CA Draft Scoping Plan comment: Sustainable Forests

This is one of a series of comments submitted to the California Air Resources Board for their draft version of the California Climate Change Draft Scoping Plan. Other BIOenergy BlogRing comments are linked here:
• Challenge the Status Quo
• Recycling and Waste
• Sustainable Forests
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The ill health of our forests is a statewide catastrophe. We are witnessing deforestation by wildfire, 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 with undergrowth - estimated to be 4-10 times their historic profile - 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.

Due to resource allocation to fight forest fires, answer environmentalist challenges (729 lawsuits between 1989-2003), and the resultant bureaucratic inertia only 77,000 acres have been thinned.

Thinning forests won't 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 homes. 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 exacerbate existing wildfire and pest problems in the Forest sector."

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

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