California has made a $15 Billion budget commitment to address climate change and protect biodiversity. The California Natural Resources Agency (CNRA) held a series of workshops to explain the initiative and give the public an opportunity to provide feedback to CNRA. Sixteen hundred Californians participated in those workshops, including me.
California Natural Resources Agency recently published a draft of the first installment of implementation plans: “Natural and Working Lands Climate Smart Strategy.” The public is invited to comment on this draft. The deadline for comment is November 9, 2021. There are three ways you can send your comments and feedback: Email: CaliforniaNature@Resources.ca.gov; Letter via postal mail: California Natural Resources Agency, 715 P Street, 20th Floor, Sacramento, CA 95814; Voice message: 1 (800) 417-0668.
Update: The deadline for public comment has been extended to Wednesday, November 24, 2021.
Below is the comment that I submitted today. I focused my attention on the portions of the draft that are relevant to my urban home, such as developed land and urban forests. My comment may not be relevant to your concerns, so I encourage you to write a comment of our own. If you find issues in the draft that I haven’t mentioned please post a comment here to alert other readers.
TO: California Natural Resources Agency
RE: Public Comment on “Natural and Working Lands Climate Smart Strategy”
Thank you for this opportunity to comment on the draft of California’s Climate Smart Land Stretegy.
I find much to like in the draft of California’s Climate Smart Land Strategy. In particular:
- The draft makes a commitment to reduce pesticide use on public lands, for example:
Priority nature-based solutions for developed lands:
“low-chemical management of parks and open spaces in and around cities to beneft underserved communities who are often the most negatively affected by health impacts related to air pollution and extreme heat caused by urban heat islands.”
“Prioritize protection of public safety by ecologically treating vegetation near roads and energy infrastructure.”
“Utilize safer, more sustainable pest management tools and practices to combat invasive species and accelerate the transition away from harmful pesticides.”
- The draft makes a commitment to expanding, maintaining and preserving urban forests:
Priority nature-based solutions for developed lands:
“Increase development and maintenance of both urban tree canopy and green spaces to moderate urban heat islands, decrease energy use, and contribute to carbon sequestration.”
“Maintain urban trees to provide vital ecosystem services for as long as feasible”
- The State of California defines the urban forest broadly and the draft acknowledges its importance in climate smart land management:
“California Public Resources Code defines urban forests as “those native or introduced trees and related vegetation in the urban and near‐urban areas, including, but not limited to, urban watersheds, soils and related habitats, street trees, park trees, residential trees, natural riparian habitats, and trees on other private and public properties.” Urban forests are our opportunity to apply climate smart land management in the places most Californians call home. The character of urban forests is diverse, which heavily influences the localized selection of management options and outcomes related to both carbon storage and co-benefits.”
- The draft acknowledges that suitability to a specific location and climate are the appropriate criteria for planting in the urban forest. Because native ranges are changing in response to changes in the climate, whether or not a tree is native to a specific location is no longer a suitable criterion.
“Utilize place-based tree and plant selection and intensity, to ensure the species selection process considers climate, water, and locally-specific circumstances.”
- The draft acknowledges the importance of forests to maintain carbon sinks to reduce greenhouse gas emissions that cause climate change. The urgent need to address climate change must trump nativists’ desire to replicate treeless historical landscapes.
“Healthy forests can serve as reliable carbon sinks, both because they are able to store significant amounts of carbon and because they are at a lower risk of carbon loss due to climate impacts such as wildfire and drought. After large, high-severity fires, some of California’s forests may convert to shrublands and grasslands59 that are not capable of supporting the same level of carbon storage as forests.”
“…shrublands and chaparral store substantially less carbon, and the dynamics of their growth and disturbance are less well known. Evidence indicates that shrublands in California are burning more frequently than they would have historically, leading to degraded conditions, possible conversion to grasslands, and reduced carbon storage in above ground biomass.”
Making these commitments operational implies that the State must also make these commitments:
- The State of California should not fund projects that destroy healthy trees for the sole purpose of replicating treeless historical landscapes, especially on developed lands.
- The State of California should not fund projects that destroy functional landscapes and healthy trees, particularly by using herbicides.
Suggested improvements in the draft
These commitments in the draft should be revised:
“Implement healthy soils practices, including through native plant landscaping and mulch and compost application.”
The word “native” should be deleted because the nativity of a plant is irrelevant to soil health. Introduced plants do not damage soil, but using herbicides to kill them does damage the soil by killing beneficial microbes and mycorrhizae.
“Increase drought-tolerant yards and landscaping through, for example, native plant species replacements and lawn removal and by adopting, implementing and enforcing the State’s Model Water Efficient Landscaping Ordinance.”
The word “native” should be replaced by “drought-tolerant,” which would include many native species, but not all. Redwoods are an example of a native tree that is definitely not drought-tolerant. Many species of drought-tolerant plants have been introduced to California from other Mediterranean climates that are well adapted to our climate and the anticipated climate in the future.
“Where appropriate and applicable, Departments should rely on the Class 33 categorical exemption for small habitat restoration projects in the CEQA Guidelines”
Such exemptions should not be granted to projects that will use pesticides because they will damage the environment, including the soil, and the wildlife that lives there. Such a specific limitation is consistent with commitments in the draft to reduce pesticide use in parks and open spaces around cities because those are the places where such small projects (5 acres or less) are likely to be proposed. Such a limitation on the use of this exemption to CEQA requirements should be added to the final draft because it does not explicitly exist in the code.
The importance of setting priorities
The strength of the draft is its emphasis on addressing the sources of climate change. All projects funded by this initiative must be consistent with that over-riding mission because climate change is the primary threat to all ecosystems. Reducing the sources of greenhouse gases causing climate change is a prerequisite for protecting biodiversity.
I appreciate the mention of opportunities to remediate brownfields, but I believe a broader commitment to addressing sources of pollution is needed:
“Ensure brownfield revitalization supports community efforts to become more resilient to climate change impacts by incorporating adaptation and mitigation strategies throughout the cleanup and redevelopment process. These efforts also increase equity, as many climate vulnerable communities live close to brownfields and other blighted properties.”
Julie Bargmann was recently awarded the Oberlander Prize in Landscape Architecture for her ground-breaking work to bring blighted land back to useful life in the heart of post-industrial cities. Her work is unique because it transforms abandoned industrial land into beautiful public space while honoring and preserving its history. She brings new meaning to the word “restoration.” She does not begin by destroying functional landscapes. She provides a model for a new approach that is particularly important to underserved inner-city communities. I live in Oakland, where I see many such opportunities to restore public land to useful life without the scorched-earth strategies commonly used by ecological “restorations.”
When ecological restorations are funded without addressing sources of pollution, valuable resources are often wasted. The recent oil leak from an oil platform off the coast of Southern California is a case in point. Millions of dollars were spent restoring a wetland that was doused with oil for the second time. Yet, some of the oil platforms in California waters are no longer productive, but have not been safely decommissioned. This is putting the conservation cart before the horse.
We are about to make enormous investments in the expansion of wetlands, as we should. At the same time, we should address the sources of pollution that will despoil those wetlands, such as many miles of impaired waters in the watersheds that drain into the wetlands. For example, the draft touts seagrasses as carbon sinks and acknowledges pollution as one of the major threats to seagrass: “The leading causes of seagrass loss are nutrient pollution, poor water clarity, disease, and disturbance.”
At every turn, climate smart solutions should stay focused on the underlying causes of problems in the environment, rather than cosmetic solutions that don’t address those causes. Quibbling about whether or not marsh grass is native or non-native is like arguing about the color of the lifeboat. Let’s focus on whether or not a landscape is functional as a carbon sink.
The draft gives me hope that the State of California can do something useful with our tax dollars to address climate change without damaging the environment further. The draft shows the influence of learned hands with good intentions. Now let’s see specific projects funded that are consistent with the goals defined by the draft. That’s where the rubber meets the road.