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Comment 64 for Draft Proposed First Update to the Climate Change Scoping Plan (proposed-sp-ws) - 1st Workshop.


First Name: Vanessa
Last Name: Raditz
Email Address: vraditz@berkeley.edu
Affiliation: UC Berkeley School of Public Health

Subject: Include Urban Agriculture in the AB32 Scoping Plan Update
Comment:
Vanessa Raditz
Master of Public Health Candidate
Environmental Health Sciences
University of California, Berkeley
vraditz@berkeley.edu

April 28, 2014

California Air Resources Board 
1001 "I" Street 
Sacramento, CA 95814


Subject: Include Urban Agriculture in the AB32 Scoping Plan Update

Re: Public Comment on AB32 Scoping Plan Update


Summary: The Scoping Plan Update for AB32 has taken important steps
in recognizing the importance of agriculture and working lands for
carbon mitigation and other co-benefits. The plan could be further
improved by including urban agriculture. The following comment is
broken into three sections, as follows:
1)	Including urban agriculture could for reductions in greenhouse
gas emissions from localizing food production, as a carbon sink,
and as a bioremediator for other short-lived climate pollutants,
along with other co-benefits for public health and city planning. 
2)	Including urban agriculture in the scoping plan could
incorporate policy initiatives the state has already passed. 
3)	CARB should consider actions for legalizing and incentivizing
urban agriculture, funding urban agriculture in environmental
justice communities, and consider penalties for the conversion of
urban agricultural land into development projects as a part of
climate mitigation and co-benefit strategies.


1)  Including urban agriculture in the scoping plan would
contribute to reductions from GHG and short-lived climate
pollutants, and incorporate more public health and city planning
co-benefits such as land conservation and environmental justice,
all of which are described in other sections of the scoping plan:

Greenhouse gas reductions
The scoping plan outlines the GHG reduction impacts of agricultural
land, such as the research showing that “agriculture can also be a
carbon sink, where carbon is stored (sequestered) in both crops and
soil” (pg 65). However, the scoping plan could be improved by
looking at the potential for GHG reductions from urban agriculture
projects. The scoping plan should evaluate the direct GHG carbon
sequestration from urban agriculture projects since trees,
vegetation, and un-paved soil all have carbon sink properties . The
scoping plan should also evaluate the indirect impacts from
incorporating urban agriculture with green zone  and smart growth
city planning strategies to reduce energy consumption. Finally, the
scoping plan should evaluate the GHG gas emissions reductions from
localized food systems, including sustainable production, cooling
and refrigeration, food waste minimization  and reduced
transportation from  agricultural delivery systems. 

o	Policy suggestions: Legalize and incentivize urban agriculture 
o	Allow urban agriculture projects to claim credits for moving us
towards our climate goal.

Short-lived climate pollutant reductions
One of the most important new components to the scoping plan is the
attention to mitigation of short-lived climate pollutants. The ARB
recognizes that reducing these chemicals can have a faster impact
on climate change, and will also have many co-benefits in terms of
public health. The scoping plan acknowledges how urban forestry can
have an impact on both GHG reduction and remediation of air
quality. Vegetation from urban agriculture acts as a passive filter
effect on short-lived climate pollutants  and reduces the
production of these compounds from reduction of diesel delivery
systems. 

o	Policy suggestion: Fund and support research into the carbon
sequestration and short-lived climate pollutant remediation effects
of urban agriculture, and methods that enhance these functions.

Co-Benefits for public health and city planning
The AB32 Scoping Plan Update includes more extensive consideration
of the co-benefits of GHG reduction strategies. For instance, it
explains that “efforts to reduce GHG emissions and enhance carbon
sequestration on natural and working lands also have significant
economic, social, and environmental co-benefits” (pg 78). There are
many public health benefits to urban agriculture, particularly for
nutrition and food security, but also for environmental remediation
. Additionally, there are many city planning co-benefits, including
organic waste management, biodiversity, microclimate control
(combats heat island effect), urban greening, economic
revitalization , strengthens communities and social capital,
cultural heritage, and education. 

o	Policy suggestion: Fund and support place-based public health and
city planning initiatives into the co-benefits of urban agriculture
for transportation, energy use, water use, air quality, nutrition,
and health.

Conservation of Agricultural Land
The current scoping plan focuses on the necessity for the
conservation of agricultural lands and forests. It states that
“local and regional land use planning actions and policies need to
more fully integrate and emphasize land conservation and avoided
conversion of croplands, forests, rangelands, and wetlands—as well
as expansion and promotion of urban forestry and green
infrastructure” (pg 78), and that “this could be accomplished by
using incentives for conservation easements, supporting urban
growth boundaries, and maintaining agricultural zoning” (pg 65).
Urban agriculture faces the same problem of economic pressures to
convert the land to development, and similar strategies such as
easements could be effective in the conservation of these urban
open spaces .

o	Policy Suggestion: Penalize and otherwise creating disincentives
for cities converting urban agricultural land into development.
o	Streamline processes and public investments in easements for
urban agricultural land to promote conservation.

Environmental Justice
The scoping plan update also considers Environmental Justice
impacts. For instance, the plan examines how “urban forests can
significantly reduce the disproportionate environmental impacts on
California’s environmental justice communities through increased
green infrastructure investments that reduce GHG emissions,” and
that further social benefits such as “experience, training, and
opportunity for at-risk youth” could also be achieved by partnering
with local groups in implementing urban forestry projects. The same
logic can be applied to policies prioritizing urban agriculture,
which provides many co-benefits to food desert and food insecure
communities, including integral environmental justice goals such as
community empowerment.  

o	Policy suggestion: Invest in environmental justice communities,
including particular attention to supporting community-based urban
agriculture projects. 
o	Incentivize and reward cities that create urban agriculture
initiatives for identifying useable land and passing policy that
assists young and beginning urban farmers. 


2)  Considering urban agriculture policies in the AB32 Scoping Plan
Update would dovetail with other path-breaking California policies
for urban agriculture and environmental justice:

The Urban Agriculture Incentive Zone Act (AB 551) 
AB 551 is a state assembly bill introduced by Assemblymember Phil
Ting (CA-D-19) and signed by Governor Brown in 2013. AB 551 gives
cities and counties the opportunity to pass local ordinances to
create “incentive zones” for urban agriculture. Within these zones,
private landowners who commit their land for urban agriculture for
10 years will be able to sign contracts with the city or county to
give them a lower property tax rate. Urban farmers will have more
rate stability because the land value is assessed only for
agricultural use and does not compete with the land’s value for
residential or commercial use. 

o	Policy Suggestion: The scoping plan should build upon this
important policy, and encourage cities to create these incentive
zones. The scoping plan should also focus on implementing different
policy solutions that not only incentivize this kind of land use,
but which also regulates or creates disincentives for the
conversion of urban agricultural land to development, since this is
a powerful force in cities with limited open space.

The Greenhouse Gas Reduction Fund (SB 535) 
SB 535 is a state senate bill introduced by Senator Kevin De León
and signed by Governor Brown in 2012. SB535 follows up on The
Global Warming Solutions Act of 2006 (AB32) by making provisions
for disbursing funds from the cap and trade program. Under SB535,
CalEPA must identify disadvantaged communities and then the ARB
must follow-up with an investment plan to ensure that at least 25%
of auction revenues are set aside for investments in “projects that
provide benefits to [these disadvantaged] communities,” with at
least 10% in projects “located within” these communities. 

o	The scoping plan update could expand upon this act with further
policy that focuses on high priority needs to ensure that projects
receiving investment achieve both GHG-reductions as well as
significant direct and immediate benefits to these disadvantaged
communities. Benefits such as economic opportunities, social
capital, education, pollution control, and food security, are all
integral aspects of urban agricultural programs that also have GHG
reduction impacts.


3)  Following up on the precedent set by these progressive
policies, the AB32 Scoping Plan Update should prioritize policies
that consider urban agriculture in GHG reduction, such as those
that:

o	Legalize and incentivize urban agriculture 
o	Allow urban agriculture projects to claim credits for moving us
towards our climate goal.
o	Fund and support research into the carbon sequestration and
short-lived climate pollutant remediation effects of urban
agriculture, and methods that enhance these functions.
o	Fund and support place-based public health and city planning
initiatives into the co-benefits of urban agriculture for
transportation, energy use, water use, air quality, nutrition, and
health.
o	Penalize and otherwise creating disincentives for cities
converting urban agricultural land into development.
o	Streamline processes and public investments in easements for
urban agricultural land to promote conservation.
o	Invest in environmental justice communities, including particular
attention to supporting community-based urban agriculture projects.

o	Incentivize and reward cities that create urban agriculture
initiatives for identifying useable land and passing policy that
assists young and beginning urban farmers. 

Overall, considering these progressive policy approaches to urban
agriculture would support the goals in the AB32 Scoping Plan Update
for reductions in GHG and short-lived climate pollutants, and other
public health and city planning co-benefits including land
conservation and environmental justice.

Considering urban agriculture would be a strong addition to the
scoping plan, and would keep California at the helm of this
thriving international movement.





References
  Kulak, M., et al. (2013). "Reducing greenhouse gas emissions with
urban agriculture: a life cycle assessment perspective." Landscape
and urban planning 111: 68-78.
  Zhang, B., et al. (2014). "The cooling effect of urban green
spaces as a contribution to energy-saving and emission-reduction: A
case study in Beijing, China." Building and Environment 76: 37-43.
  MacRae, R., et al. (2013). "The Food System and Climate Change:
An Exploration of Emerging Strategies to Reduce GHG Emissions in
Canada." Agroecology and Sustainable Food Systems 37(8): 933-963.
  Schindler, S. B. (2012). "Of Backyard Chickens and Front Yard
Gardens: The Conflict Between Local Governments and Locavores."
Tul. L. Rev. 87: 231.
  Speak, A., et al. (2012). "Urban particulate pollution reduction
by four species of green roof vegetation in a UK city." Atmospheric
Environment 61: 283-293.
  Public health Brown, K. H. and A. L. Jameton (2000). "Public
health implications of urban agriculture." Journal of public health
policy 21(1): 20-39.
  Rose, N. and K. Larsen (2013) "Economic Benefits of ‘Creative
Food Economies’: Evidence, Case Studies and Actions for Southern
Melbourne." Victorian Eco Inovation Lab. Accessed online 4/12/2014.
<
http://www.ecoinnovationlab.com/wp-content/attachments/Creative-Food-Economies-1-Economic-Benefits-and-Case-Studies.pdf>
  Lovell, S. T. (2010). "Multifunctional urban agriculture for
sustainable land use planning in the United States." Sustainability
2(8): 2499-2522.
  Campbell, M. C. and D. A. Salus (2003). "Community and
conservation land trusts as unlikely partners? The case of Troy
Gardens, Madison, Wisconsin." Land Use Policy 20(2): 169-180.
  McClintock, N. (2008). "From industrial garden to food desert:
Unearthing the root structure of urban agriculture in Oakland,
California."
  Urban Agriculture Incentive Zone Act. AB551 (2013-2014). Accessed
online 04/12/2014.

  California Global Warming Solutions Act of 2006: Greenhouse Gas
Reduction Fund. SB535 (2012). Accessed online 04/12/2014.

  Schindler, S. B. (2012). "Of Backyard Chickens and Front Yard
Gardens: The Conflict Between Local Governments and Locavores."
Tul. L. Rev. 87: 231.

Attachment: www.arb.ca.gov/lists/com-attach/15-drafteaspu14-VyICdl0+VmQFbQRb.docx

Original File Name: Urban Agriculture Comment Scoping Plan Update AB32.docx

Date and Time Comment Was Submitted: 2014-04-28 14:01:12



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