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Dear Members of the Board,

As a PhD trained botanist,I  strongly object to the merger of
conifer forests and shrublands into a single category. There is no
functional utility in uniting these groups, because they store
biomass in different ways (above versus below ground) and they
arere subject to vastly different fire regimes, to vastly different
climate limits, and so forth.  This absurd simplification is not
just useless, it is actively harmful.

Most importantly, much of the state's vegetation has already been
mapped in detail using a hierarchical classification by CDFW and
CNPS, so lumping them actually undoes work that has already been
done.  Worse, it already ignores the crosswalk done by CDFW and
CNPS between vegetation types and fire ecology, information that is
freely available online.

It also leads CARB into problematic conflict with existing species
management scenarios under the state and federal Endangered Species
Acts. And it probably conflicts with 30x30.  And it probably
conflicts with fire models being independently developed by
insurance industry experts, although others in the State of
California are working to reconcile the insurance and CalFire
models.

This is absolutely wrong scientifically, and will lead to erroneous
management practices over large parts of the state for carbon
sequestration, climate resilience, and wildfire management. 

CARB should withdraw these fatally flawed scenarios, provide
separate categories (plural)for shrublands, and consult with
recognized outside experts on appropriate management strategies
that recognize that climate change and the extinction crisis are
two facets of the same problem.  Scenarios must simultaneously deal
with climate resilience, fire resilience, conservation, and
restoration simultaneously.  This is completely doable, especially
with current science and technology.  As noted above, some of this
work has already been done, and ignoring it helps no one.

Thank you for taking my comments.

Sincerely,

Frank Landis, PhD