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Dear Ms. Nichols and Ms. Livingston:

The Carbon Cycle Institute (CCI) appreciates this opportunity to
comment on the California Air Resources Board’s (ARB’s) Draft
Second Investment Plan (Plan).  CCI is committed to addressing
climate change by advancing science-based solutions, particularly
in working and natural lands, that remove atmospheric carbon, while
promoting environmental stewardship, social equity and economic
sustainability.  These comments are supplemental and reinforce the
comments and recommendations made in CCI’s comment letter submitted
on August 30, 2015 in response to the ARB’s draft concept paper. We
are pleased by ARB’s continued focus and refined strategies on
Working and Natural Lands in the Plan.  We also applaud the
creation and diligent work of the Natural and Working Lands Working
Group that is bringing together state agencies to develop the
critical strategies identified in the Plan.  The Plan creates a
solid foundation and emerging framework to achieve climate change
goals, including carbon sequestration and GHG reductions, in the
Working and Natural Lands sector.  CCI offers these comments to
enhance and strengthen the strategies outlined in the Plan for
Working and Natural Lands, including agriculture.

Thank you very much for the opportunity to comment on Plan.  We
plan to provide additional technical comments in December in
advance revised Draft Plan.  We have included (below) a summary of
our recommendations from our August 2015 comment letter.  If you
have any questions regarding our comments, please do not hesitate
to contact us. 


Sincerely Yours,

Torri Estrada						                Jeff Creque, PhD
Managing Director/Director of Carbon Policy		Director of
Agroecosystem
                                                                   
             Management