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Comment 32 for Public Workshop: 2022 Scoping Plan Update – Natural and Working Lands Technical Workshop (nwl-2021-tech-ws) - 1st Workshop.


First Name: Jim
Last Name: Stewart
Email Address: drjimstewart@gmail.com
Affiliation:

Subject: Fix errors in 39 million tons of forest carbon credits documented in the CarbonPlan report
Comment:
Dear Adam and Team,
What a great team and an impressive plan! But it is so scary that
you are projecting up to 400 MMT of net emissions (no net removal)
from NWL by 2100. Please document the sources of these net
emissions, as it was not clear from your slides.

However, new Scoping Plan must fix the errors in the 39 million
tons of forest carbon credits documented in the CarbonPlan report
Systematic over-crediting of forest offsets
(https://carbonplan.org/research/forest-offsets-explainer), and
reported in detail at
https://insideclimatenews.org/news/05052021/the-climate-solution-actually-adding-millions-of-tons-of-co2-into-the-atmosphere/.
In fact, how can you justify any forest offsets, while forests are
net emitters?

SB 1383 requires diversion of organic wastes, which produces
millions of tons of nutrient-rich compost and digestate that could
be distributed on grasslands to increase soil sequestration. How
can you factor that increased soil sequestration into your plan?

It is disappointing that you are focusing 85% of your time on
analyzing carbon losses in forests and shrublands, because as you
know AB and SB 32 require consideration of co-benefits, which are
obvious for urban forests.

In addition, coastal wetlands and seagrass meadows (and kelp
forests) have huge co-benefits in terms of coastal protection and
fishery nurseries. How are you considering co-benefits in CARB
staff time?

Here are some links to recent review articles on sequestration in
seagrass (doi: 10.3389/fmars.2019.00317) and kelp (DOI:
10.1038/s43247-021-00177-9).
Thanks,
Jim Stewart, PhD

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Date and Time Comment Was Submitted: 2021-08-03 21:11:38



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