Comment Log Display

I have read and commented (for the Southwest Wetlands Interpretive
Association/SWIA) on the Natural and Working Lands Strategy (file
attached).  One of the commments SWIA made was that "forests" is a
very inclusive term/category and that not all forests can or should
be addressed as a single "entity."

The scenarios go one step further in the WRONG direction by lumping
forests and shrublands into a single category. I strongly object to
the merger of forests and shrublands into a single category. As we
made clear in our letter, and consistent with scientific studies
that demonstrate the vast differences within "forest" types and
more so between forests and shrublands, the current proposed
lumping is not defensible.  It will lead to erroneous management
practices over large parts of the state for carbon sequestration,
climate resilience, and wildfire management. 

Regarding the alternatives, it is apparent that current practices
(Business As Usual/BAU) has been a disaster for California's
natural habitats, as well as for urban and agricultural areas. None
of the alternatives as summarized in the technical workshop fully
addresses the needs of the NWL categories.  A synthesized version
of Alternatives 1-3 would more closely meet basic needs. For
example, statements such as "maximum wildfire defensible space" in
Alternative 3 are both vague and unjustified - more appropriate is
" Establish defensible scientifically recommended defensible space"
in Alternative 2.


CARB should replace these flawed scenarios with a set of new ones
that better reflect and represent scientific principles and
verified approaches.  That new set should treat shrublands as a
separate category from forests (which also needs to recognize
significant differences within forest types). After scientifically,
sound scenarios are recirculated, a focus on conservation and
restoration, carbon sequestration, and climate resilience will be
appropriate. 

Thank you for considering my comments.