Comment Log Display

January 4, 2022

Chair Liane M. Randolph 
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812

RE:	CHCPC Comment on the December 2, 2021 ARB Scoping Plan Natural
and Working Lands Workshop


Dear Chair Randolph:

On behalf of the California Habitat Conservation Planning Coalition
(CHCPC), thank you for your continued effort to engage stakeholders
and the public across the state to advance climate action with
nature-based solutions.  Habitat Conservation Plans (HCP) and
Natural Community Conservation Plans (NCCP) were created with the
state's support and participation for the conservation and
protection of land, species, and habitat, which allow for growing
regions across the state to thrive sustainably. These Plans are
ready, willing, and have the long-term infrastructure to acquire,
restore, and uplift land that can deliver on the state's goal to
achieve carbon neutrality and build climate resilience while
promoting biodiversity and access to open space.  Through land
acquisition, fully implemented Plans will permanently manage and
protect well over 2 million acres of carbon sequestering habitat.

CHCPC applauds the State's commitment to developing a comprehensive
strategy to inventory and implement nature-based solutions to the
impacts of climate change.  However, we remain concerned regarding
the dangerous oversimplification of landscape types and proposed
treatments that remain in the Scoping Plan discussions.

The following comments highlight opportunities for the California
Air Resources Board to focus its approach to a climate-resilient
future.

Thank you for your time and consideration.  Please do not hesitate
to contact me, should you require additional information.  CHCPC
looks forward to the continued partnership.

Sincerely,


John Hopkins
Director
(530) 601-1489
John4IEH@gmail.com


Below:	CHCPC Comments





CHCPC Comments on CARB's December 2nd Workshop for the 2022 Scoping
Plan Update Natural and Working Lands Component

A] Modeling section

There is  a single modeling category for forests, shrublands and
grasslands. [We assume that forests includes woodlands and riparian
areas as well as conifer forests.]  Slides 10 and 11 detail a
single modeling approach.   Inputs include the treatments 
"Clearcut, Harvest, Thinning, Mastication, Mechanical,
Bio/Chem/Herb, Prescribed Fire".  This may be convenient for
modelers.  However, the ecology, management needs, fire issues and
more for these landscapes are very different to forests and to each
other.  Woodlands, shrublands, grasslands and riparian areas must
all be individual categories, separate from forests and from each
other.

We note the California Natural Resources Agency's (CNRA)'s 2019
Natural and Working Lands Implementation Plan excluded chaparral
and shrubland management and restoration from modeling "due to an
insufficient understanding of their effects on carbon dynamics." 
Does CARB believe that CNRA's determination has changed since 2019?
 CARB must be deliberate in its modeling approach if the treatments
ultimately included in the Scoping Plan are to be successful.

B] The scenarios section 

The five scenario alternatives separate out grasslands from
forests.  But they continue to lump chaparral / shrubland, and
woodlands [also we assume riparian areas] with forests.

Management of shrublands, including chaparral and coastal scrub,
woodlands and riparian areas must each be addressed separately. 
They must be based on the ecology, fire issues, and overall
management needs that ensure the conservation of the different
vegetation types and their health and resilience.

Note that the State has a three-component vision for Natural and
and Working Lands.  The final scenario should follow this vision:

A] Protect land from conversion to more intensified uses by
increasing conservation incentives and pursuing local planning
processes that maximize development where it already exists;
B] Enhance the resilience of and potential for carbon storage and
sequestration on lands through management and restoration,
including expansion and management of green space in urban areas,
and reduction of GHG and black carbon emissions from wildfire and
management activities; and
C] Innovate biomass utilization such that harvested wood and excess
agricultural and forest biomass can be used to advance statewide
objectives for renewable energy and fuels, wood product
manufacturing, agricultural markets, and soil health, increasing
the resilience of rural communities and economies and avoiding GHG
emissions relative to traditional utilization pathways through
these activities.