Comment Log Display

To: California Air Resources Board
Re: 2030 Target Scoping Plan Update Concept Paper
Date: July 1, 2016

Save the Redwoods League applauds the California Air Resources
Board for integrating the forestry sector and natural environment
into the goals for achieving GHG reduction targets by 2030. The
forests of California are a critical carbon storage asset and
iconic symbol of California’s heritage, yet without public
investment in their further protection and restoration, forest
condition and their associated ecosystem services will decline over
time. By increasing the State’s commitment to forest health, not
only will our natural landscapes sequester and store more carbon,
but Californians will benefit from increased water quality and
yield, enhanced habitat for endangered species, and access to
spectacular recreational resources.

All four of the concepts identified in the concept paper includes
goals for natural and working lands that, if achieved, will
significantly improve the conditions of California’s forests while
contributing to the State’s 2030 GHG reduction targets. We strongly
encourage the Scoping Plan to prioritize natural landscape
investments with a science-based framework to protect and restore
ecosystems with the highest likelihood of carbon capture and
storage:

•	Each year, 500,000 acres of nonfederal forest lands included in
restoration plans oriented towards forest health and carbon storage
– We recommend investing in restoration implementation, not simply
restoration plans. Restoration forestry has high potential to
significantly accelerate carbon sequestration in young and degraded
forests. Research clearly shows that larger trees sequester carbon
faster than younger trees (Sillett et al. 2010), so stimulating the
growth of small trees now will produce higher carbon stocks faster
and help the State achieve its GHG reduction goals sooner. There is
urgency to increasing the pace of forest growth for carbon storage
and for the numerous other benefits associated with forest
restoration including expanding habitat for endangered species and
improving water quality.  We recommend that the Scoping Plan
include policies to encourage restoration on private land and
financing mechanisms to pay for restoration on the state’s public
lands. Within the land owned by the state and thus within direct
state control, there is a critical need and opportunity to restore
the coast redwood forest and increase carbon storage capacity.
California State Parks owns more than 100,000 hectares of the coast
redwood ecosystem and more than 70% of this forestland was once
harvested and is in need of restoration. 

•	Ambitious land preservation policies – We recommend prioritizing
the protection of forests to prevent conversion and loss of
associated ecosystem carbon storage. There is urgency to protect
the forests with the highest carbon sequestration potential because
more than 70% of the coast redwood ecosystem is privately owned and
conversion threats from development, vineyards, and marijuana
agriculture are increasing. 

•	Increase habitat acreage protected or restored – We recommend
setting not only high goals for acreage of habitat to protect and
restore, but prioritizing acres with the highest potential to store
carbon for the long term. A growing body of scientific evidence
shows that the coast redwood forest ecosystem continues to
sequester carbon rapidly even as climate changes (Sillett et al.
2015), stores more carbon aboveground than any other forest on
Earth (Van Pelt et al. 2016), and can store significantly more
carbon if restored (Madej et al. 2013). 

The concept paper points out that the “Scoping Plan will require us
to consider what policies are needed for the mid-term and
long-term, knowing that some policies for the long-term must begin
implementation now.”  It also acknowledges that “the approach we
take must balance risk, reward, longevity and timing.”  In that
context, it asks the question: For the forest sector, are we
comfortable with policies that may result in some near-term carbon
loss, but ultimately support more resilient and healthier forests
in the longer timeframe?  The near-term risk of carbon loss through
ecological forest management to improve forest conditions is scaled
to the treatment applied (Madej et al. 2013; van Mantgem et al.
2013), but studies show that biomass loss can be quickly
ameliorated by the resulting enhanced forest growth (van Mantgem
and Das 2014). For example, in the iconic and treasured coast
redwood and giant sequoia forests, there are phenomenal carbon
storage opportunities that can only be realized through improved
forest management techniques that by necessity lower carbon stocks
temporarily:

•	Giant sequoia groves in the Sierra Nevada boast remarkable
aboveground carbon stocks of more than 1,500 metric tons in live
trees per hectare (Robert Van Pelt, Redwoods and Climate Change
Initiative). More than 80% of this carbon resides in giant sequoia
wood and bark alone. Yet, decades of fire exclusion threaten the
regeneration of giant sequoia and growth of the largest trees on
Earth. In the absence of fire, dense of stands of other conifers
(primarily white fir) thicken beneath the canopy of ancient giant
sequoia, increasing risk of crown fires and reducing giant sequoia
access to water and nutrients through belowground competition.
Mechanical thinning of sub-canopy trees or prescribed burning
removes some forest carbon temporarily, but stimulates giant
sequoia growth and seedling establishment which results in more
vigorous and resilient forest stands (York et al. 2010; York et al.
2011).

•	Old-growth coast redwood forests in Northern California contain
more than 2,000 metric tons of carbon per hectare which is more
than twice the carbon stocks found in other forests world-wide (Van
Pelt et al. 2016). Individual large coast redwood trees can contain
more than 200 metric tons of carbon per tree and sequester carbon
faster than smaller trees (Sillett et al. 2015), but unfortunately
more than 95% of the coast redwood range (600,000 hectares) has
been cut at least once and most of the large redwoods are gone.
Today young, dense stands of harvested coast redwood forest face
impediments to recovery (e.g. stagnated growth from competition)
that limit their ability to realize their carbon storage potential.
Restoration forestry reduces tree competition and accelerates stand
growth (Lindquist 2004; O’Hara et al. 2010; Oliver et al. 1994),
setting carbon-limited young forests on a trajectory to more
quickly sequester carbon and enhance habitat quality for numerous
species. The ecological gains from such restoration forestry
significantly outweighs the temporary carbon losses associated with
its implementation.

We greatly appreciate the opportunity to provide comments on the
concept paper and support robust policies and funding for forest
protection and restoration as a critical strategy for reaching the
state’s ambitious 2030 GHG reduction goals.

Sincerely,
Emily Burns, PhD
Director of Science and Education

Literature Cited

Lindquist, J. L. 2004. Growth & yield report for Whiskey Springs
redwood commercial thinning study: a twenty-nine year status report
(1970-1999). California Department of Forestry & Fire Protection,
California Forestry Report No. 3.

Madej, M. A., J. Seney, and P. van Mantgem. 2013. Effects of road
decommissioning on carbon stocks, losses, and emissions in North
Coastal California. Restoration Ecology, 21, 439-446.

O’Hara, K. L., J. C. B. Nesmith, L. Leonard, and D. J. Porter.
2010. Restoration of old forest features in coast redwood forests
using early-stage variable-density thinning. Restoration Ecology,
18, 125-135.

Oliver, W. W., J. L. Lindquist, and R. O. Strothmann. 1994.
Young-growth redwood stands respond well to various thinning
intensities. Western Journal of Applied Forestry, 94, 106-102.

Sillett, S. C., R. Van Pelt, A. L. Carroll, R. D. Kramer, A. R.
Ambrose, and D. Trask. 2015. How do tree structure and old age
affect growth potential of California redwoods? Ecological
Monographs, 85: 181-212.

Sillett, S. C., R. Van Pelt, G. W. Koch, A. R. Ambrose, A. L.
Carroll, M. E. Antoine, and B. M Mifsud. Increasing wood production
through old age in tall trees. Forest Ecology and Management, 259,
976-994.

van Mantgem, P. and A. Das. An individual-based growth and
competition model for coastal redwood forest restoration. Can. J.
For. Res., 44, 1051-1057.

van Mantgem, P., M. A. Madej, J. Seney, and J. Deshais. Estimating
ecosystem carbon stocks at Redwood National and State Parks. Park
Science, 30, 20-36.

Van Pelt, R., S. C. Sillett, W. A. Kruse, J. A. Freund, and R. D.
Kramer. 2016. Emergent crowns and light-use complementarity lead to
global maximum biomass and leaf area in Sequoia sempervirens
forests. Forest Ecology and Management, 375, 279-308.

York, R. A., D. Fuchs, J. J. Battles, and S. L. Stephens. 2010.
Radial growth responses to gap creation in large, old
Sequoiadendron giganteum. Applied Vegetation Science, 13, 498-509.

York, R. A., J. J. Battles, A. K. Eschtruth, and F. G. Schurr.
2011. Giant sequoia (Sequoiadendron giganteum) regeneration in
experimental canopy gaps. Restoration Ecology, 19, 14-23.