Comment Log Display

NOTE: an illustrated and source-linked version of this comment is
available at
http://biostock.blogspot.com/2008/07/ca-draft-scoping-plan-comment.html
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The ill health of our forests is a statewide catastrophe. We are
witnessing unprecedented wildfires, bug infestation, and decay
that consumes our forests without adequate reforestation efforts.
It is estimated by the California Forest Foundation that we are
losing over 30,000 acres of timberlands (an area the size of San
Francisco) each year to brushlands.

Nationally, six of the seven worst fire seasons on record have
occurred within the last eight years with some fires lasting
months and covering hundreds of thousands of acres. Just four
wildfires that were recently studied were found to emit the GHG
equivalent of adding 7 million cars to our streets for one year. 

The smoke and emissions from wildfires are greenhouse gases that
we can see, smell, and touch as ash and particulate matter is
strewn across the landscape. But this is only the start of the GHG
problem. Decay contributes 3 times as much greenhouse gas as the
fire itself. 

The goal of reducing 5 MMTC02E by 2020 seems woefully inadequate
considering the GHG from the combustion of just one wiidfire (2007
Moonlight Fire in Plumas National Forest) which burned 65,000 acres
has been documented to have generated 4.9 MMT GHG. Unmanaged
treatment would add an additional 15 MMT GHG according to a study
by the California Forest Foundation. If wildfire trends continue
on their current trajectory, we will have to see much greater
reductions to maintain the  forest managed GHG sequestration
defined in the Scoping Plan.

There are forest management practices that can and should be
implemented that would mitigate the greenhouse gas impact of these
fires while reducing the ferocity of future fires. These practices
are not mentioned in the Scoping Plan and I'll list them here:

1 - We need to thin our most vulnerable forests.

Recent reports of a thousand fires in California spotlight the
urgency of the problem - which is neither the lightning that
sparks the fires nor the lack of firefighting resources to fight
the blazes. The real problem is the density of the number of trees
 - estimated to be 4-10 times their historic profile - and
undergrowth on our largely unmanaged forests. 

In 2003, the U.S. Congress passed the 2003 Healthy Forest
Restoration Act (HFRA) allocating $750 million dollars in federal
funds to thin approximately 20 million acres nationally. Thinned
forests contain the spread of wildfires.

Resource allocation to fight forest fires (50% of the current USDA
/ Forest Service budget) and to answer environmentalist challenges
(729 lawsuits between 1989-2003) has resulted in bureaucratic
inertia - so only 77,000 acres have been thinned.

Thinning forests won't necessarily reduce the incidence of fires,
but it would significantly reduce their size and GHG
consequences.

2 - We need to salvage wood from impacted forests.

Reducing the biomass of dead and dying trees would go far to
mitigating the GHG impacts of wildfires since decay contributes
three times the GHG as the original fire itself. Large diameter
wood could be converted into saw logs and building materials that
sequester carbon in energy efficient home construction. Scrap wood
could be used to cleanly generate green electricity and convert
into carbon-neutral biofuels reducing our GHG from fossil fuels.

3 - We need to replant our devastated forests.

From 2001 to 2007, over 143,500 acres of forestland outside
wilderness owned by the federal government has not been replanted
and has been left to turn into brush.

Following the 1992 Cleveland Fire in the Eldorado National Forest,
the U.S. Forest Service replanted some lands, and left some
untouched in an experimental ecoplot. Today, trees stand more than
17 feet tall on replanted lands, but brush dominates the untreated
ecoplot.

Unlike government-owned lands, private forest landowners quickly
remove dead trees and other fuels for additional fires and then
replant. It is a part of their enduring legacy for their children.


CARB needs to incorporate these common sense steps into the
Scoping Plan otherwise the status quo will prevail. CARB needs to
show leadership in fighting bureaucratic inertia caused by public
resistance to necessary change in forest management. These
problems will worsen in the midst of compounding global warming
factors. As the Plan so clearly states "Future climate impacts
will exacerate existing wildfire and pest problems in the Forest
sector."

We can ill afford to lose the carbon sequestering forests of our
state.