Comment Log Display

 



Re: ForestEthics Comments on Proposed Scoping Plan

ForestEthics appreciates the opportunity to provide comments on
the Proposed Scoping Plan (PSP) for meeting the goals of AB 32.  We
will be limiting our comments to the PSP’s section on forestry. 

We are grateful that the Air Resources Board (ARB) is including a
section on forestry, as this is an often overlooked, but incredible
important component toward meeting our state’s commitment to
solving the climate crisis.  As is acknowledge in the scoping plan,
deforestation accounts for 20% of global greenhouse gas emissions.

We believe the goal of maintaining the current 5 MMTCO2E is
certainly doable and would urge ARB to set an even more robust
target moving forward.  We would also urge the following
recommendations:

1).  Shift the emphasis towards measuring average carbon stocks in
a forest instead of rates of uptake and release.
With limited funds, trying to account for the rate of carbon
uptake or release is not the most judicious use of taxpayer dollars
and is irrelevant.  Rates of uptake and release are of less concern
from a carbon perspective than the average amount of carbon the
forests is storing.  For example, if one cuts an old growth forest
and replaces it with a sapling, there may be faster growth from the
sapling after several years.  However, the forest is still in a
carbon deficit due to the logging of the old growth forest that had
years and years of accumulated carbon.  To emphasize throughout the
PSP the rate at which California’s forests are growing is less
relevant than how much carbon these forests are maintaining on
average.  Until there is accurate accounting of average carbon
stocks, ARB will not be able to tell whether California’s forests
are even meeting the goals of AB 32.  

2).  Reduce the PSP’s emphasis on fire emissions
There is no question that communities should be protected from
wildfires and studies by the Forest Service have shown that logging
within 100 feet of a home to reduce fuel loads from brush and small
trees can protect property. However, from a carbon perspective, the
more important point is that focusing on fires once again puts the
emphasis on rates of carbon release instead of overall carbon
stores for unless the forested area never grows back, the carbon
will be reabsorbed.  Additionally, just because a forest burns,
even a high intensity fire does not translate into immediate and
total carbon losses,   and as the wood decays, rigorous post fire
growth recovers much of the carbon that is lost.   
  
3).  Encourage and create incentives for landowners to produce
multi-aged and diverse forests
Appendix B says, “There are significant opportunities to increase
the carbon storage on managed forest lands over the next few
decades by increasing forest growth through healthy and fully
stocked stands that utilize site potential for growth while
resisting or minimizing emissions from fire, insects and disease.”
(C-169)  There is no guarantee that vigorous tree growth will
result in stands better able to withstand fire, insects and
disease.  In fact, the California Climate Change Center with staff
from Berkeley and Cal EPA said of global warming, “Monodominant
stands are at most risk. Designing diverse forest structures with
multiple species where appropriate alleviates some risk associated
with even-aged, single-species stands. A spatially mixed forests
limits the spread of both pathogens and insects.”  The same study
showed that pine plantations would also face a 31% reduction in
yield due to global warming as compared to 18% for mature forest
stands. 
  The science is also quite clear that certain logging methods
release more carbon than others.  For example, clearcutting
releases more carbon than any other forest disturbance, including
fire.   Yet, the closest forest management prescription the PSP
will make is encouraging “sustainable forestry practices.”  Indeed,
where the PSP says, “Providing incentives to developing countries
to help cut emissions by preserving standing forests, and to
sequester additional carbon through the restoration and
reforestation of degraded lands and forests and improved forest
management practices, will be crucial in bringing those countries
into the global climate protection effort,” could no doubt apply to
our own state as well.  

4).  Shift away from encouraging biomass until proper accounting
is done that ensures it is carbon negative
It may be possible that biomass may help to reduce carbon
emissions, but there must be transparent and rigorous accounting
that considers all elements of the energy production including
transportation, milling, and logging before it is regarded a
worthwhile solution.	

5).  Make sure reforestation and afforestation is scientifically
sound.  
Reforestaton and afforestation are important, but ARB must ensure
credit is only given for genuine carbon reductions.  For example,
the science is far from clear that salvage logging and replanting
post fire is a carbon benefit.  To give credit carte blanche for
such activities will not necessarily result in carbon gains.  
	 
We appreciate the opportunity to comment on this historic piece of
legislation.

Joshua Buswell

Sierra Campaigner, ForestEthics
1 Haight Street
San Francisco, CA 94114
415-863-4563 ext 328