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Comment 50 for Public Input on Cap-and-Trade Auction Proceeds Second Investment Plan (investplan2-ws) - 1st Workshop.


First Name: John
Last Name: Hopkins
Email Address: ieh@cal.net
Affiliation: California HCP Coalition

Subject: Need for a Habitat Lands Conservation component
Comment:
Thank you for this opportunity to comment on behalf of the
California Habitat Conservation Planning Coalition, whose members
include local government led conservation plans across the state,
NGOs and businesses.

The draft plan includes a very important natural resources
component - "conservation and improved management strategies for
achieving net climate benefits and long-term carbon sequestration
on natural and work lands" (Figure ES-1 and Figure 10, page 28). 
It recognizes that "protection and sustainable management of these
lands and resources to develop resilient carbon storage will be
pivotal in meeting climate goals" (Page 3).  It states that
"Investment in resilient carbon storage across all land types is of
particular importance"(Page 43). The Targets and Goals for the
Second Investment plan (Figure 15, page 42) states "protect,
restore and manage natural and working lands so they store carbon
and provide net GHG benefits."

These statements recognize the importance of natural lands in
meeting state GHG goals, and that this includes all land types.

However, the current natural resources components only address a
subset of these lands. The components are Healthy Forests (forest
health restoration, forest legacy and land conservation and urban
forestry) (page A-7); Wetlands and Watershed Restoration (Delta and
coastal wetlands, mountain meadows habitat and water efficiency on
CDFW lands) (page A-7); and Agricultural Land Preservation (page
A-4).

Missing from this suite of actions is the preservation of Habitat
Lands such as oak woodlands, chaparral, coastal scrub and desert
lands, key areas for meeting the long-term GHG reduction targets.

Creation of a Habitat Lands Conservation component, focused on the
protection of lands threatened by conversion such as suburban
development, needs to be a major item in the Second Investment
Plan.  

These other habitats have very extensive stored carbon, especially
soil carbon (Potter, 2010), much of which is lost when development
conversion occurs.  In addition, they are often ongoing carbon
sinks, or can become carbon sinks through management measures. 
Scientific studies are increasingly showing the importance of these
lands for addressing GHG levels.  (See examples  of recent
scientific and technical findings below).

Programs such as large landscape-scale Natural Community
Conservation Plans and Habitat Conservation Plans offer excellent
opportunities which the Second Investment Plan should use.  These
programs include development of preserve management plans, plus in
perpetuity monitoring and management and are highly leveraged. 
They will allow for management that protects already stored carbon
and maximizes opportunities for additional carbon sequestration.


Comment on specific items in the draft Second Investment Plan

Figure 2, page 6. Last item (carbon storage)
Please add "and other natural lands" after "rangelands"

Figure 16, page 45, third bullet item
Please add " and fee title acquisition" after "conservation
easements".   
There are various situations where natural lands important for
carbon sequestration and threatened by development can only be
protected by fee title easement.  It is our understanding that
there are concerns about whether fee title acquisition properly
protects natural lands.  In fact it does, at least with NCCPs and
HCPs, as the acquisition process includes restrictions that protect
the land in perpetuity and prohibit conversion.  Also management
plans and adaptive management programs for fee title acquisition
lands will ensure protection of existing soil carbon and maximize
future carbon sequestration.


Some recent scientific and technical findings

There have been measurements of carbon fluxes at a few California
non-forest locations; grasslands, oak savanna, and southern
California chaparral.  In dry years, rangelands are often a carbon
sink, absorbing more carbon than is emitted into the atmosphere by
respiration.  There is data showing that natural lands with woody
vegetation, including oak woodlands an
chaparral, are net carbon sinks.  For example, Liu et. al. (2012)
determine that grasslands and shrublands in Mediterranean climate
California are a carbon sink ( -6.4 to +0.3 teragrams of carbon a
year for the entire area).  Silver (2009) and DeLonge et. al.
(2014) state that California rangelands have the potential for
considerable carbon sequestration in the soil.  Baldocchi (2009)
states that oak woodlands are carbon sinks ( - 92 +/- 43 gms carbon
per square meter per year). A mature, 100 year old growth chamise
chaparral stand was found to sequester 58 grams of carbon per
square meter per year on average over a seven-year period (Luo
et.al. 2007).  Walter Oechel and colleagues at San Diego State
University have conducted broader studies on Southern California
Chaparral and concluded that chaparral ecosystems are a significant
carbon sink. (Oechel, 2013)

The loss of natural ecosystems is severe and ongoing.  For example,
Liu et al (2012) projected that 17 percent of the grassland and
shrubland areas in California's Mediterranean climate region will
be lost to conversion between 2005 and 2050.  The major causes are
urban/suburban/rural development and conversion to orchards and
vineyards.  Essentially all of the remaining coastal sage scrub
habitat in southern California that is not protected as
conservation land (primarily through Natural Community Conservation
Plans) will be lost to suburban and rural development.  All of
these conversions will result in substantial release of CO2 into
the atmosphere.  For example, conversion of natural ecosystems to
agricultural land results in loss of 25 to 50 percent of the
original organic carbon (Lal, 2001).

When natural and working lands are converted to urban / suburban or
rural development there are two carbon impacts.  The first is loss
of vegetation and soil carbon from land clearing and grading.  The
second is long term increased carbon emissions by vehicles and
other uses in the developed areas.  For example, a recent UC Davis
study if Yolo County shows that the annual carbon emissions level
of urban lands is 219-fold higher than rangelands and 70-fold
higher than irrigated croplands (Jackson et al, 2012).  

References

Baldocchi D. (2009)  Carbon and Water Exchange of an Oak-grass
Savanna and Peatland Pasture Ecosystem.  Berkeley Faculty
Roundtable on Environmental Services in Rangeland Production
systems.  March 20 2009.  University of California, Berkeley.

DeLonge MS, Owen JJ and Silver WL. (2014) Greenhouse Gas Mitigation
Opportunities in California Agriculture: Review of California
Rangeland Emissions and Mitigation Potential. Nicholas Institute
GGMOCA R 4. Durham, NC: Duke University

Jackson L. et.al. (2012) Adaptation Strategies for Agricultural
Sustainability in Yolo County, California.  California Energy
Commission Publication number: CEC-500-2012-032.

Lal R. (2001) World Cropland Soils as a Source or Sink for
Atmospheric Carbon, Advances in Agronomy. 71:145-191.

Liu S. et. al. (2012) Baseline and Projected Future Carbon Storage
and Greenhouse-Gas Fluxes in Ecosystems of the Western United
States. In Zhu S and Reed BC, eds. Baseline and Projected Future
Carbon Storage and Greenhouse-Gas Fluxes in Ecosystems of the
Western United States. Chapter 5. U.S. Geological Survey
Professional Paper 1797. Reston VA.

Luo H. et.al. (2007) Mature Semiarid Chaparral Ecosystems can be a
Significant Sink for Atmospheric Carbon Dioxide. Global Change
Biology. 13:386-396.

Oechel W. (2013) The Effects of Climate Change: Elevated CO2,
Climate Variability, and Fire, on the Functioning and Atmospheric
Feedbacks of Chaparral of Southern California and the Desert of
Baja California, Mexico.  Powerpoint presentation.  February 6
2013.
www.otmed.fr/IMG/pdf/Walter_Oechel_06_February_2013.pdf

Potter C (2010) The Carbon Budget of California.  NASA Publications
81 http://digitalcommons.unl.edu/nasapub/81

Silver WL, Ryals R and Eviner V. (2010) Soil Carbon Pools in
California's Annual Grassland Ecosystems.  Rangeland Ecology and
Management. 63:128-136.

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Date and Time Comment Was Submitted: 2015-11-13 12:06:51



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