Comments on California Forest Carbon Plan

  • Mar 17, 2017
  • Comment Letters

Agency: California Natural Resources Agency

Subject: California Forest Carbon Plan: Managing our Forest Landscapes in a Changing Climate, Public Review Draft, January 20, 2017

Letter excerpt:

Many of the forest restoration and management issues and described in the Forest Carbon Plan are also identified in ACWA’s policy document entitled Improving the Resiliency of California’s Headwaters – A Framework (February 2015) (Headwaters Framework). Implementation of the Forest Carbon Plan will address a number of elements identified in ACWA’s Headwaters Framework, including recommendations to:

  • Establish headwaters monitoring programs that help quantify GHG benefits and other performance metrics of proactive headwaters management;
  • Provide carbon credits for investments in lands management programs and biomass energy projects that balance or create gains in carbon sequestration benefits and air quality concerns;
  • Promote biomass management, an important component of forestry management, as a potential source of revenue for headwaters protection while ensuring other renewable energy sources remain economically viable; and
  • Facilitate innovative research that can develop new markets for forest products and create financial support for restoration activities.

Suggested Addition to “Regulatory Opportunities” section of the Forest Carbon Plan

The ACWA Headwaters Framework proposes the following recommendation, which we believe could also strengthen the Forest Carbon Plan:

  • Review regulatory obstacles to carrying out activities to GHG emissions and maintain or enhance carbon storage associated with forests and headwaters lands.

Specifically, ACWA recommends that the Forest Carbon Plan be amended to include under the “Regulatory Opportunities” header in section 4.2.1 “Flexible Elements of Major Regulatory Laws” (p. 40) a discussion of air quality attainment standards that are enforced by the California Air Resources Board, Air Pollution Control Districts, and Air Quality Management Districts, and the need to evaluate and remove possible barriers to implementing actions in the Forest Carbon Plan.

Download ACWA’s comment letter

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