Comment Log Display

COMMENTS ON AB 32 PROPOSED SCOPING PLAN,
SUBMITTED BY SIERRA CLUB CALIFORNIA, November 19, 2008


15. Sustainable Forests (p. 27)

•	The forest sector can play an important role in sequestering
carbon from the atmosphere, but the targets outlined in the scoping
plan continue to be quite weak.  We encourage ARB to revisit the
targets as data improves, and re-evaluate whether a more aggressive
target is appropriate.
•	While there will inevitably be a role for the California
Department of Forestry, the Board of Forestry, and the Resources
Agency in developing regulations and conservation strategies for
the forest sector, it is imperative that the ARB retain a clear
leadership role in evaluation of the standards, the certainty of
potential emission reductions, and the consistency of the inventory
and accounting.  
•	Any perceived reduction in potential wildfire-related emissions
attributed to fuels reduction activities should be considered
highly speculative and should not be used to reach the 5MMTCO2E
target.  While fuels reduction actions in certain locations, such
as near homes and communities, may be a public safety priority, it
is not at all clear that there is a net savings of carbon emissions
associated with these activities.  
To the extent that there is an increased focus on using forest
biomass to generate electricity, it is important that biomass
utilization not lead to adverse forest management practices.  It
makes sense to utilize the material created from community
protection efforts, or incidental to an otherwise lawful harvest,
but we should not allow biomass production to impact important
habitat areas, including riparian areas, late seral forests, or
other sensitive habitats.