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Comment 53 for 2030 Target Scoping Plan Concept Paper (sp-concept-paper-ws) - 1st Workshop.


First Name: John
Last Name: Amodio
Email Address: jamodio@msn.com
Affiliation: Yosemite-Stanislaus Solutions (YSS)

Subject: Comments on the 2030 Target Scoping Plan Concept Paper
Comment:
On behalf of Yosemite-Stanislaus Solutions, a community based
collaborative of diverse interests in tuolumne County, I am
submitting the following comments.

First, thank you for your continued effort and engagement of us and
other interests.  Our comments are in two sections: 1) Comments on
specific text; 2) General and Overarching Comments.

Comments on specific text
“As shown in Figure 1, in 2014, total GHG emissions decreased by
2.8 million metric tons of CO2 equivalents (MMTCO2e) compared to
2013, representing an overall decrease of 9.4% since peak levels in
2004.” 

We strongly urge that GHG emissions from natural lands be included
in the inventory.  As Lucy Blake, President of the Northern Sierra
Partnership commented at a joint State-federal public forum on
Sierra forest health, the current inventory is both incomplete and
inaccurate by excluding the significant emissions associated with
the increasing trend of megafires throughout California and
particularly the Sierra. Contrast wildfire emissions to High-Speed
Rail. This is essential to enable that AB 32 funds are allocated to
sectors that are most significant in terms of existing and
potential emissions. By any objective measure, GHG funds are now
grossly under invested in restoring forest health and resiliency.

Page 4
We applaud that you recognize “increasing trend in the severity of
wildfires in California due to climate change, and understand how
best to increase carbon sequestration in forests and other identify
targets for natural and working lands, such as through the Forest
Carbon. We must also address the natural lands over time. The Draft
Scoping Plan will build off of ongoing efforts to Plan,1 and
identify policies that directionally set us on the path towards
achieving the vision for the sector even in the face of scientific
and methodological uncertainty. 

A Draft Scoping Plan workshop held on March 23, 2016, focused on
the natural working lands sector.2 As described at the March 2016
workshop, the high-level objectives for the State’s strategy for
natural and working lands include: 
• Manage and restore land to increase carbon storage and minimize
GHG emissions in a sustainable manner so that the carbon bank is
resilient and grows over time. 

Pages 19 - 20
“It is also important to understand the sources of emissions when
considering opportunities for policies and programs to reduce GHGs.
Figure 3 provides the percent contribution to statewide emissions
from the main economic sectors as reflected in the 2014 GHG
Emission Inventory (2016 Edition).11 

Climate change mitigation policies must be considered in the
context of the sector’s contribution to the State’s total GHGs. The
transportation, electricity (in-state and imported), and industrial
sectors are the largest sectors for GHGs in the inventory and
present the largest opportunities for GHG reductions. However, to
ensure decarbonization across the entire economy, policies must be
considered for all sectors.”

We seriously challenge the accuracy of this statement since forest
and the vast amount of GHG emissions caused by wildfire, which are
on steady increasing trend, are not even represented on this chart.
 This omission not only misrepresents current reality, it also will
justify continuing the under-investment in forest health and
resiliency when compared to their importance in achieving AB 32
goals.

Pages 22 - 27
“• Natural and Working Lands – by 2030 
o Each year, 500,000 acres of nonfederal forest lands included in 
restoration plans oriented towards forest health and carbon
storage”

While we applaud the modest increase in the annual goal for forest
health and carbon storage, restricting this goal to non-federal
lands makes no sense and runs contrary to the reality that federal
lands pose the greatest risks to achieving AB 32 goals. While they
may be under federal management, they constitute the majority of
forest land in California, form the headwaters from which 60% of
California’s developed water supply originates, and by any
objective measure represent one of the largest potential sources of
GHG in coming decades.


General Comments 

Accomplishments and progress can be measured in a number of ways. 
We think first and foremost it will be useful to have a way to
track NET changes in both stored carbon (above and below ground) 
and Fire Regime Condition Class (FRCC) across the landscape over
time.  These are the two most important factors in our view.
Forests are dynamic environments and both carbon stored and FRCC
can change from year to year.  So we advocate an accurate way of
doing both on a periodic basis (some kind of statistical sampling
schema). We  also think that it would be helpful to partition the
state into bio geographic regions to accommodate different rates of
change in these conditions that depend on different forest types
and geography.  This all is being done to some degree now,
different organizations doing different parts of this,but could be
improved upon.

Policies that influence the utilization of forest biomass for
energy production have been largely ineffective for a long time;
basically it is too expensive to haul forest biomass to processing
stations.  This dilemma will persist until we innovate a means for
making it economically viable to invest in biomass electricity
generation plants and/or other sources of energy become more
expensive.  We also have to account for full life cycle of energy
inputs and outputs from forest biomass.  This is a complex issue
but it is not viable at the moment and won't be until policies and
innovations evolve.

It will be important to carefully consider the tradeoffs between
emissions from prescribed fire and uncontrolled wildfire. 
Currently air regulations restrict prescribed and managed fire
resulting in larger and more severe wildfires that emit larger
volumes of GHG.  This has to be thought through carefully and
compromises reached to enabled more management of fire.  On the
face of it this can be perceived as being in conflict with public
health, an obvious goal of the overall concept paper.  But careful
thought will reveal that we will be better off enduring some smoke
from managed fires than suppressing all but the very worst fires.

Of course, as said many times, we want to shift forest structure to
less dense and more variable and composition to more fire tolerant
species (more pine and oak, less fir and cedar) in most places in
the Sierra.  Creating a more heterogeneous landscape will lead to a
more disturbance resilient landscape; thus maintaining more carbon
for longer periods of time. More carbon, for longer periods of
time, in more areas results in carbon sequestration increases.
(page 9 of concept paper)

It is essential to support local/regional collaborations as much as
possible.  Reaching agreement on what and how to manage forests is
challenging and only through skilled collaboration will difficult
decision making stick.  The plan should do everything in its power
to enable these efforts to proceed and conclude.

Relying on sound science (page 12 of the concept paper) is wise. 
Keep a standing committee of credible scientists who can guide this
effort.  And support additional research on targeted topics.

We agree with the intergovernmental collaboration (page 13).  This
is the only way we can effectively manage firescapes (large
watersheds/landscapes).  We have to do everything we can to make
these collaborations work.

Beginning on Page 22 of the Concept Paper, all four Concepts
address Natural Working Lands by aiming for 500,000 of non-federal
lands included in reforestation plans annually.  First, why is this
goal the same for all four concepts?  This means that there is not
difference in any concept for the role of forests.  Seems like at
least one should be somehow different.  Second,  again we should
not distinguish between federal and non-federal lands.  Third, we
need to define what we mean by restoration. It must be based on
ecological health.

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Date and Time Comment Was Submitted: 2016-07-08 16:28:52



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