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Thank you for organizing this workshop. It's great to see how CARB
is thinking about updating the protocol based on new science and
data opportunities.

I'm glad there was a lot of discussion of remote sensing data. As
an ecosystem ecologist I'm supportive of these products to be used
in addition to ground-based data. The remote sensing data continue
to improve and can provide more comprehensive views in space and
time, as well as adding transparency and lowering barriers to entry
for small landowners.

In September we published a paper in Global Change Biology
(https://onlinelibrary.wiley.com/doi/full/10.1111/gcb.16380) which
I think has already been on your radar and may have been partly
addressed in the workshop. There are a couple points I would like
to emphasize and clarify regarding the study:

More than a critique of any specific methods embedded in the
current protocol, the study was designed to look for RESULTS from
the ~10 years the compliance program has existed. Of course this is
a limited record and only a small piece of the total 100+ year
lifetime of projects, but we at least have a window now to look
back for some detectable signature of carbon offsets on the
landscape. For example, forest offsets are often discussed as an
important financial incentive for landowners to harvest less than
they otherwise would have. Can we see that reflected in harvest
rates yet?

It should be concerning to CARB staff, policymakers, and the public
that we can not yet detect a harvest reduction in carbon offset
projects compared to pre-project levels or compared to other
similar private forests ("similar" defined 3 different ways in the
study).

CARB seems very defensive of the current baseline system as
reasonable and conservative, with multiple safeguards built in.
However our study should raise a red flag, indicating that tracking
carbon relative to current baselines alone might not be enough to
ensure a net climate benefit. Large timber companies in particular
appear to be meeting baseline requirements without actually doing
anything differently to sequester or protect carbon.

CARB also seems highly confident that there are safeguards against
selection bias of project areas. However, we have concrete examples
particularly in northwestern California and for one large timber
company where project boundaries are intricately drawn and quite
distinct from the rest of the property or regional average in terms
of species composition.

It doesn't make sense for CARB to respond to these observations by
reiterating how the carbon is additional according to the protocol
or by pointing to different safeguards. Our findings are simply
observations of carbon and harvest indicating how projects aren't
behaving differently from non-projects so far.

Our goal here is not criticism for its own sake, but to be
constructive in the context of CARB's willingness to update the
protocol. Our study was a demonstration of how remote sensing
products can be used to look for signatures of forest management
and track carbon across the landscape. At the simplest level, one
idea would be require large landowners not just to maintain carbon
stocks above baseline, but also to show direct evidence of improved
management (e.g., extending harvesting rotation lengths, etc) that
they are pledging in their initial documentation.

Our study also discusses the current limitations and biases of
remote sensing products, while demonstrating that they are still
useful for comparisons over space and time. The data we used for
harvest come from the from the Wang et al., 2022 paper
(https://agupubs.onlinelibrary.wiley.com/doi/full/10.1029/2021AV000654)
for California but could be expanded to the rest of the US.

Please don't hesitate to reach out if you'd like to discuss any of
this or if we can help make our science useful to the State going
forward.

Shane Coffield 

Original File Name:

Date and Time Comment Was Submitted: 2022-12-01 20:44:14