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Dear Ms. Nichols, Mr. Goldstene and members and staff of the
California Air Resources Board,

Our organizations commend the California Air Resources Board
(CARB) for producing the first economy-wide framework in the
United States to address global warming.  This plan is an
important milestone and sets California on the path toward
becoming a model for reducing emissions across all sectors of our
state’s economy.
	
Global warming is one of the most serious threats to wildlife
worldwide. Average temperatures have increased by about 1.5
degrees Fahrenheit (°F) worldwide over the past century. According
to the Intergovernmental Panel on Climate Change, if increases
exceed more than 2.7°F to 4.5°F above current temperatures, 20
percent to 30 percent of all species worldwide are likely to be at
increased risk of extinction.  By 2050, temperatures in California
are projected to increase by 2.4°F to 3.6°F, and by 2100, the
projected increase is 4.1°F to 10.4°F.  Clearly, global warming
will increase the stress on California’s already stressed plant
and animal species.  We need to address this problem
comprehensively and quickly: the health of the natural systems on
which our economy and way of life depend is at serious at risk.  

We are pleased to see in the draft scoping plan (the Plan) that
CARB has responded positively to recommendations made by our
organizations.  The Plan suggests a strong and cost-effective cap
on greenhouse gas (GHG) emissions and a market-based program to
reduce greenhouse gas emissions from major emitting sectors.  We
support these criteria and recommend that in the final Plan, CARB
specifically include forest-based offsets in the market-based
program.  The inclusion of forest-based offsets coupled with a
strong declining cap will foster significant GHG reductions in a
cost-effective, timely and efficient manner from capped sectors. 
It will also secure a role for natural systems, initially through
forests, as effective GHG mitigation tools, a public service
(among many others) that has been historically undervalued.

Furthermore, we appreciate that the Plan acknowledges the need to
provide funding to help human communities and natural systems
adapt to climate change through the collection of GHG revenues and
the establishment of a California Carbon Trust.  We urge that the
final Plan dedicate at least 20% of the available funding to
plans, projects and programs that foster adaptation allowing human
communities and natural systems, wildlife, plants and habitat to
survive the negative impacts of global warming that will increase
stress on these critical natural systems.   

We also support the plan’s recommendation to establish a firm
target for forest carbon statewide.  The draft Plan’s proposed
target of five mmtCO2e is modest and we recommend that ARB
consider increasing this “floor” by re-evaluating input provided
by the forest sector Climate Action Team (CAT) subgroup.  In order
for the state to maintain this level, policies and programs that
address emissions from land conversion must be adopted.  Towards
that goal, we request that the final Plan clearly establish the
use of CEQA as an appropriate tool to mitigate carbon emissions
from forest and wildland (e.g., wetland and grassland) conversion.
In addition to establishing this “no-net-loss” of forest carbon
policy, we urge CARB to adopt a non-binding forest carbon
restoration goal for the state and pledge to work with CARB to
develop the specifics of this goal.  Finally, we urge CARB to move
quickly to establish scientifically derived protocols and processes
to develop reduction and accounting methods for other habitats such
as wetlands and grasslands.

To succeed in reducing emissions and addressing global warming,
the final Plan must provide assurance that the reductions are
real, measurable, and meet the other requirements of AB 32.  Thus,
the final Plan should specify that reductions from the forest
sector be evaluated under the existing, CARB-approved, accounting
methods, standards, and protocols acknowledging that CARB may
adopt refinements to them over time.  

As currently drafted, the role that CARB intends for the Board of
Forestry and Fire Protection to play is vague.  CARB should
clarify that role soon to avoid confusion.  In addition, the final
plan should explicitly reaffirm CARB’s responsibility as the lead
agency for adopting reduction measures and other policies
involving all sectors, including the forest sector, and including
especially, the accounting rules and responsibilities for state
and project level inventories.

The impact of local and regional land use decisions on GHG
emissions is significant.  In this area too, adoption of revised
planning processes and other measures can reduce emissions from
transportation, energy, water use and waste recycling beyond the
values included in the scoping plan.  We urge CARB to adopt an
ambitious and meaningful target for reductions from the landuse
sector 
A robust role for forests and other natural resource based
projects is critical for the success of the Plan and the public’s
acceptance of it.  Recent polling information released by Next Ten
underscored the importance of establishing a comprehensive role for
natural resources in the state’s climate policy.  Conducted last
month, the poll found that
•	79 percent say that global warming is a serious threat to the
economy and quality of life for California's future 
•	88% strongly support protecting forests and natural areas that
naturally remove global warming pollution from the air as part of
the state’s plan
•	81% recognize that protecting existing forest lands was very
important as an additional benefit from addressing global warming.
 
 
In conclusion, we look forward to reviewing the technical
appendices to the draft Plan when they are released and may submit
additional comments at that time.  We commend CARB and its staff
for their hard work in producing the draft AB 32 scoping Plan  We
urge CARB to make firm and binding commitments in the final Plan
to policies that fully capitalize on the capability of forests and
other natural resource-based projects to address climate change
both by avoiding emissions and increasing carbon sequestration.  

Sincerely, 
   	   	 		
Michelle Passero			
The Nature Conservancy
Kim Delfino		
Defenders of Wildlife
Dan Taylor
Audubon California				

Original File Name: Coalition comments on draft AB 32 Scoping Plan 7.18.08.doc

Date and Time Comment Was Submitted: 2008-07-21 16:40:58