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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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