carbon
from the atmosphere through photosynthesis and transfer it to the
soil, where it provides important ecological services, including
the enhancement of soil water holding capacity. Land managers can
dramatically increase carbon storage in California’s soils by
employing a number of practices recognized by the Natural Resources
Conservation Service (NRCS) as climate beneficial, including
compost application, riparian restoration, no-till farming,
windbreaks, agroforestry and other practices. Along with increasing
long-term carbon sequestration in soils and plant material, these
practices also offer additional water, habitat, and economic
viability benefits for farmers and working land managers.

We would like to see increased emphasis on the potential role of
soils in helping the state meet its 2030 GHG reduction goal of 40
percent below 1990, in light of both the tremendous demand from
producers to implement carbon-beneficial practices and the robust
infrastructure and leadership at the regional and local level ready
and able to move projects forward at scale. The State’s GHG and
carbon reductions targets for 2030 and 2050 are extremely
ambitious, which we applaud, but they are deeper than what has been
accomplished to date.  Without the natural and working lands
sector, in general, and carbon sequestration and soils,
specifically, it is difficult to see how the State will meet its
2030 and 2050 climate goals.  As detailed below in our comments,
the IPCC and leading climate experts agree that we must engage our
soils in agricultural and working lands in a significant manner to
address climate change, and we need to take significant steps now
to scale our efforts in this arena if we want to reap the benefits
in the
2030 (and 2050) timeframe.

Thank you for your just consideration of our comments and
recommendations.