Comment Log Display

am attempting to attach letter in Word format. seems problematic
technically. will send by surface mail.

               
	
September 12, 2008

Mary Nichols, Chair
California Air Resources Board
1100 I Street
Sacramento, CA  95814

Re:  Principles for Climate Change Adaptation Funding for Fish and
Wildlife and Their Habitats in the AB 32 Final Scoping Plan
Dear Mary:
Climate change poses an unprecedented threat to the future
sustainability of human communities, fish and wildlife habitat,
and the natural communities we depend upon for our food, our
drinking water, recreational opportunities such as fishing,
hunting, boating and hiking, the strength of our local economies,
and our quality of life.
California’s natural and human communities are already
experiencing impacts from climate change.  For example, recent
research shows that climate change is threatening the survival of
the Bay Checkerspot butterfly, the Desert bighorn sheep,
California’s iconic Joshua tree, the Pika, and many more species. 
Other research shows that we are already experiencing an increase
in temperature and changes in the cycle of water.  Scientists
doing work in California predict that these and other impacts will
increase in scale, scope, and magnitude.  However, neither State
nor Federal agencies have the resources they need to respond to
the massive new threat of global warming.  With major paradigm
shifts in how our Federal and State agencies will need to manage
land and water resources, additional funding to address the new
threats on natural resources will be vital.  Consistent with our
earlier input, we are recommending that 20% of the revenue from an
auction of allowances in the AB 32 cap and trade program be
directed to helping natural resources adapt to climate change.
While the state works to minimize impacts by maximizing reduction
of emissions of greenhouse gases, California must simultaneously
design, fund, and implement a comprehensive adaptation program to
ensure that people, plants, animals, and fish survive the
unavoidable impacts of climate change and that the natural
character of California that we pass on to future generations
bears some resemblance to that we have enjoyed..

In the context of responding to climate change, the goal of
adaptation is to reduce the risk of adverse environmental outcomes
through activities that increase the resilience of ecological
systems to climate change. Here, resilience refers to the amount
of change or disturbance that a system can absorb without
undergoing a fundamental shift to a different set of processes and
structures.  Fortunately, using forests and other natural resources
to mitigate climate change by reducing or avoiding emissions and/or
increasing sequestration, also produces companion benefits for
climate change adaptation.
Following are a set of design strategies based on scientific
principles for a natural resource climate change adaptation
program for California connected to AB 32 implementation:
1.	Dedicated Annual Funding Based on an Auction System.   The
cap-and-trade component of AB 32 implementation, and the companion
WCI cap-and-trade should include an auction system for the
distribution of emissions allowances, moving as quickly as
possible to 100% of allowances auctioned.  Proceeds from this
auction system should be devoted to appropriate public interest
purposes, including actions to address the harmful impacts of
climate change on public health, infrastructure, community
well-being, and the natural environment.

2.	Auction Proceeds for Resilience-based Ecosystem Management and
Protection.  At least twenty percent (20%) of the proceeds from
the cap-and-trade auction system should be dedicated to the
resiliency of all ecosystems types, the ecological processes that
support them, the associated habitats, and plants and fish and
wildlife that are threatened by climate change.  The program scope
should include the full spectrum of ecosystems and habitats,
including terrestrial, freshwater aquatic, estuarine, coastal, and
marine. Development of adaptation strategies must include the
promotion and protection of ecosystem services, supporting the
critical role that these systems play in abating risk and
enhancing resilience and protection of human and natural systems.

3.	Broad Authority for Resilience-based Ecosystem Management and
Protection Auction proceeds in the Final Scoping Plan should
ensure dedicated funding for these purposes to help state, tribal
and local resource agencies and their partners enhance the
resilience of ecosystems at the system, habitat and species level,
in the face of an altered and rapidly changing climate. Eligible
activities should include land acquisition for habitat migration
corridors and for buffer zones to protect lands, rivers, streams
and estuaries; the protection of large intact landscapes; and
restoration, planning, research, monitoring, education and
land-owner assistance activities that are carried out pursuant to
a comprehensive resiliency-based state adaptation strategy

4.	Eligible Agencies.  Agencies eligible for auction proceeds
under the Final Scoping Plan are those state, tribal and local
agencies and non-governmental organizations with authority and
responsibility for maintaining the ecological health of protected
lands, waters, plants, and fish and wildlife and their associated
major habitats (forest, freshwater and coastal).   

5.	Inter Agency Coordinated State Strategy.  To maximize
effectiveness and efficiency, state, tribal and local resource
agencies should collaborate and coordinate their actions through a
comprehensive state adaptation strategy and incorporate climate
change adaptation considerations into existing planning processes
and continuing programs to the fullest extent possible.

6.	Federal Coordination.  The activities of California’s state,
tribal and local resource agencies should be coordinated with
priorities and programs developed by federal resource agencies
pursuant to any national climate change adaption strategy that is
developed.   By adopting a state adaptation strategy consistent
with any federal guidelines, California will be well-positioned to
capture funding that may pass through federal fish and wildlife
agencies for state adaptation work.

7.	Cost-Share Requirements.  In order to ensure full and effective
utilization of funds dedicated to fish and wildlife conservation
under this program, states and other non-federal entities
receiving auction proceeds for conservation actions should, where
feasible, provide a relatively small cost-share payment toward
those projects.  This cost-share requirement should supersede any
cost-share requirement in the program through which the adaptation
strategy is delivered.

8.	State Climate Change Ecosystem Assessment Research.  The
scientific capacity of the state resource agencies to evaluate and
address the impacts of climate change on ecosystems and plants,
fish and wildlife should be enhanced and coordinated.  Capacity
should be developed and enhanced through existing agency centers
and resources such as the California Resources Agency and Cal EPA,
and their various departments and divisions including the
California Energy Commission and its Public Information Energy
Research Program.  Research, data and resources should be made
publicly available for use by the academic, nonprofit, tribal and
local communities to carry out additional research. 

We appreciate your leadership on this matter and look forward to
working with CARB on the implementation of AB 32.

Sincerely, 

 	         		

Louis Blumberg			Kim Delfino			Dan Taylor
The Nature Conservancy		Defenders of Wildlife		Audubon California


cc:	Lynn Terry
Edie Chang
	Kevin Kennedy
	Robert Duvall