Comment Log Display

Re: Draft Scoping Plan Preliminary Recommendation on Sustainable
Forests
Submitted online at
http://www.arb.ca.gov/cc/scopingplan/spcomment.htm

Dramatic reduction in CO2 emissions and additional carbon
sequestration are urgently needed.  The California legislature and
the Governor have boldly stepped forward and we understand that all
businesses, governmental agencies and citizens must make sacrifices
and changes in order to address this world-wide crisis. All
industry sectors will undoubtedly lobby against change and promote
their own “science” view.  In the end CARB must ensure that good
unbiased science is used and that no one industry sector is
allowed to escape “transparency.”  If one sector gets away without
reducing emissions then another sector will have to take up the
slack. CARB must continue to hold high standards and be vigilant
and ensure that any delegation of work on AB 32 issues to agencies
or Boards is not biased by political or industry pressure. 

The current forest sector scoping document is a first step but it
needs to be significantly strengthened to embrace the bold
challenge of AB 32. As currently written it requires little over
the status quo for the forest industry. Forests are critical to
climate change and forests can either be managed in a way that
emits more CO2 than they sequester for decades.  The issue of CO2
emissions from forest and forest soils disturbance is one that is
not adequately addressed.
 
--Clearcutting practices produce more CO2 and immediately
eliminate more carbon sequestration than other logging methods for
a variety of reasons that are clearly documented. Companies like
Collins Pines and The Mendocino Redwood Company have embraced
sustainable harvest methods that reduce CO2 emissions and
sequester more carbon in the short term and long term.  This
approach needs to be addressed and alternative timber harvest
methods that produce less CO2 than clearcutting need to be rquired
by Cal Fire Resources.
--Climate change conditions such as higher temperature and less
rainfall will severely stress forests.  Scientific analyses and
reviews show that  forestry practices that build diverse
unevenaged will increase the chances for healthy forests and
wildlife habitat.  Plantation forests are more susceptible to
climate change impacts and should not be replacing biodiverse
properly thinned and maintained forests.
--In one Sierra Nevada County nearly ½ of the entire forest is
privately owned by a company that is converting that forest area
to tree plantations following clearcutting type timber harvest. As
climate change worsens the impact of that plantation conversion is
likely to be disastrous.
--Timber harvest methods need to be those methods  that do not
degrade watersheds or snowmelt runoff rates for California’s
critical water supplies. Clearcutting is has the most negative
impacts on water.
--CAL FIRE Resources and Board of Forestry need to ensure that all
science views on climate change related forestry issues are
proactively brought forward and  fully evaluated – not just those
that support industry views. All calculations and assumptions used
in climate change and forestry work need to be readily available
for peer and public review. This transparency needs to be
strengthened in the foresty arena.

Thank you for the opportunity to comment.