November 9, 2021
Amanda Hansen
Deputy Secretary for Climate Change
1416 9th Street
Sacramento, CA 95814
RE: Natural and Working Lands Climate Smart Strategy Draft Report
Dear Deputy Secretary Hansen:
We appreciate the hard work that the California Natural Resources Agency (CNRA) staff and sister agencies have provided in an effort to design a pathway that conserves at least 30 percent of California’s land and coastal waters by 2030 as specified in E.O. N-82-20. We are writing to provide our initial reactions and recommendations to the Natural and Working Lands Climate Smart Strategy Draft Report (NWLCSS report), as it relates to lands and waters in the Inland Desert region. Our signatories represent community members and non-profits working throughout the region on issues of conservation, access, and equity specific to our region.
This letter identifies parts of the report which we support as well as areas that are cause for concern -- especially as it pertains to desert biodiversity and carbon sequestration modeling in the Inland Desert. We trust that the CNRA and relevant agencies will reverse their outlook on the importance of desert carbon sequestration and correct the inconsistencies in the draft NWLCSS report. Anything less would jeopardize our community health and undermine the state’s 30 by 30 effort.
Key Issues
The NWLCSS draft report is a good start towards creating a state pathway towards 30 by 30 -- however, there remain gaping holes in the current report that jeopardizes the integrity of the state’s 30 by 30 process. Our supporting documentation for these claims are mostly included in our appendix. The majority of our letter includes reactions and recommendations to specific points in the NWLCSS report.
We would be remiss if we did not highlight our appreciation and support for the leadership the state is showing in support for diversity and equity issues as well as working with indigenous communities throughout this process. We urge the state to fund 30 by 30 work with frontline communities, people of color, and indigenous peoples as one of its top priorities for achieving a 30x30 pathway.
Concern #1: Currently, desert carbon sequestration expertise informing this report and process is lacking. Until this changes, the state is in no position to craft policy that may disrupt and harm a landscape that may be key in the fight against our climate crisis.
Desert expertise informing this report and process is lacking. The state should ensure they have adequate staff trained to read and understand the science behind desert carbon sequestration before they craft policy that jeopardizes one of the major natural solutions to the climate crisis. If the state believes it does have appropriate staff, we respectfully ask to review their credentials as experts in desert carbon sequestration. Along these lines, the state should immediately secure desert carbon sequestration expert advisors/consultants who can demonstrate decades of scientific experience in desert carbon sequestration and have generated peer-reviewed publications on this topic; their views and recommendations should be included in current and future analysis. Furthermore, their curriculum vitae should be made public in order to provide scientific source transparency.
Concern #2: In the NWLCSS report, the state has miscategorized the desert region including the use of incorrect images, maps, and descriptions. We urge the state to create a ninth and separate category for the desert.
The state should reconsider its current definition of the deserts under the "sparsely vegetated" category which is currently lumped with coastal beaches, bare rock, and snow -- and move it into its own "deserts" category. Desert vegetation above-ground is spaced according to the availability of water. However, below-ground, desert plants such as creosote are connected under-ground in a network of roots and fungal partners that create a large biomass, surpassing that of their canopy above-ground. The desert ecosystem is not homogeneous, but instead is a mix of varied topographic and geologic features, habitats, microhabitats, and climatic variations depending on elevation and location. As varied as it may be, it should not be classified with elements that have little to no overlap in determining the process for sequestering carbon. Presumably, the state will use these categories to create management prescriptions -- if this is the case, the prescriptions will not work for the region, since desert elements function differently than the rest of the other elements (coastal beaches, snow, etc.) in the “sparsely vegetated” category.
In this current NWLCSS report draft, the state is ignoring 15% of desert land as defined by the California Desert Conservation Area map. This map, as well as Bureau of Land Management (BLM) designations, show the California desert occupying a much larger area, to the tune of 25% of the entire state -- not the 10% claimed in this report. Ignoring this important fact puts other state and federal agencies at odds with each other and may generate faulty scientific models and outcomes.
Furthermore, according to the NWLCSS draft report, the majority (61.2%) of the desert is composed of shrublands and chaparral -- placing the desert under shrublands and chaparral seems more reasonable than combining it with coastal beaches, snow, etc. However, doing so still undervalues the important and unique below-ground carbon sequestration taking place in the desert. We strongly urge the state to create a ninth category for the California desert.
Concern #3: The state should reconsider its dismissive stance on the benefits of inorganic carbon as a contributor to the state's total carbon sequestration pool.
It is our understanding that CNRA is using suggestions from sister agencies to determine the process for quantifying carbon in California. Unfortunately, there is currently no state agency that has been able to understand and model a carbon sequestration process specifically for the desert. Rather, CNRA has required a modeling system made to fit within the Intergovernmental Panel on Climate Change (IPCC) protocol -- however, the IPCC protocol is deficient in desert carbon sequestration studies and modeling systems.
California’s hot deserts contain a large pool of inorganic carbon in the form of calcium carbonate (caliche), derived from biological processes. Because of carbon’s potential to remain sequestered in mineralized form for eons, it is often considered that carbon stored under-ground in caliche does not affect greenhouse gases, so it should not be included in carbon models. Although this mineralized carbon can be stored under-ground for many thousands of years, it can also be released back into the atmosphere if weathered upon exposure when disturbed. Anthropogenic activities can degrade the capacity for carbon sequestration and storage in desert soils by land management practices that allow for vegetation removal and soil disturbance.
Therefore, we urge you and your colleagues to consider Appendix A, a white paper authored by Dr. Michael Allen, Distinguished Professor Emeritus, Department of Microbiology and Plant Pathology University of California, Riverside as a means to properly model carbon sequestration in the California desert; and Appendix B, a science briefing by Defenders of Wildlife scientist, Dr. Lindsay Rosa which affirms that up to 10% of carbon sequestration in California stems from below-ground activity in its deserts.
Concern #4: The California desert landscape is highly vulnerable to destructive anthropogenic effects from which it could take millennia to recover.
The state’s strategy should recognize and address the extraordinary and imminent level of threat to the desert from various angles, and the fact that tourism to its intact public lands is a primary economic driver in less affluent desert counties.
Large-Scale Industrial Solar Development
The NWLCSS report should recognize and address the extraordinary level of threat to the desert from industrialization for large-scale solar. To reach decarbonization goals for 2045, the state’s recent SB 100 Joint Agency Report[1] calls for about 70,000 megawatts of new large-scale solar development, acknowledging this as a land-use problem that would industrialize a half-million acres of land (mostly in the desert) — and potentially more land if the Joint Report’s proposal for 28,000 megawatts of behind-the-meter (ie, rooftop) solar is not achieved.
Yet recently California Public Utilities Commission (CPUC) reduced its valuation of distributed energy resources by half,[2] because it narrowly defined costs. Now the CPUC is actively considering increasing fees and reducing payments for behind-the-meter solar adopters.[3] No accounting has been made for other societal costs of large scale solar such as land use, transmission costs and losses, health costs of perpetuating fossil fuel generation in underserved communities, etc. As responsible state agencies, CPUC and California Energy Commission (CEC) need to be active partners in 30 by 30, and account for it in their proceedings.
Scientists estimate that the removal of desert vegetation and disturbance of the top-soil requires about 30 years before the pre-existing plant community will begin to grow back; however, it may require 3,000 years before the disturbed area will return to the function it had prior to disturbance.[4]
Climate Crisis Threats
Between 1950 and 2020, over 1 million acres of California desert burned due to wildfire and this situation is only projected to increase due to climate change.
Concern #5: Biodiversity is not properly categorized or valued and as a result, strategies are missing or improperly included.
Overall the report lacks an emphasis on biodiversity, which has been elsewhere recognized as one of three key goals: climate resilience, equity, and biodiversity. The desert in particular is improperly characterized through its worth being placed only on endemic species, which are not the only species of importance in the desert. Further, endemic species as a group have no greater or lesser role in carbon sequestration or water cycling than more broadly distributed species.
The suggestion of cultural or prescribed burning in sparsely vegetated areas -- deserts in particular -- is inappropriate and should be removed.
Conclusion
In addition to our concerns shown above, find in Appendix C, our reactions to specific content throughout Sections 1-5 of the NWLCSS report. You can also find our response to your Section 6 Opportunities to Scale Action matrix of suggestions in Appendix D.
It is our hope to be supportive in your herculean efforts to create a pathway to 30 by 30. We are confident that once you consider desert sequestration experts in your reporting, the state will be on a stronger foundation to achieve a successful outcome for all. We appreciate your review of our material and welcome further conversations with you and your colleagues at CNRA and your sister agencies. The health of our planet and our communities deserve to have our desert correctly understood. We thank you in advance for your consideration and all the work that this type of endeavor requires.
Respectfully,
Signatories:
Andrea Williams, Director of Biodiversity Initiatives
California Native Plant Society
Brandon Dawson, Director
Sierra Club California
Frazier Haney, Executive Director
The Wildlands Conservancy
Jora Fogg, Policy Director
Friends of the Inyo
Robin Kobaly, Executive Director
The SummerTree Institute
[1]https://efiling.energy.ca.gov/EFiling/GetFile.aspx?tn=237167&DocumentContentId=70349
[2]https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M382/K179/382179225.PDF
[3]https://www.latimes.com/business/story/2021-11-02/should-california-make-solar-more-expensive-inside-the-climate-justice-battle
[4] Lovich J.E., Bainbridge D. (1999) Anthropogenic degradation of the Southern California desert ecosystem and prospects for natural recovery and restoration. Environmental Management 1999, Oct. 24 (3): 309-326.