Comment Log Display

Dear Board Members Loveridge and Riordan,

Thank you very much for our discussion today.  As promised, here
is some proposed language that embodies what we discussed, and that
PFT would like to see added to the Scoping Plan, either in its
text, or in the Resolution for Adoption.

1.  Cross Sectoral Accounting:  in the Adopting Resolution, we
suggest adding “ The Board directs the staff to ensure that
transparent, cross–sectoral accounting systems be developed such
that stocks and flows of carbon can be tracked readily within and
across sectors, as, for example, from forests to landfills to
methane emissions”

2.  Accounting for Adaptive Management:  in the adopting
resolution we suggest adding:  “ The Board directs staff to ensure
that accounting across all sectors provides data sufficient to
identify significant changes in carbon stocks and flows at the
source of such change, in order to allow for adaptive management to
ensure the achievement of AB 32 target goals.”

3.  Synergy of Mitigation and Adaptation: we suggest adding in the
text of the forest sector “Actions undertaken undertaken pursuant
to AB 32 for purposes of mitigation in the Forest Sector are
inherently linked to those appropriate for adaptation to support
resilient, robust natural forest ecosystems that are more capable
of adapting to  climate change, especially with regard to watershed
and habitat functions.   Therefore, ARB will consult with key state
entities responsible for the health and functioning of watersheds
and habitat for California's plants, fish and wildlife to ensure 
actions pursuant to AB 32 are also beneficial for adaptation.” 

4.  Woody biomass combustion:  We note that the addenda have
changed the definition of woody biomass combustion from
anthropogenic to biogenic. ARB should classify woody biomass
combustion as an anthropogenic emission. The combustion of biomass
vastly speeds up the release of carbon from waste-wood and from
slash after harvest.   Because there is insufficient waste and
slash material available to meet biomass demands, this will result
in increased harvest to fulfill that demand, overall emissions from
biomass combustion will increase, as will forest –based emissions
resultant from increased harvest disturbance.  Unless harvest
rotations or intervals are held steady, there will be insufficient 
times to re-absorb those emissions in the forest.  This is likely
to result in net increased emissions overall.