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Dear CARB,
Thank you for this opportunity to comment on the CARB 2022 Scoping
Plan. I  have a specific comment on the scope of the analysis in
Appendix I ("Natural and Working Lands Technical Support
Document"). This document examines the potential effects of
different forest management strategies on forest carbon stocks and
GHG emissions. Although the document considers several scenarios
for "improved" forest management, none of these scenarios reflect
the full suite of management approaches that could be undertaken to
improve forest health while also enhancing carbon sequestration
capacity. As noted by LaLonde (2018), the goals of wildfire risk
reduction and forest carbon storage are not necessarily at odds -
they interviewed numerous experts who "commented about the high
likelihood of making these goals complementary through fuel
reduction treatments that create more stable forest structures,
lessen fire risk, and increase sequestration in live carbon pools"

I would therefore like to recommend that CARB consider a forest
management scenario aimed at maximizing forest health and carbon
storage potential while minimizing wildfire risk. This would entail
several components:

(1)	Significant reductions in clear-cutting - a maladaptive
practice which destroys forests and increases wildfire risk in the
medium-to-long term. (Note that none of the scenarios envisioned in
CARB's scoping plan entail any major reduction in clear-cutting.)

(2)	Reductions in commercial harvesting or stipulations ensuring
that harvesting will be conducted in a manner that does not destroy
forests or increase wildfire risk. (All of the scenarios currently
evaluated in the plan entail significant increases in commercial
timber harvests; there are no provisions to ensure that these
harvests actually promote the goals of forest health and wildfire
risk reduction.)

(3)	Banning the removal of old growth trees, and prioritizing
efforts to promote the growth of larger trees (to help reinstate
old growth forests).

In addition, CARB should consider whether reforestation efforts
could help meet the state's climate goals. It may be that
reforestation is not feasible in light of climate change (with
drier and hotter conditions) but CARB should at least explain why
it did not consider reforestation as a approach for enhancing
carbon stocks.

Thank you very much.

Best,

Jessica Wentz  


Citation: Seth J Lalonde et al., Forest Management in the Sierra
Nevada Provides Limited Carbon Storage Potential: An Exert
Elicitation, ECOSPHERE (2018).

Original File Name:

Date and Time Comment Was Submitted: 2022-10-19 12:20:51