Comment Log Display

Hello,

Thank you for the opportunity to submit comments on this process as
it develops. We applaud CA and ARB for leading the world in this
area, including potentially expanding the program to provide
incentives towards sustainable forest management and reducing
deforestation in tropical forests around the world.

Comment 1) Firstly, we would like to direct you to tow programs
that USFS participates in, in collaboration with other federal
agencies: 1) Silvacarbon and 2) SWAMP, focused on 1) enhancing
capacity worldwide for monitoring and managing forest and
terrestrial carbon and 2)to generate knowledge that is relevant to
policymakers and practitioners regarding the sustainable management
of tropical wetlands and wetland carbon.

http://egsc.usgs.gov/silvacarbon/sites/default/files/SilvaCarbon_Fact_Sheet_September2015_0.pdf


http://www.cifor.org/swamp/

Both these initiatives represent cross USG agency collaborations
that have developed many tools, research, and methodologies that
California might want to consider as they move forward.
Furthermore, SilvaCarbon and SWAMP might already be partnering with
jurisdictional authorities in areas that California is looking at.

Comment 2) Where to the freely associated islands fit into the ARB
process. Territories, if I understand correctly could be
incorporated under the domestic program, but freely associated
states? USFS Region 5 supports forestry programs through both our
domestic and international programs in Palau, Marshalls, and
Micronesia for example.

Comment 3) Leakage is a serious issue in tropical forest countries,
that cannot necessarily be tracked in a compartmentalized way as it
is in CA. China for instance imports raw materials and exports
products around the world. Thus even robust jurisdictional
integrity might have little affect on carbon at a global market
where vertical integration is not contained in that same
jurisdiction. Testing the globalization of the CA market is a
worthwhile endeavor, but might not actually have the intended GHG
reduction result desired in the near term.

Comment 4) Many researchers are working with LiDAR in tropical
forests including Dr Greg Asner and Dr Sassan Saatchi.
Additionally, there is not consensus that wall to wall LiDAR is the
"best" or most cost effective tool to use for remote monitoring of
forests. Other combinations of remote sensing technologies and
tools such as those developed by Dr Matt Hansen and WRI also have
value in different ways. Of course there is Japan, France, and the
EU as well. All with different methodologies, tools, and data.
UNREDD vs FCPF. Thinking in the long term, developing countries
often do not have the capacity to manage or analyze competing
programs and tools. So setting specific technologies might
significantly restrict which jurisdictions Ca is able to engage
with.

Comment 5) Trying to align any guidelines and parameters as much as
possible with those coming out of Warsaw and Paris would be very
practical.

USFS looks forward to continuing to be involved with ARB as this
process develops and is always available to provide support where
appropriate.