Comment Log Display

Endangered Habitats League (EHL), as southern California
conservation group, appreciates the opportunity to comment on the
Working and Natural Lands Scoping Plans Draft Alternative
Scenarios.  

The scenarios err - and err grievously - in lumping forest and
shrublands together in a single category. Conifers forest (for
example, towering redwoods) and shrublands (for example, sparse
patches of coastal sage scrub hugging the ground) do not look
alike, act alike, or have even vaguely similar fire regimes and
fire behavior. We call on CARB to immediately withdraw these faulty
scenarios.

CARB should first consult with scientific experts on the major
differences between these two classes of vegetation, and separate
them according into two different categories.  The category of
shrublands should reflect their unique ecology, carbon
sequestration in soil and root systems, propensity to type-convert
to flammable weeds after vegetation removal or too-frequent fire,
and specific fire modeling characteristics.

In particular, CARB should engage independent experts on
appropriate fire management in shrublands. Outside of defensible
space for structures, roadside treatments, and strategic fuel
breaks for the purposes of staging and access, science-based
management does not include broad-scale treatments like vegetation
removal and prescribed burning. This differs completely from forest
systems, where prescribed fire can rectify fire-deficient
conditions. However, due to existing habitat degradation and the
baseline high frequency of anthropogenic wildfire in shrublands,
such treatments are counterproductive, and will result in
type-conversion to weeds, loss of carbon storage and biodiversity,
and increase in flammability and fire hazard.

After the above scientific process is conducted, please reformulate
a new and scientifically sound set of alternative scenarios.  In
concept, a combination of the objectives of Scenarios 1 and 2
(conservation and restoration, carbon sequestration, and climate
resilience) will best serve the State. But as it now stands, the
conflation of forests and shrublands is a blatant and egregious
mistake that renders the scenarios as a whole scientifically
indefensible.

EHL would be happy to work with CARB and to recommend qualified
fire ecologists for consultation.