FEMA projects in the East Bay deny carbon loss

Hummingbird in eucalyptus flower.  Courtesy Melanie Hoffman
Hummingbird in eucalyptus flower. Courtesy Melanie Hofmann

Our readers know that one of many reasons why we object to the destruction of healthy trees is that they are sequestering and storing carbon which is released as carbon dioxide into the atmosphere when the trees are killed and as wood decays.  Carbon dioxide is the predominant greenhouse gas that is causing climate change.  We believe that addressing climate change should be considered our highest environmental priority.

Although we like native plants and would like to conserve them, they will not survive in their historical ranges in a changing climate.  Therefore, native plant advocates should join us in making climate change a higher priority than destroying our existing landscape in places where native plants may no longer be adapted if that destruction contributes to climate change.

Federal and State policies and laws have been adopted to address climate change and the main point of an environmental impact study is to assure the public that the project complies with all laws.  Therefore, the Draft Environmental Impact Study (DEIS) for the FEMA projects in the East Bay that will destroy tens of thousands of healthy trees stands on its proverbial head trying to deny that carbon loss resulting from these projects will not violate these laws.  These projects are described in detail HERE.

The point of this article is to inform the public of some of the flaws in the DEIS with respect to its analysis of carbon loss resulting from these projects.  (This will not be a complete list of omissions and errors in the DEIS regarding carbon loss.  A complete list would be too technical and lengthy.)

Only 15% of carbon storage in the existing forest has been quantified by the DEIS

The DEIS quantifies only two sources of carbon dioxide emissions resulting from this project:  the fossil fuels used by motorized equipment during the project and the trunks of the trees greater than 5” in diameter that will be destroyed.  Calculating loss of stored carbon based solely on the trunks of the trees that will be destroyed excludes the following sources of stored carbon in the forest:  the understory, the forest floor layer (e.g., duff and litter), the bark, roots, and branches of the trees, and the soil.  RA Birdsey of the US Forest Service reports (1) that only 15% of total carbon stored in forest ecosystems in the United States is contained in the trunk:

Allocation of carbon in forest ecosystems and trees

                              US Forests, 1992






Bole (trunk)


Other wood above ground






Forest floor





Although the soil will remain when the trees are destroyed, there is scientific evidence that there will be some loss of soil carbon as a result of this project“…a major forest disturbance, such as a clearcut harvest, can increase coarse litter and oxidation of soil organic matter.  The balance of these two processes can result in a net loss of 20% of the initial carbon over a 10-15 year period following harvest.” (1)  The destruction of all non-natives trees on 400 acres of UC Berkeley and the City of Oakland properties and 90% of the trees on 1,600 acres of East Bay Regional Park District, surely qualifies as a “major forest disturbance” which will result in loss of carbon stored in the soil of the forest.

The DEIS pretends there is no carbon loss from prescribed burns

East Bay Regional Park District plans to chip the trees that are destroyed and distribute them on 20% of the project areas to a depth of 4-6 inches.  They plan to burn the wood that cannot be distributed on the ground without exceeding these limits.  This excess wood will be burned in piles.  In addition to pile burns, EBRPD also plans to conduct broadcast burns for the purpose of destroying non-native vegetation and vegetation debris considered potential fuel for a fire.

The DEIS does not quantify the carbon that will be released by these burns, citing an EPA policy of 1996:  “It should be noted that the emission of CO₂ from burning has not been calculated since the removal of the vegetation would allow new vegetation to grow, eventually consuming at least a portion [of] the CO₂ released during burning, as noted in EPA emission factor guidance (EPA 1996)”

This EPA policy regarding CO₂ emissions from prescribed burns has been revised to include carbon emissions from prescribed burns.   In response to climate change, the EPA established an “Emission Inventory Improvement Program” (EIIP) in 1997.  Since then, the EIIP has continuously expanded and improved the National Emissions Inventory (NEI).  The NEI for 2008 is available on the EPA website.  It includes reporting of CO₂ emissions resulting from prescribed burns.  Data for each type of emission is available on the internet.  It can be sorted by state.  The 2008 NEI reports that the State of California emitted 2,156,547 tons of carbon dioxide from prescribed burns in 2008.

Obviously, the DEIS is mistaken in its outdated claim that the EPA excludes emissions from prescribed burns from calculations of greenhouse gas emissions.  Furthermore, whether or not the carbon released by prescribed burns must technically be reported, that carbon is, in fact, released to the atmosphere.  Such a legalistic quibble ignores the fact that carbon released by prescribed burns has the same harmful environmental consequences as any other carbon release.   

Loss of the ability of the existing forest to sequester carbon in the future is not quantified

In addition to the grossly underestimated loss of carbon stored in the existing forest ecosystem, the DEIS does not quantify the loss of the ability of the existing forest to sequester carbon in the future.  The DEIS acknowledges that the post-treatment landscape will be less capable of sequestering carbon than the existing landscape:

“The proposed and connected actions would also be self-mitigating to some degree in the absence of a wildfire, because native vegetation would partially replace the non-native vegetation removed. However, the planned growth of oak and bay woodlands and successional grassland containing shrub islands would not sequester as much carbon as the larger eucalyptus and pines and the denser coastal scrub that would be removed.”  (DEIS 5.6-11)

The DEIS cannot claim that legal thresholds for carbon loss are not violated without quantifying this decrease in the ability to sequester carbon.

Blue gums live in Australia from 200 to 500 years. (2)  They live toward the longer end of the range in milder climates such as the San Francisco Bay Area.   Most Blue Gum eucalypts were planted in the East Bay between 1886 and 1913, according to David Nowak of the US Forest Service. (3)  Therefore, they are not more than 130 years old.  They can be expected to continue to sequester carbon for at least 100 years and perhaps 300 years.

The native trees that the proposed projects claim will occupy the ground now occupied by non-native trees are significantly smaller than the existing trees.  Since carbon sequestration and storage are proportionate to biomass, the native trees will not compensate for the loss of the ability of the existing forest to sequester carbon.  The DEIS reports in Table 4.7-1 that the oak-bay woodland in the project areas is storing only 8.97 metric tons of CO2 per acre, compared to 325.91 metric tons per acre in the eucalyptus forest and 184.61 metric tons per acre in the Monterey pines.

Furthermore, the predominant native tree is being killed by Sudden Oak Death (SOD) at an epidemic rate, so its future is both unlikely and unknown.  SOD exists in the project areas, which is reported HERE.

Misinterpreting or misrepresenting science

The DEIS sets up a straw man to support its claim that the FEMA projects will not increase carbon dioxide emissions by offering a false choice between theoretical carbon loss from a wildfire vs. carbon loss from destruction of the non-native forest.  This false choice violates both federal and state law regulating environmental impact studies because the measure of environmental impact as defined by those laws require that the study compare the existing, baseline condition to the potential impact resulting from the proposed project.  In other words, the existing condition is the forest that exists now, not a theoretical forest that has been destroyed by fire.

Adding insult to injury, the DEIS tries to prove its theoretical straw man by misinterpreting or misrepresenting scientific studies:

“Studies indicate that if a wildfire occurs, the proposed type of vegetation management sequesters more carbon in the long term than leaving the sites untreated. Two wildfire modeling studies indicated that thinning would reduce damage caused by wildfires, allowing faster regrowth after a fire (Hurteau and North 2010; Wiedinmyer and Hurteau 2010). The Wiedinmyer and Hurteau (2010) study included the use of prescribed burning as a treatment method.” (DEIS 5.6-11)

In fact, these studies don’t say what the DEIS claims they say:

In “Prescribed fire as a means of reducing forest carbon emissions in the Western United States,” (4) the authors compare carbon loss from prescribed burns with carbon loss from wildfires in the same locations and reach the conclusion that prescribed burns result in less carbon loss than wildfires without prescribed burns.  However, the prescribed burns they are considering were restricted to the understory and did not include any trees:  “The fraction of fuel consumed in prescribed fires was applied only to the surface fuel fraction (including herbaceous, fine, and coarse fuels of the total fuel loading model…); no live or standing dead trees are assumed to burn in prescribed fires.”  Therefore, this study is not applicable to the proposed project which intends to burn the remains of hundreds of thousands living trees which will obviously release far more carbon into the atmosphere than the prescribed burns in this study as well as reduce carbon sequestration into the foreseeable future.

In “Carbon recovery rates following different wildfire risk mitigation treatments,” (5) the authors compare several different methods of fuel reduction with respect to how long it takes for the forest to recoup the carbon loss from those methods.  It finds that the forest is unable to recoup the loss of carbon when the destruction of the overstory canopy is the method used because of the large amount of carbon stored in large trees:  “Overstory tree thinning treatments resulted in a large carbon deficit and removed many of the largest trees that accumulate the most carbon annually, thereby increasing carbon stock recovery time.”  In fact, this is precisely the method that will be used by the proposed project.  Therefore, this study makes the point that this project will permanently reduce the ability to sequester carbon by destroying large trees that will not be replaced.  In other words, this study contradicts rather than supports the assumptions of the DEIS regarding carbon storage.

In “High-severity wildfire effects on carbon stocks and emissions in fuels treated and untreated forests,” (6) the authors compare carbon loss from wildfires in a thinned forest (both loss from treatment and loss from subsequent wildfires) with carbon loss from wildfires in the same locations without thinning.  They conclude that such thinning results in more total carbon loss than wildfires without such thinning in the short run.  However, because more trees remain after wildfire in a treated forest, the ability of the forest to sequester carbon in the long term can recoup much of the loss of the treatment.  The forests they are considering have average densities of 1536 stems per hectare and thinning is limited to stems of less than 18 inches in diameter.  This study is therefore not relevant to the proposed project because the forests in the proposed project are significantly less dense and are being completely destroyed by UCB and Oakland and more drastically thinned by EBRPD compared to the study.  In other words, a much greater percentage of total carbon storage will be lost by the proposed projects in the short run because a higher percentage of total trees will be destroyed, including all large trees which store more carbon than smaller trees.  In addition much more capability to sequester carbon will be lost in the long run because few trees will remain.

All of these studies have in common that they have measured all sources of carbon in the forest:  carbon in the soil and roots, in the branches and leaves, in the understory, in the duff and leaf litter.  In contrast, the DEIS quantifies only the amount of carbon stored in the trunks of the trees.  All other sources of carbon are ignored.

It’s time to send your public comment on these projects

Remember that public comments are due by June 17, 2013.  You may submit written comments in several ways:

  1. Via the project website: http://ebheis.cdmims.com
  2. By email: EBH-EIS-FEMA-RIX@fema.dhs.gov
  3. By mail: P.O. Box 72379, Oakland, CA 94612-8579
  4. By fax: 510-627-7147

These public lands belong to you and the money that will be used to implement these projects is your tax dollars.  So, please tell the people who work for you what you think of these projects.


(1)     “Carbon Changes in US Forests,” RA Birdsey and LS Heath, US Forest Service Gen. Tech. Report RM-GTR-271, 1995

(2)     Eucalypt ecology: Individuals to ecosystems, by Jann Elizabeth Williams, John Woinarski ,Cambridge University Press, 1997

(3)     David Nowak, “Historical vegetation change in Oakland and its implications for urban forest management,” Journal of Arboriculture, 19(5), September 1993,

(4)     Christine Wiedinmyer and Matthew Hurteau, “Prescribed fire as a means of reducing forest carbon emissions in the Western United States,” Environmental Science Technology, 2010, 44, 1926-1932

(5)     Matthew Hurteau and Malcolm North, “Carbon recovery rates following different wildfire risk mitigation treatments,” Forest Ecology and Management, 260 (2010) 930-937

(6)     Malcolm North and Matthew Hurteau, “High-severity wildfire effects on carbon stocks and emissions in fuels treated and untreated forest,” Forest Ecology and Management, 261 (2011) 1115-1120

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