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Gentlepersons:

Endangered Habitats League (EHL) support this component of
California's GHG reduction program and urges an ambitious effort
that goes far behind baseline trends.  We particularly stress the
importance of natural lands protection, which has the important
co-benefit of climate adaption, for example in the preservation
environmental gradients and movement corridors.   

However, while we agree that avoided conversion is a key factor in
many part of the state, such as Southern California, there should
be greater emphasis on the role of natural lands in sequestering
carbon per se.  Sequestration in soil is the major form of
sequestration in scrub systems.

The concept paper refers to "rangelands" rather than listing the
more specific habitat types.  Please clarify that rangelands
include coastal sage scrub, chaparral, and oak woodland.  This is
very important.

We support setting acreage targets.

There is much emphasis on restoration.  While EHL supports this
goal, restoration is also expensive.  It will be important to look
at the cost effectiveness of preservation/avoided conversion in
this context.

Thank you for your consideration.