Chapter and Page Number (Revised Document)

Comment (Anonymous)

Amended Content (If Applicable)

Amended to reflect the lack of available information on this topic.

"It is unclear what the source of the elevated rates of aluminum is."

On page 85, it states that the industry cluster and labor market analysis suggest that relative to economic value-added, Working Lands and the Blue Economy have the highest output of greenhouse gas emissions among the RRRISE target industry sectors. It is unclear how this conclusion was derived. Forestry is a net emitter in the state due to wildfires, however, this is not a result of production so I’m assuming this was not factored into these estimates.

The report was amended to acknowledge data gaps and the need for a comprehensive regional emissions inventory, while providing context about the main emission sources based on currently available data, addressing the commenter's question about data improvement needs.

“Major gaps exist in data related to the region’s greenhouse gas emission, highlighting the need for the region to conduct a comprehensive emissions inventory. Available data show that residential energy use, followed by transportation, are the two largest anthropogenic emitters of GHGs in the Redwood Region. However, the largest overall source of GHG in the region is likely to be wildfires. Among the target sectors, data from the Industry Cluster and Labor Market Analysis suggest that, relative to economic value added, the Working Lands and Blue Economy industries have the highest output of greenhouse gas emissions among the RRRISE target industry sectors.”

I am also concerned with the table on page 86 outlining emissions by industry, as it is not aligned with current carbon benefit evaluation methodologies, which account for 1. storage of carbon in product; 2. production emissions, and; 3. substitution emissions. To reference only production emissions is misleading and further confounds working together to develop strategies to reduce atmospheric GHG emissions.

For decades California’s commercial and recreational fishing industry has been in decline and along with it California’s fishing based harbors.  California’s commercial fishing fleet is shrinking as ocean based fish stocks diminish along with the profitability of the industry.  The root problem for California’s fishing industry is the damage  done to the Pacific Ocean by pollution and climate change.  Adding to this problem are the impacts of sea level rise from global warming and increase damage to coastal harbor from climate change driven storms. 

Until harbors in the RISE region can be throughly assessed as to their future on-going economic and environmental viability, it makes no sense to invest public money in harbor infrastructure projects that have a high risk of failure due to flooding and damage from sea level rise and climate disasters.

The report was updated to address concerns about harbor infrastructure vulnerability by highlighting regulatory frameworks for coastal planning, noting the critical gap that only 3 of 14 Local Coastal Programs in the North Coast Region currently incorporate sea level rise considerations, underscoring the commenter's point about potential infrastructure risk.

"The Coastal Act, which was adopted by the California Coastal Commission (the Commission) in 1976, requires 61 cities and 15 counties in California to prepare Local Coastal Programs (LCPs) that are meant to govern land development, use, and resources in the coastal zone inland of the mean high tide (California Coastal Commission: Sea Level Rise Policy Guidance, 2024). Recently, a new bill was passed that requires local governments to have updated sea level rise adaptation plans in their LCPs by 2034. The purpose of having sea level rise adaptation plans in LCPs is to promote sustainable economic growth while also taking into account public safety and protecting coastal resources, such as recreation areas or coastal habitats. However, as of this report only three out of fourteen LCPs in the North Coast Region have been updated to discuss sea level rise and climate change. Those LCPs are from the City of Crescent City, the City of Eureka, and the Humboldt Bay Area Plan. Each document provides guidance on sea level rise hazards, based on current climate change analysis, and guidelines for how local infrastructure should consider future sea level rise when building near the coast (City of Eureka Coastal Land Use Plan, 2023; Crescent City Harbor: Coastal Land Use Plan, 2020; Humboldt Bay Area plan, 2022). The other eleven LCPs do not discuss sea level rise or climate change, and this could potentially lead to critical loss of infrastructure and coastal resources."

Chapter and Page Number (Revised Document)

Comment (Anonymous)

Updated Content (If Applicable)

To address the question about forestry emissions methodology, the report was amended to clarify the specific EPA data source used while acknowledging its limitations in accounting for carbon storage and substitution benefits, with supplemental graphs added to present a more balanced view of regional carbon sequestration.

"It should be noted that the IMPLAN data is sourced from the Environmental Protection Agency (EPA) for their USEEIO Version 2.0 model. This model uses the U.S. EPA GHG and Sinks: 1990-2016 data; specifically the Land Use, Land-use Change, and Forestry data. This data does not account for storage of carbon in timber lands, or substitution emissions. The graphs below show more on carbon sequestration and rates in Northern California."