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November 2007
California Oak Report
California Global Warming Solutions Act of 2006
Below is a recent letter sent by California Oak
Foundation (COF) to the California Air Resources Board (CARB) regarding
oak woodlands-climate change under California law. The CARB forest
protocols focus on counting the capture or emission of carbon dioxide
by forest "biomass." In a nutshell, the protocols address carbon
"biological emissions" from the conversion of oak woodlands habitat. In
the opinion of COF, California Environmental Quality Act (CEQA) oak
woodland biological reviews must analyze both wildlife habitat impacts
and carbon emission impacts when determining significant impacts and
proportional mitigation measures.
COF is not alone in its perspective that California’s passage of
Assembly Bill 32 means that climate change is a potential environmental
impact that needs to be addressed in CEQA reviews. California Attorney
General Brown has made it clear to cities and counties that
discretionary approvals must
provide an examination of a project's impact on global warming.
Brown’s recent $10 million CEQA settlement with ConocoPhillips
regarding mitigation offsets for increased refinery greenhouse gas
emissions included $2.8 million for reforestation projects to sequester
carbon. If the California Attorney General is requiring CEQA
reforestation mitigation for smokestack carbon emissions, then
deforestation emissions from the conversion of oak woodlands certainly
merit CEQA analysis and conservation/reforestation mitigation.
The CEQA legal opinions and actions of Attorney General Brown signify
that there is no need to wait until January 1, 2010 for CARB's
prescriptive oak woodlands regulations to be implemented; CEQA projects must analyze long-term climate change impacts due to carbon emissions resulting from significant impacts to oak woodlands - now.
Forest Protocol Key Terms
Biological emissions: For the purposes of
the forest protocol, biological emissions are GHG emissions that are
released directly from forest biomass, both live and dead, including
forest soils.
Biomass: The total mass of living organisms in a given area or volume; recently dead plant material is often included as dead biomass.
Bole: A trunk or main stem of a tree. For
the purposes of the Protocol, any tree bole with a minimum diameter of
three inches should be included in the inventory to estimate carbon
stocks.
Carbon pool: A reservoir that has the
ability to accumulate and store carbon or release carbon. In the case
of forests, a carbon pool is the forest biomass, which can be
subdivided into smaller pools. These pools may include aboveground or
below-ground biomass or roots, litter, soil, bole, branches and leaves,
among others.
California Air Resources Board
October 14, 2007
Dr. Jeanne Panek, Forestry Lead
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812
Re: Forest Protocols
Dear Ms. Panek:
"A day will come it is already a fact in the
European Union when landowners will be paid, as a public good, to
regenerate oaks on their lands. And why aren't there similar types of
payments in the West?" (Paul F. Starrs, Fifth Symposium on
California Oak Woodlands, 2001).
The California Oak Foundation (COF) writes with brief comments
regarding oak woodlands and implementation of the California Air
Resources Board (CARB) forest protocols.
1. In fact and in law it will be much easier for California to
assimilate forestry protocols for oak woodlands than for conifer
timberlands. For example, development of the timberland regulatory
system will be complex and time-consuming. Meanwhile, significant
impacts to oak woodlands are already addressed by California
Environmental Quality Act (CEQA) review. Melding CEQA analysis of oak
woodland carbon emissions and mitigation measures is a simple process.
Moreover, Attorney General Brown has made it clear that CEQA
discretionary approvals must provide: (1) an examination of a project's
impact on climate change and the adoption of all feasible mitigation
measures to reduce such impacts; (2) such analysis can and must be done
today even absent established thresholds of significance or impending
regulations under Assembly Bill 32. Therefore, under CEQA review CARB
can promptly
implement CEQA oak woodland protocols based on existing information
(Winrock International 2004) and proportional
reforestation/conservation mitigation measures.
2. The 2004 California Energy Commission study, Carbon Supply From Changes In Management of Forest, Range, and Agricultural Lands of California (Winrock) made the following hardwood rangeland findings:
"For rangelands, estimates of the potential
carbon benefits were analyzed for one alternative, afforestation
[reforestation]. Historical evidence suggests that in many areas, large
tracts of forest may have once stood where grazing lands now do.
Moreover, a significant proportion of today's oak woodlands and annual
grassland vegetation types on California's rangelands were also once
either dense forests or similar woodlands but with significantly higher
biomass than they currently contain. Presently, in much of the state,
ranching is the primary activity on what remains of these lands that
were once forests or woodlands.
Afforestation of rangelands provides the most carbon at the least cost.
The counties with the least expensive carbon from afforesting
rangelands are also the same counties that potentially can sequester
the most. Restoration of biological diversity and water resources is a
possible additional benefit that could accrue from afforestation of
existing rangelands."
3. Based on the latest University of California
data (2001), COF conservatively estimates that since 1990 California
has converted 325,000 acres of oak woodlands to other land uses. Thus,
in California there are substantially less acres of oak forest to help
reduce state carbon emissions by 2020 to 1990 levels. Furthermore, the
escalating deforestation of California oak woodlands will make it that
much more difficult and expensive to meet the AB 32 requirement to
reduce greenhouse gas emissions to 80 percent below 1990 levels by 2050.
COF urges the California Air Resources Board to swiftly implement air
quality-oak woodlands analysis and mitigation criteria for CEQA review.
Otherwise, unmitigated carbon emissions from development of an
estimated additional 60,000 acres of oak woodlands will occur by
January 1, 2010.
Sincerely,
Janet S. Cobb, President
California Oak Foundation
Merchandise
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habitats and some of the more than 300 species that rely on oaks for
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California Oak Foundation Membership
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Acorn Membership $25.00
Seedling Membership 50.00
Sapling Membership 75.00
Heritage Oak Membership 100.00
Oak Grove Membership 250.00
Oak Woodland Membership 500.00
Quercus Membership 1,000.00
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