Comment Log Display

	Please use PDF as official comment. 	 	 	 		
			 		 


		 	 	 		
	
2030 Scoping Plan Update                                           
                                            12/12/16
California Air Resources Board







	Thank you for the opportunity to comment on the 2030 Scoping Plan
Update for the California Global Warming Solutions Act of 2006 (AB
32) and for presenting on this process in Orleans, which we
understand is one of the first meetings on this issue north of
Sacramento.  We hope that the state continues to reach out to
coastal communities in Northern California, as they are already
suffering from the serious impacts of climate change and drought
through lack of water supply, and food, and the loss of fishing
industry jobs. 


The Pacific Coast Federation of Fishermen’s Association (PCFFA) is
the largest organization of commercial fishing men and women on the
West Coast. For 40 years, PCFFA has led the industry in assuring
the rights of individual fishermen and fighting for the long-term
survival of commercial fishing as a productive livelihood and way
of life. The Institute for Fisheries Resources (IFR) is dedicated
to the protection and restoration of fish resources and the human
economies that depend on them. By establishing alliances among
fishing men and women, government agencies, and concerned citizens,
IFR unites resource stakeholders, protects fish populations, and
restores aquatic habitats. A critical component of both
organizations’ missions is robust protections for surface water
quality that supports salmon and the protection of California’s
ocean fisheries and fishing jobs.


PCFFA and IFR appreciate the opportunity to engage on the Scoping
Plan Update, and are specifically concerned about the following
issues with regard to climate change resiliency: water management
and savings; economic impacts from climate change; cold water
supply for salmon; short lived pollutants such as methane; ocean
warming and acidification; dam management; agricultural pollution;
toxic algae in water supplies; fossil fuel development; water
rights; and mitigations that deal with the current impacts of
climate change. 


The California  industry is already suffering from the impacts of
climate change. Fisheries and fishery-dependent California coastal
communities are suffering through back-to- back-to- back resource
crises, with a poor salmon season in 2015, loss of half of the crab
season, and another poor salmon season in 2016. California’s
Chinook salmon resource has been on a downward abundance trend
since at least the year 2000, with rapid acceleration of that trend
in the last few years. While much of this decline can be attributed
to the state’s historic drought, whose persistence and severity may
have been influenced by climate change, more specifically, the
California Central Valley Chinook abundance decline is due to drops
in river productivity, which in turn has been directly caused or
exacerbated by the politicization and over-allocation of finite
water resources coupled with increasing water  pollution, both
factors which are likely to be exacerbated by climate change. 


In 2014-15, commercial crab vessels landed 17 million pounds of
Dungeness crab in California, worth nearly $60 million. Dungeness
crab is now the main driver of the state’s fishing economy. In
2015-16, this important fishery was shut down for over half of the
season because of a biotoxin in crabs that is related to warm ocean
temperatures, which are likely to have been strongly driven by
climate change. Fishing communities already suffering from the
impact of drought will have a hard time surviving if both salmon
and crab are in rotating crises. 


Given these scenarios, and the increasing likelihood that similar
and more severe versions of the same could result from changing
climate conditions, PCFFA and IFR urge the Board to add fisheries
as a “key sector” in the scoping plan, and to address the
socioeconomic impacts to seafood harvesters and the ecological
impacts to fishery and habitat resources in the scoping plan.
Fisheries are a critical “canary in the coalmine” for climate
change, existing at the confluence of water and habitat resources,
food security policy, and coastal community resiliency.
Specifically, our organizations ask that the Board analyze the
impacts of climate change on:


Changing ocean temperatures on existing and future fishery
viability and productivity, including discussion of
temperature-driven species migration changes and the need to manage
new or different fisheries;
Increasing demand for an increasingly limited water supply on the
future availability and productivity of anadromous fishery aquatic
habitat resources, with specific discussion of prospective changes
to the cold water supply for fisheries, changes necessary to dam
management, and the need for statewide water conservation;
Ocean acidification vis-a-vis both mariculture operations and
wild-catch fisheries;
The need for sea-level rise mitigation measures for
fishery-dependent coastal communities, including infrastructure
such as harbors, hoists and fuel docks, and economic or physical
displacement;
The need for land and water right retirement of heavily polluting
agricultural lands which do not have reliable water supplies or
soils that can continue to support farming without public
subsidization.


Despite the economic impacts to this industry and coastal
communities, fisheries impacts are rarely included in economic
analyses done by the state of California, nor are mitigation
measures employed in EIRs created by California to protect the
fisheries and clean water on which we depend. We ask that our
issues be addressed in this process and that it be clarified that
some of the economic impacts to other industries from this process
can be offset by the benefits of restored fisheries and the
restoration of fishery-dependent communities. California’s fishing
industry provides a significant economic benefit to the state and
has survived without the subsidies and pollution impacts that
characterize the agriculture industry. It is important as we look
forward that we promote sustainable food systems and phase out
unsustainable farms and farming practices. 


We applaud many of the state’s efforts to fight climate change. We
welcome the fact that this process looks beyond CO2 and includes
short-term environmental pollutants such as methane. We also
support the fact that this effort addresses water supply issues and
includes polluters such as the agriculture industry, timberland
holders, frackers, and reservoirs which have been not been held
accountable for their actions until this point. 


We are concerned that a presenter at the Orleans scoping meeting
expressed the belief that we cannot impact the agricultural
industry with this plan. The assumption that agriculture is
“untouchable” is not only false, but deeply insulting to rural
communities that are suffering from the lack of fish due to
excessive river water diversions which all too often go to arid and
unproductive lands. California's agricultural industry uses an
estimated 80% of the state’s developed water supply and is also
heavily subsidized. It also pollutes our limited supply of clean
water and air, and then sends many of their crops to countries like
China, thus causing much more pollution, in addition to exporting
what could be many American jobs. Not only is the reduction of
agricultural lands and wasteful water use key to securing clean
water supplies within the state, it would greatly help reduce and
mitigate the impacts of climate change, and these lands could be
used for solar and wind generation in the same way that other
retired lands in the Western San Joaquin Valley have been.


Along with protections to fisheries and our water supply we request
that this plan address divestiture from fossil fuel production and
transportation in California to protect air and water resources.
The fracking boom in California has not only released a huge amount
of methane gas into the atmosphere, but has also in many places
polluted the state’s groundwater, surface water and oceans. Natural
gas is mostly methane (CH4), a super-potent greenhouse gas, which
traps 86 times as much heat as CO2 over a 20-year period. Fracking
is not only polluting our air and water but it also is a huge water
waster, and fracking near communities has caused huge environmental
disasters in places such as Porter Ranch in Southern California,
where over 100,000 tons of methane was released into the
environment, and situations where whole aquifers were rendered
unusable through illegal fracking waste injection. 


Over 70 million gallons of water was used in California in 2014 for
fracking, which was the worst year of the drought, and over 9
million gallons of fracking wastewater is dumped into California’s
oceans every year. Various proposed LNG pipelines also threaten our
water supply and fisheries. California’s recent fracking
controversies and disasters have undone years of effort to protect
our water and climate. We see no place for expanded oil
exploration, development and transport in a state that is
committing to fighting climate change. 


PCFFA and IFR suggest that that National, State and private forests
within the California be managed to not only offset global climate
change but also to protect our dwindling water supplies from
sedimentation and pesticide run-off. The Air Resources Board should
work with Regional Water Boards to create Waste Discharge
Requirements that protect older carbon sequestering forests and
riparian areas. Permits issued by these agencies should require
regular review to ensure that they continue to serve the purposes
of water and air quality protections in light of complications from
climate change on ambient conditions. 


We reiterate the need to work with the Water Rights Diversion of
the State Water Resources Control Board to prioritize public trust
responsibilities such as water for mitigation to protect instream
flows and to protect water quality and drinking water. We encourage
your agency to work with Regional Water Boards to protect water
quality, and to work with the the U.S. Bureau of Reclamation, the
Federal Energy Regulatory Commission and the State Water Resources
Control Board to manage dams in a way that pollutes less and
provides benefits to rivers and anadromous fish.


We also support air quality permits that allow for prescribed
burning to protect forests from out of control stand-replacing
fire. Using controlled fire selectively to better protect water
supplies in the long run, and avoid more heavily impacting major
fires is often a sound air and water quality protection strategy. 




Thank you for the opportunity to comment, 
Regina Chichizola
Pacific Coast Federation of Fishermen’s Association and Institute
for Fisheries Resources.