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February 28, 2014 Ms. Ann C. Chan Deputy Secretary for Climate Change California Natural Resources Agency 1416 Ninth Street, Suite 1311 Sacramento, CA 95814 Re: Safeguarding California Plan

The Nature Conservancy welcomes the opportunity to provide comments on the Safeguarding California Plan: Reducing Climate Risk (“SCP” or “The Plan”), an update to the 2009 California Climate Adaptation Strategy. The mission of the Nature Conservancy is to conserve the lands and waters on which all life depends, and the Nature Conservancy is working to preserve ecologically important lands for nature and people in California and around the globe. The Safeguarding California Plan is an important addition to the significant body of climate change plans and activities underway to reduce climate-driven risks to the state’s economy, environment, and human well-being. In an effort to provide comprehensive and constructive input to this planning process, the Nature Conservancy is submitting three letters to the Natural Resources Agency. One is a group letter that addresses high-level general themes and provides specific recommendations to improve the cross – sector section of The Plan. A second letter focuses specifically on coastal and ocean resources informed by the Nature Conservancy’s unique experience working with local communities on adapting to coastal climate change. And this, the third letter, provides sector-specific comments in some detail. Collectively, we hope this tri-partite input from the Nature Conservancy will help the Natural Resources Agency produce a final plan that will help California respond to the escalating impacts of a changing climate. We continue to support the Climate Adaptation Strategy (CAS) of 2009 and commend the Natural Resources Agency for clearly reaffirming its commitment to the 2009 Strategy except where recommendations are explicitly addressed in the SCP. However, the approach to “Hazard Avoidance” in the SCP is less directive than in the 2009 CAS so we recommend that the final SCP reaffirm the CAS text and include this language in the cross sector section:

“State agencies should consider project alternatives that avoid significant new development in areas that cannot be adequately protected (planning, permitting,

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SCP Sector Specific Comments, TNC,

development, and building) from flooding, wildfire and erosion due to climate change. The most risk-averse approach for minimizing the adverse effects of sea level rise and storm activities is to carefully consider new development within areas vulnerable to inundation and erosion. State agencies should generally not plan, develop, or build any new significant structure in a place where that structure will require significant protection from sea level rise, storm surges, or coastal erosion during the expected life of the structure.” (CAS, page7)

Our sector-specific comments follow: Agriculture Climate change-driven loss of biodiversity poses a number of risks to California agriculture, including: lack of pollination, loss of soil biodiversity and capacity for nutrient cycling, and loss of natural biological control leading to potential new pest outbreaks. At the same time, the agriculture sector plays an important role in maintaining biodiversity by providing critical habitat and linking migration corridors, which will become more essential as the climate changes. The Agriculture section in the SCP should explicitly acknowledge this important connection. In addition, greater cross-sector collaboration can produce a broader suite of adaptation solutions and result in a more comprehensive climate response strategy for the state than a plan that relies primarily on sector-specific strategies.

General comments:

Protecting Agricultural Land (pg. 26-27) SB375 is another law that could prove beneficial to protecting farmland Urban Footprint and other “sketch” models should be mentioned as additional resources

to help provide information on emission reduction and climate adaptation benefits to protecting farmland and habitat

Additional Actions Needed:

Inventory and monitor the critical habitat provided by California farmland. Develop biodiversity monitoring plans to analyze changes in delivery of ecosystem

services due to climate change in specific farming systems, to inform place-based adaptation strategies.

A robust mitigation policy to mitigate for the loss of farmland.

Other notes:

Department of Fish and Wildlife should be added as an agency on page 33

We also strongly the support the comments submitted by CalCAN and urge their adoption into the Plan. We especially support recommendations to highlight the adaptation benefits of planning and management of farm systems, especially for biologically-diverse, sustainable agriculture, and including conservation easements as an important strategy to protect farm- and rangelands.


Biodiversity and Habitat

General Comments:

We were pleased to see this chapter highlights the need to quantify baseline carbon information associated with natural systems, and to identify and prioritize conservation and restoration opportunities with carbon sequestration benefits as well as a prioritization of nature-based adaptation solutions. As in our general comments, we urge that this prioritization be elevated to a cross-sectoral strategy and that it is applied to all sectors.

The “Action Needed” section should include references to who should do the work and when it should be done. For example, the last bullet on page 53 states a “….comprehensive, statewide climate change vulnerability analysis at the habitat scale is needed…”, but it does not indicate who should do this analysis and in what time frame. For each recommended action, indicate which state agency is best suited to complete or oversee the completion of the given task and provide a schedule for implementation.

The endnotes require consistent formatting and editing. For example, the formatting for endnote #83 includes multiple types of text and is hard to read. In addition and at a minimum, every publication should be cited with the authors and year. A hyperlink is not adequate as the hyperlinks change over time. For example, endnote #87 references the “California Climate Adaptation Strategy” but does not provide details on the year, authors, agencies, number of pages etc. Even citations that reference webpages should use more information than just the URL.

Specific Comments:

Page 39: Incorporate the California specific examples from the top of page 40 (paragraph starting “The August 2013 Indicators…” into the bulleted list of impacts on page 39.

Page 39, 4th bullet: The following sentence needs a citation: “The Intergovernmental Panel on Climate Change (IPCC) estimates that 20-30% of the plant and animal species evaluated so far in climate change studies are at risk of extinction if temperatures reach levels projected to occur by the end of this century.”

Page 41: The following sentence needs a citation: “Providing corridors and maintaining “connectivity” to facilitate the movement of species between suitable areas and to newly suitable areas over time as climate changes (e.g. northward or up in elevation) is the most frequently recommended strategy for conserving species.” We recommend the following citation: Heller, N. E., & Zavaleta, E. S. (2009). Biodiversity management in the face of climate change: A review of 22 years of recommendations. Biological Conservation, 142(1), 14–32. doi:10.1016/j.biocon.2008.10.006

Pages 41-42, Box entitled “Citizen Science – Crowdsourcing Climate Monitoring”: Add a mention of iNaturalist and BioBlitzes as examples of citizen science in California.

Page 42, paragraph starting with “Natural Community Conservation Planning (NCCP)”: We were pleased to see a discussion of NCCPS included in this chapter, but the program lacks adequate funding and staff resources. The Plan should identify this issue and request funding and resources be directed to this initiative. The Nature Conservancy


recently completed a report that found that implementing the reserve network in the HCPs and NCCPs in southwestern California will help species adapt to climate change. Please review this report and include it as an example and citation. The review is available here: http://www.scienceforconservation.org/downloads/SW_CA_Climate_Report

Page 47, paragraph entitled “November 2010 “Bridging the Gap: Downscaling Climate Models to Inform Management Actions” Workshop”: This is in the “Research and Tools” section, but a conference is neither research nor a tool. There have been many climate change related conferences over the past 5 years, so it seems odd to highlight this one. We recommend listing all the conferences in a new section or deleting this reference.

Page 47, Box entitled “Tools to Support Biodiversity Conservation in the Era of Climate Change”: We recommend adding the following tool reference:

o The Nature Conservancy’s “Actions Likely to Increase Plant and Animal Resilience to Climate Change” Tool is an interactive webmap that shows concrete conservation actions land managers can take now to help address the threat of climate change to the terrestrial species of California. The tool can be accessed here: http://scienceforconservation.org/map_gallery/actions_likely_to_increase_plant_and_animal_resilience_to_climate_change

Page 55: Add the following bold text to the sentence: “Priorities for creating, maintaining or restoring conservation areas should include landscape features that will ease the transition to future climatic conditions for species supported by the habitat (e.g., high topographic diversity, rich microclimate diversity, intact riparian corridors, low fragmentation, climatic and elevational gradients, groundwater resources, etc.).” This sentence can be cited with the following paper: Klausmeyer, K. R., Shaw, M. R., MacKenzie, J. B., & Cameron, D. R. (2011). Landscape-scale indicators of biodiversity’s vulnerability to climate change. Ecosphere, 2(8), art88. doi:10.1890/es11-00044.1.

In addition, we note that the making decisions in the context of uncertainty is an important but poorly understood issue in the context of climate change. The impacts of decisions, including those that are deferred are especially important to the resilience of biodiversity but are also applicable to decision making in other sectors. We recommend that the final SCP include the following text under the heading, “Applying and Advancing Best Practices in Decision-making in the Face of Climate Uncertainty”: Managers of protected areas and natural resources are generally well aware of the threat of disruption and extinction posed by climate change. Climate change challenges managers to adapt traditional approaches for setting conservation goals, and the philosophical and policy framework they use to guide management decisions. While many managers likely have general hypotheses about how climate change will impact resources in their charge, and some even may be observing ecological changes consistent with predictions, there are relatively few examples of managers altering their conservation goals and management prescriptions in the face of climate change, and fewer still undertaking actions that may be considered non-traditional, such as assisted colonization. A growing literature discusses methods for structuring management


decisions in the face of climate-related uncertainty and risk. It is often unclear, however, when managers should undertake such explicit decision making processes. California should actively seek to identify circumstances where explicit decision-making processes about adapting management prescriptions in the face of climate change are being or can be undertaken, and encourage those decision-making processes to apply best practices in structured decision making, which includes that they be documented. The purpose of documentation is to develop a portfolio of written case studies of how California managers explicitly address risk and uncertainty in decisions to act or not act. That portfolio will be a helpful resource for other managers navigating similar issues, and can help develop greater in-state expertise in what is sure to be a required proficiency of managers in the near future. Selected References Bierbaum, R., J. B. Smith, A. Lee, M. Blair, L. Carter, F. S. Chapin III, P. Fleming, S. Ruffo, M.

Stults, S. McNeeley, E. Wasley, and L. Verduzco. 2013. A comprehensive review of climate adaptation in the United States: more than before, but less than needed. Mitigation and Adaptation Strategies for Global Change 18: 361–406.

Cole, D.N., and L. Yung, editors. 2010. Beyond Naturalness: Rethinking Park and Wilderness Stewardship in an Era of Rapid Change. Island Press.

Lunt, I. D., M. Byrne, J. J. Hellmann, N. J. Mitchell, S. T. Garnett, M. W. Hayward, T. G. Martin, E. McDonald-Maddden, S. E. Williams, and K. K. Zander. 2013. Using assisted colonisation to conserve biodiversity and restore ecosystem function under climate change. Biological Conservation 157: 172–177.

McDonald-Madden, E., M.C. Runge, H.P. Possingham, and T.G. Martin. 2011. Optimal timing for managed relocation of species faced with climate change. Nature Climate Change 1: 261–265.

Morrison, S.A., T.S. Sillett, C.K. Ghalambor, J.W. Fitzpatrick, D.M. Graber, V.J. Bakker, R. Bowman, C.T. Collins, P.W. Collins, K.S. Delaney, D.F. Doak, W.D. Koenig, L. Laughrin, A.A. Lieberman, J.M. Marzluff, M.D. Reynolds, J.M. Scott, J.A. Stallcup, W. Vickers, and W.M. Boyce. 2011. Proactive conservation management of an island-endemic bird species in the face of global change. BioScience 61:1013–1021.

Polasky, S., S. R. Carpenter, C. Folke, and B. Keeler. 2011. Decision-making under great uncertainty: environmental management in an era of global change. Trends in Ecology and Evolution 26: 398–404.

Stephenson, N. L., and C. I. Millar. 2012. Climate change: Wilderness's greatest challenge. Park Science 28: 34–38.


Emergency Management California is already seeing the effects of climate change and the amplification it causes on the hazards we face. It is essential we account for climate change in planning for future disasters. In this respect, we encourage more emphasis be given to prevention of and preparation for these events, rather than focusing on how to respond once an event takes place. Nature can play an essential role in risk reduction and prevention. As mentioned in our general comment letter, we urge the final Plan to prioritize natural infrastructure over engineered actions, where feasible. We are pleased that this chapter highlights green infrastructure, restoring and creating wetlands and urban greening as potential hazard mitigation strategies and recommend these actions be prioritized. While risk reduction strategies will vary based on location, natural infrastructure can provide a cost effective means of reducing overall risk to infrastructure and people. Utilizing natural infrastructure for climate resilience can include:

expanding existing habitats through conservation strategies (such as Natural Community Conservation Planning programs);

protecting and restoring habitats to enhance flood mitigation and ecosystem services (for example, TNC is involved in a flood management project in Hamilton City along the Sacramento River, the Hamilton City Flood Damage Reduction and Ecosystem Restoration Project, where a century-old levee is being set back and natural conditions are being restored to reduce flood risk to the community);

creating new habitat such as oyster reefs and artificial wetlands; and integrating natural systems into hard infrastructure (and vice versa) to provide long-

term ecological and climate benefits. In addition to flood management, ecosystems provide many economically beneficial services that support and protect humans and nature such as filtering pollutants, erosion control, production of fish and shellfish, and clean drinking water. Green responses can also be used as a first step, delaying the time and the extent of an eventual grey response. Priority should be given to these multi-benefit actions. Moreover, natural infrastructure has lower long-term maintenance costs than “grey” infrastructure. More information, including the cost effectiveness, is provided in our recent report, “Reducing Climate Risks with Natural Infrastructure,” attached herein.1 General Comments:

Improve mapping to include future conditions and natural infrastructure: Currently maps, such as those used for flood management, do not consistently include information on the most vulnerable areas to sea level rise, erosion and increased storm surge potential nor on important natural features that provide disaster risk reduction benefits. Ensuring this information is consistently available will help local communities to effectively incorporate natural infrastructure in their community planning and will help align federal funding sources to these efforts.

1 Available here: http://www.nature.org/ourinitiatives/regions/northamerica/unitedstates/california/ca-green-vs-gray-report-2.pdf


Begin with the state: map state facilities at risk from climate-amplified extreme weather events including wildfire, flood and sea level rise and coastal hazards. Tools like CalAdapt exist for the state to augment the final Plan by identifying all state facilities as well as critical community resources like hospitals, water and waste water treatment plants and schools at-risk. This action will facilitate integration of climate change into the State’s emergency planning and management and should also apply cross sector.

Prioritize conservation and restoration land protection so investments in open space and conservation also contribute to reduce risk and vulnerability. Funding criteria used by agencies with land protection programs should include criteria that prioritize natural areas that also provide disaster risk reduction benefits. Restoring natural conditions is an effective strategy with multiple benefits that should be given priority wherever feasible. TNC is involved in a flood management project in Hamilton City along the Sacramento River, the Hamilton City Flood Damage Reduction and Ecosystem Restoration Project, where a century-old levee is being set back and natural conditions are being restored to reduce flood risk to the community.

Energy Energy strategies and key recommendations from the 2009 Adaptation Strategy should be retained and expanded on in the SCP. Specifically,

Urban greening; Protecting species and habitat when developing Natural Community Conservation Plans

and other mitigation measures for power plants; and Identifying vulnerable communities that will be disproportionately affected by higher

temperatures and increased energy demand. Vulnerable and EnviroScreen disadvantaged communities at risk from climate impacts should be spatially displayed in the final Plan.

These strategies are important for the energy sector to use when responding to a changing climate and should be prioritized in safeguarding the energy sector. The SCP Energy chapter highlights a number of important issues, some of which would benefit from expansion and clarification:

The economic and ecological issues related to the increased use of woody biomass should be more thoroughly explored before specific action siting new facilities is taken.

Hydropower adaptation options should be evaluated, with special attention given to the potential impact on water flow, water temperature and impacts on fish, particularly salmon.

The roles of trees, especially in urban forests, should be highlighted and cross-sector collaboration with the forestry and other sector should be explored (see below). Trees remove pollutants from the air and keep our cities cooler, and play an important role in lowering demand for energy consumption and improving the quality of our neighborhoods.


Additional cross-sector impacts and opportunities for the Energy Sector should be identified and adopted, where feasible. Potential cross-sector collaborations for the Energy Sector with various other sectors should include:

Emergency preparedness: it will be critical for the energy sector to have a plan for emergency response. Impacts of climate change on energy facilities are critical to consider in this cross sector analysis.

Water: water conservation, increased risk to hydropower, and the role of hydropower facilities in water storage and runoff should all be addressed by both the water and energy sectors in a coordinated effort.

Forestry: increased use of biomass, risk of fire, and risk to transmission lines from fire all affect both the forestry and energy sectors.

Biodiversity: protecting habitat, migration corridors and sensitive species is essential when citing new power facilities and undertaking mitigation measures. All decisions for citing of new energy facilities should include an analysis of climate change impacts over time. Salmon and other fish should be considered when considering new hydropower facilities.2

Public health: identifying and aiding vulnerable communities who are disproportionately affected by high heat days and ensuring energy security and are important for both the public health and energy sectors.

Forestry California’s forests provide a multitude of benefits including the capacity to help regulate the climate by storing vast amounts of carbon. Maintaining this benefit helps both emissions reduction and climate response (mitigation and adaptation). Forests also have important co-benefits with water management as well as biodiversity and habitat. To take advantage of these multiple benefits in urban settings, the state should: Create cross-cutting Urban Forestry team. We were pleased to see references to urban

forestry in the public health, emergency management and forestry chapters. Urban greening clearly illustrates how conservation of nature and forests can help communities respond to increased temperatures, while also sequestering carbon, creating more livable communities, and providing habitats for birds and animals. Given the important role this plays in these sectors and others (such as energy), we recommend creating a cross-sectoral strategy and a workgroup to coordinate various state agencies and share staff resources and funding to promote a more robust urban forestry program in California.

Proper forest, land management and land use decisions can reduce ignition sources and restoring appropriate fire regimes and can reduce the impacts of intense wildfires. To this end, we suggest the following opportunities for enhanced wildfire hazard mitigation:

2 See Evaluating and predicting habitat suitability for California salmon: improving models through a holistic perspective - Final Project Report. R&D Report. Publication # CEC-500-2013-150. Posted: December 23, 2013http://www.energy.ca.gov/2013publications/CEC-500-2013-150/CEC-500-2013-150.pdf.


Reintroduce fire (controlled or prescribed burns) to fire-prone ecosystems. The Nature

Conservancy supports greater use of prescribed fire as an effective tool to promote forest health and to reduce risk of high-intensity crown fire and therefore risk to human communities.

Reduce accumulated fuel load through thinning and brush removal. The Nature Conservancy supports greater use of thinning and brush removal providing sustainability criteria are adopted and adhered to, as an effective tool to promote forest health and to reduce risk of high-intensity crown fire and therefore risk to human communities. We recommend that the strategy also recommends enhanced use of biomass energy, again with appropriate environmental sustainability safeguards, to improve forest health, reduce fire risk, promote alternative energy production and provide local economic benefits including jobs.

Additional resources to be included in the Forestry Chapter:

Forecasting the Response of Terrestrial Habitats to Climate Change in the Northern Sierra: Climate Adaptation Strategies for the Northern Sierra Partnership, where LANDFIRE vegetation data was used by the Northern Sierra Partnership to explore how climate change may impact terrestrial ecosystems. Available here: http://www.conservationgateway.org/Files/Pages/forecasting-response-terr.aspx

EcoAdapt’s Vulnerability Assessment for Focal Resources of the Sierra Nevada, which analyzes species (such as yellow-legged frogs) and ecosystems (such as wet meadows) vulnerable to climate change and discusses various adaptation measures. Available here: http://ecoadapt.org/programs/adaptation-consultations/calcc/ . This information will be used to inform the USFS climate scorecards and update the Forest Plan, and has potential to be replicated in other forests throughout the state.

Health We were pleased to see the public health chapter acknowledge the link between a “healthy and stable natural environment” and the health of our communities (page 185) and promotes natural resource investments that help communities prepare for risk (page 201), such as urban greening (page 205).

Given the current staff and funding resource limitations, the final Plan should contain a prioritization of its proposed actions. Noting there are a number of factors to be considered when prioritizing actions for the health sector, we urge the Plan to include the following: (1) natural infrastructure over engineered actions, where feasible; (2) strategies that simultaneously address mitigation and adaptation; (3) actions that provide other co-benefits to the community (e.g. urban greening); and (4) actions targeted at protecting vulnerable populations.

Nature can help alleviate each of the major health impacts of climate change. For example:

Rising temperatures and increased air pollution (page 187) – urban greening, greenbelts and parks keep our cities cooler, resulting in fewer deaths from heatstroke, while also removing smog and pollution from the air, thus lowering the incidence of respiratory illness. The dual benefit of mitigation is provided by the carbon sequestration from the trees.


Increased precipitation and flooding (page 189) –riparian habitats provide a buffer against flood and storm surges protecting human communities from the property damage, injury and deaths associated with these events as well as helping to reduce erosion and preventing water contamination.

Sea level rise– wetlands, riparian corridors and coastal habitats can slow the impact of sea level rise on property and buffer communities from flooding events resulting from storm surges and peak tides.

More frequent catastrophic wildfires (page 189) – proper forest and land management can reduce ignition sources and restore appropriate fire regimes will reduce the incidence of wildfires.

Land degradation leading to soil erosion, loss of soil productivity, and risks to our food supply – hillside trees and other vegetation prevent erosion, while intact rivers and watersheds and healthy floodplain habitats produce soil, thereby protecting productivity.

Increase in infectious diseases (page 190)- ecosystem-scale conservation, maintaining habitat connectivity and proper watershed management prevent the loss of biodiversity, and in turn, reduces vector-borne diseases and preserves sources of medicine.

Conservation of our natural resources is a key component to helping communities respond to the impacts of climate change, while also reducing emissions and providing a multitude of co-benefits and therefore must be given priority in Plan.

Finally, we strongly support the comments submitted by the Public Health Institute and urge the SCP to incorporate their recommendations and edits.

Transportation The Transportation chapter provides a good overview of many of the climate related impacts California’s transportation system faces. It could be improved by including a discussion of nature-based solutions and metrics and other, qualitative indicators of success. Connect Transportation and Natural Systems This chapter would benefit from a more holistic view of what impacts our transportation system and the solutions to address them. For example, how the changes in hydrologic regimes will impact roadways (to this end, the Department of Water Resources should be listed as a state agency at the end of the chapter, page 220). Additionally, our roadways impact essential habitat throughout the state. We were pleased to see mention of the Essential Habitat Connectivity Project (EHCP) (page 214). However, it lacks implementing funds or actions associated with the project, and none associated with Caltrans. The EHCP should require specific actions to preserve connectivity both dealing with habitat connectivity actions and reducing or mitigating fragmentation, including retrofitting existing structures that are current barriers to migration. The “action needed” to better understand the specific vulnerabilities of transportation infrastructure (page 217) should include retrofitting of existing facilities to address vulnerabilities and resilience, such as allowing for tidal flow or wildlife connectivity. In addition, the final Plan should include a map of state transportation


facilities at risk from climate-amplified extreme weather events including wildfire, flood and sea level rise and coastal hazards. For the recommendations to “use state of the art materials and infrastructure design for resilience” for new construction and repairs (page 219), we recommend a provision for new construction and repairs to address habitat connectivity and migration corridors as well. Additionally, under strategies to “improve the reliability of California’s transportation system in face of expected climate impacts” (page 219), we urge the adoption of the following strategy: “Prioritize multi-benefit actions and promote natural system function and services, where feasible.” To help achieve this, a long term, life cycle analysis of all proposed solutions (both green and grey) should be conducted before selecting one. This analysis should account for the ecosystem service and habitat benefits provided by natural, or green, solutions including change in carbon and greenhouse gas emissions avoided. Green infrastructure can play an important role in reducing risk for the transportation sector and should be discussed in this chapter. To this end, when discussing Hurricane Sandy (page 210), reference should be made to Mayor Bloomberg’s extensive assessment3 of the disaster and the steps New York should take to become more resilient , including the nature based solutions. Finally, to improve information sharing and education (page 220), we recommend the interagency task force referenced on page 220 be convened by CalTrans and include natural resource, conservation, and environmental agencies. Training tools and guidance for transportation professionals should include green infrastructure solutions (discussed above). Include Metrics for Success As mentioned in our general comment letter, this chapter should include metrics and other, qualitative indicators to measure how we will know if the transportation sector is being “safeguarded”. For example, one metric of success can be improved habitat connectivity and resilience, and use of green infrastructure. An assessment could be conducted to measure how many facilities currently impede natural systems and habitat connectivity, and this can be measured over time to track improvement. Water The recommendations for the water sector make sense, and we agree with the recommended actions. In particulate, we applaud the actions addressing flood management and groundwater resources. In general, however, recommendations lack specific timelines for implementation. We suggest that timelines and milestones for the recommendations be established, and would be pleased to work with the Natural Resources Agency (NRA) and the Department of Water Resources (DWR) to establish in work toward achieving the milestones once they are established.

Additionally, it would be useful to many stakeholders if the NRA and DWR published or by other means, made available their assumptions about which watersheds would be affected in

3 Available: http://www.nyc.gov/html/recovery/downloads/pdf/sandy_aar_5.2.13.pdf


what ways by the effects of climate change, especially any assumptions they have employed in analyses about future hydrology for each hydrologic region in the California Water Plan Update. General Comments and Key Recommendations: Use an integrated, watershed-based approach to design, plan and manage our water

resource infrastructure to optimize the multiple benefits and consider natural, social, and built systems as a whole. While our country has built water resource projects usually one at time, it’s the cumulative effect of our investment in many projects that determine their environmental and economic benefits and impacts. Often projects are planned and carried out with a singular goal focus and not designed to achieve multiple benefits. We need to plan, manage and set fund priorities on watershed basis to meet and achieve the collective needs of the many stakeholders in a watershed. One resource that water resource planners and managers at all levels of government can use is the Climate Change Handbook for Regional Water Planning (November 21, 2011, prepared for the U.S. Environmental Protection Agency Region 9 and the California Department of Water Resources).

Increase “above-the-dam” regional natural water storage system. The Nature Conservancy notes that “above the dam” storage using natural, ecosystem-based processes plays an essential role in preparing for, and responding to impacts of climate change. In addition to helping stabilize the state’s water supply, these conservation-oriented actions provide multiple, cross sector benefits, as noted, to forests, biodiversity, fire risk reduction and meadow conservation.

Specific Comments:

Page 225: Reference to possible need for “legal changes” is unclear. Is this in reference to existing operations? Or is it suggesting there is a need to file a lawsuit to change operations to provide for climate change? The final report should clarify and amplify the constraint and the range of remedies.

Page 232: In reference to progress made since 2009 Adaptation Strategy, it would be helpful to cite examples of the progress or point reader to section in document that contains examples of the progress; or, if this sentence is a lead in to the following paragraphs, add a sentence explaining examples of some of the progress follow.

Page 237: “It will also be important critical to continue and enhance monitoring of changing water conditions.” (Replace “important” with critical”.)

Page 238: For example, regionally managed groundwater recharge, storage, and conjunctive use (the coordinated management of surface and groundwater) can play a key role in compensating for SOME OF the loss of natural water storage as the Sierra Nevada snowpack diminishes. (Insert “some of” before “the loss”.)

Page 238: “State level support and oversight should be provided where needed to ensure the success of local and regional management efforts.” (Delete the words “where needed”.)

Page 239: “GAIN AND promote better understanding about California’s groundwater…” (Insert the words “Gain and” before “promote”.)


Page 239: Support regional groundwater management for drought resiliency-- Add bulleted item as follows: “Develop and fund a state program for researching, evaluating, and monitoring the impacts of groundwater pumping on desert, floodplain, and wetland ecosystems.”

Page 239: “Develop and fund a state program for monitoring drought impacts on groundwater resources, including FUNDING for remote sensing-based monitoring of land subsidence associated with groundwater extraction…” (Insert “funding” before “for remote sensing”.)

Page 242: “Develop a coordinated streamlined permitting process for desalination projects that provides strong environmental protection” ADD TEXT: “and does not induce residential or commercial development in areas vulnerable to climate change impacts.”

Page 244: “The State Water Board and DWR should MUST develop funding criteria to discourage construction of new water infrastructure in high-risk areas.” (Replace “should” with “must”.)

Page 245: “The Governor’s Office of Planning and Research will engage local land use authorities and water agencies and amend the General Plan Guidelines to promote local land use decisions that are consistent with local sustainable water management.”-- See Guidebook for Implementation of SB 610 and SB 221 of 2001--to assist water suppliers, cities, & counties in integrating water and land use planning, (DWR, 10/8/03) OPR and others can build from these laws.

Page 246: “In order to reduce these risks, the state should MUST continue its efforts to restore key wetlands and to ensure adequate water quality and supply for important ecosystems. Collaboration between state entities working on water issues and ecosystem management issues will also continue to be important.” (Replace “should” with “must” and delete “also”.) Also, add a sentence to this paragraph that emphasizes outreach to stakeholders and the public to develop management actions for protecting the state's water-dependent ecosystems that provide multiple benefits, such as filtering contaminants, storing water, and recharging aquifers, as well as providing critical habitat.

Thank you for your leadership and hard work in preparing the Safeguarding California Plan and the opportunity to submit these comments. Please do not hesitate to contact Louis Blumberg, [email protected] or Alex Leumer, [email protected], if you have any questions. Sincerely, Louis Blumberg Director, California Climate Change Program The Nature Conservancy Alexandra Leumer Climate Change Policy Associate The Nature Conservancy

February 28, 2014 Ms. Ann C. Chan Deputy Secretary for Climate Change California Natural Resources Agency 1416 Ninth Street, Suite 1311 Sacramento, CA 95814 Re: Comments on the 2014 Draft Safeguarding California Plan Dear Secretary Chan, The Nature Conservancy, Defenders of Wildlife, National Wildlife Federation, Environmental Defense Fund, Natural Resources Defense Council, Audubon California, California Native Plant Society, Public Health Institute, Point Blue Conservation Science, Pepperwood Preserve, Council for Watershed Health, Save the Bay, Santa Clara Valley Open Space Authority, Land

2014 Safeguarding California Plan Comments P a g e | 2

Trust of Santa Cruz County, Sierra Nevada Alliance, Bay Area Open Space Council, Peninsula Open Space Trust, Bolsa Chica Land Trust, Sonoma Land Trust, and Big Sur Land Trust welcome the opportunity to provide comments on the Safeguarding California Plan: Reducing Climate Risk (“SCP” or “the Plan”), an update to the 2009 California Climate Adaptation Strategy.

We thank the Natural Resources Agency for producing this important document. It provides a comprehensive summary of climate change impacts across California and an excellent catalogue of available resources. The SCP also gives state agencies and departments a strategy to help them address the impacts of climate change, both now and into the future.

Our organizations are invested in ensuring that the Plan results in aggressive and effective state action for reducing risk and building climate resilience, and we believe that to achieve this goal, clear guidance to state agencies is essential. This notion is reinforced by Governor Brown’s recent statement to the President’s Taskforce on Climate Preparedness where he said that, “one of my priorities [is] to emphasize the dangers of climate change. In California, we're going to do everything we can".1 The current drought is pushing environments and resources beyond previous thresholds, thus raising a unique opportunity to increase awareness and develop adaptive responses in real time. In order to maximize impact and achieve the Governor’s vision, we recommend that the next draft of the SCP be revised to make the Plan more action-oriented. Specifically, we suggest that the next draft offer more specific strategies and include more aggressive actions with a prioritized timetable of next steps for implementation. We also recommend improving the integration and coordination of the Plan across various sectors. The Cross-sectoral Strategies begin to achieve integration by highlighting a few common strategies, and we recommend including additional strategies to prioritize natural infrastructure and avoid investment in high risk areas. We also suggest strengthening this section by incorporating a common set of goals and principles. Finally, all strategies and plans should be based on state-of-the-art science.

The Safeguarding California Plan is an important addition to the state’s growing body of climate change related planning and if strengthened, could reduce climate-magnified risks to California’s human and natural communities. We appreciate the hard work that has resulted in this draft respectfully request that you enhance the Plan by adopting the following recommendations. These comments are focused on the overall plan and some of the undersigned groups will submit sector-specific comments.

1. Adopt a common set of goals and principles. We recommend adopting the set of common, cross-sector principles and goals as articulated in the group letter submitted November 1, 2013. Adopting a clear goal and core set of principles will provide direction and focus to the SCP and promote continuity among the various, sector-specific sections. This addition will create a solid foundation for an effective cross-sectoral approach.

2. Create a cross-sectoral strategy to prioritize natural infrastructure over engineered actions, where feasible. The SCP should include guidance to agencies on how they should

1 E&E News, Friday, February 14, 2014 http://www.eenews.net/climatewire/2014/02/14/stories/1059994609


prioritize the proposed “actions needed”. This guidance should direct agencies to establish a preference for green or nature-based responses to the maximum extent feasible including restoration, conservation, and projects on agricultural land, forests, wetlands, and grasslands. This approach would also prioritize multi-benefit actions and promote natural system function and services in addition to risk reduction including water and food security, habitat for fish and wildlife, recreation, jobs, and quality of life amenities. Furthermore, protecting natural systems will help mitigate climate change by sequestering carbon and avoiding emissions associated from conversion of natural lands. This policy is a good mechanism to catalyze cross-sector, cost-effective action. We were pleased that many sectors discussed, to some degree, the importance of natural infrastructure in reducing climate risk. For example, the strategy is well captured in the Biodiversity chapter on page 56:

“Promote Nature-Based Solutions for Adapting to Climate Risks The State should encourage and support the consideration of nature-based approaches for preparing for climate risks where such approaches are available. In order to support informed decision making, funding is needed for studies that help quantify the benefits of ecosystem services that reduce climate risks.”

We recommend including this language in the section on cross-sectoral strategies so that it applies to all sectors.

3. Revise the actions to be more specific, compelling, and more readily discernable. The proposed actions in the Plan are arguably its most important element and will hopefully be implemented by the relevant agencies. However, we recommend that the actions be more specific and aggressive. To achieve the Governor’s vision, more far-reaching actions are required. For example, the final Plan should identify all state buildings at risk from increased sea level rise and coastal hazards and from increased fire hazard and offer a process for setting priorities for protective actions. In some locations, “managed retreat” may be the most appropriate action to reduce these climate-amplified risks. This strategy discussed in the Oceans and Coastal chapter, pages 169-170 and should be considered in implementing actions to safeguard state facilities. Additionally, the current organization of the report makes it difficult for the reader to find the actions. It would be helpful if the strategies could be pulled out and highlighted in a more action-oriented format. We recommend creating an Executive Summary “action guide” so that all the sector strategies can be viewed at once in a brief document making them more easily accessible and increasing the chances that they will be understood, implemented and monitored.

4. The Plan should direct state agencies to integrate consideration of climate change into their standard business practices. We note that the Plan appropriately includes the goal that, “All core functions of government must make the risks Californians face from a changing climate an integral part of their activities.” (page 3). However, the recommended actions are qualified and the Plan defers any commitment to this key strategy due to a lack of training and funding. Given the urgency for action, well-articulated by Governor Brown and many others, we urge the state to provide the additional resources necessary to implement this goal immediately. As clearly evidenced in the Plan itself, many tools have been


developed since 2009 and are now available to state agencies to assist them in conducting the needed analyses. We believe that responsible planning today requires consideration of climate change, a notion increasingly demonstrated by the private sector, for example, by Dow and Coca Cola.2

5. Create a cross-sectoral strategy to avoid development in areas that would be at increased risk from climate change impacts such as drought, flood, wildfire, and sea level rise. This is a straight forward, common sense strategy that was referenced in the Oceans, Emergency Management, and Forest sector chapters, but it should apply to all sectors in the Plan. In addition, the SCP should recommend that all state capital outlay projects of $1,000,000 or more include a climate impact and risk management analysis up to 2050. This action will help the state make fiscally sound and prudent investments in the context of a changing climate.

6. Strengthen the focus on risk avoidance and prevention. A stronger role for prevention should be included in the Plan, highlighting actions we can take now that are flexible and will protect us for years to come. Additionally, there should be a more detailed analysis of the human and natural communities at risk, for example, disadvantaged communities (as identified by Cal EPA) that are at risk from climate-magnified extreme events should be identified in the final Plan. To produce this information, statewide vulnerability assessments will be required to identify communities most at risk. Funding for risk reduction measures (such as restoring wetlands to protect coastal communities from sea level rise) could then be prioritized in these areas.

7. Specific actions should be included to protect vulnerable populations. As the Plan appropriately notes, climate change results in a disproportionate impact on vulnerable populations and disadvantaged communities; this is so globally. The SCP should clearly outline strategies to specifically address this “climate gap” and the multiplier effect of climate change on existing health inequities. While the introduction notes the need to ensure that risk reduction measures provide for the most vulnerable populations and several chapters discuss vulnerability, additional steps must be taken to translate this into specific actions or targeted strategies. For example, the Plan should include the concept of climate change as a threat multiplier, discuss pre-existing health inequities and pre-existing differential exposures to pollutants, as well as differential adaptive capacities associated with limited economic resources and limited transportation options.

Additionally, a coherent approach is needed to engage vulnerable populations and communities in this discussion. The Plan does not provide means to ensuring that low-income people and disadvantaged communities benefit from the full advantage of adaptation strategies (such as energy retrofits, green buildings and green infrastructure, urban forestry, insurance) that have up-front costs and health and economic co-benefits longer-term. Working with these communities is essential to truly “safeguard” California.

2 See: Industry Awakens to Threat of Climate Change: http://www.nytimes.com/2014/01/24/science/earth/threat-to-bottom-line-spurs-action-on-climate.html and Dow Chemical, Addressing Climate Change http://www.dow.com/sustainability/goals/climate.htm


8. Develop a plan to implement the actions outlined in each chapter and include metrics for success. The SCP does not include a timeline or "next steps" strategies. It also does not provide clear guidance to agencies - it does not identify specific agencies responsible for implementation, goals to guide implementation for the agencies, or metrics to measure progress. We recommend that the plan be revised to include a schedule for implementation with priorities, either for the SCP as a whole or for each individual chapter. Additionally, the Plan should include clear metrics for success to measure progress in “safeguarding” California. Once completed, the guide and metrics should be available online where status updates can and should be posted bi-annually.

9. Make the relationship to other state planning documents clear. Finally, the Plan should link more directly to other state climate planning efforts (such as the State Hazard Mitigation Plan, Environmental Goals and Policy Report, Adaptation Planning Guide, and the Scoping Plan), and many more. Coordinating the many climate change-related efforts taking place within California is essential to ensure efficient use of resources and avoid duplicative efforts and can also build relationships between the various climate change specialists at state agencies. The role these other efforts will play in the implementation of the SCP (or vice versa) should be outlined in the introduction of the Plan, but should also be an online resource that would be frequently updated as new state actions arise. Achieving this goal will be facilitated by broad adoption of the goal and principles recommended above in number 1.

In closing, we are eager to collaborate with you and your staff to integrate our recommendations into the final Plan and collectively, produce a final plan that meaningfully reduces climate risk to the people and natural resources of California. We commend you for the good work that has been accomplished to produce this draft Safeguarding California Plan and thank you for the opportunity to provide these comments. Please do not hesitate to contact any of our groups for follow-up.

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February 28, 2014 Ms. Ann C. Chan Deputy Secretary for Climate Change California Natural Resources Agency 1416 Ninth Street, Suite 1311 Sacramento, CA 95814 Re: Comments on Safeguarding California: Preparing for Risks an update to the 2009 Climate Adaptation Strategy – Ocean and Coastal Resources Chapter

Dear Secretary Chan:

Thank you for the opportunity to provide comments on the Ocean and Coastal Resources chapter of the Safeguarding California: Preparing for Risks an update to the 2009 Climate Adaptation Strategy (“the Plan”). The Nature Conservancy (“TNC”) and Save the Bay are very pleased that the Natural Resources Agency has taken the important step of updating the groundbreaking 2009 Climate Adaptation Strategy (“CAS”), maintaining California’s leadership on climate change adaptation policy in the United States and globally. As you know, TNC has provided a separate letter regarding the overall plan, but because of our unique experience working with local communities on adapting to coastal climate change, we wanted to call special attention to this section of the Plan.

In general, the Ocean and Coastal Resources chapter is one of the more thoroughly developed chapters in the Plan, reflecting the strong scientific and policy foundations that the state has developed over the past several years. In addition, this chapter contains the strongest and most explicit action item – the Ocean Protection Council (OPC)-led process to inventory existing actions to reduce risks from sea level rise, storms and erosion, and to improve the capacity of entities at multiple scales to more effectively act to reduce these risks. This commitment reflects an appreciation of the importance of the risk from sea level rise and coastal hazards, and the need to move beyond science and planning toward affirmative risk-reduction action. We look forward to participating in this process. We offer a number of specific comments and recommendation, below:

1) The Plan should affirmatively settle the status of the guiding principles from the 2009 CAS. The document’s pledge to produce – at some unspecified time – “a framework for improved action to reduce risks and support vibrant, healthy coastal and bay communities and natural landscapes”

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(p149) is a vague and inadequate substitute for explicitly reaffirming the continued validity of these principles. In general, we support these principles, and we recommend that the Plan to adopt them. The only reason to abandon them would be if new science has emerged since the release of the 2009 CAS justifying a new course; to our knowledge, this has not occurred.

2) While the cross-references are helpful, given the length of the overall document, it would be useful to have short descriptions of the connections between sea level rise (SLR) and flood hazard management, saline intrusion, and sea level rise impacts on transportation and energy infrastructure in this section (p149). In particular, the connection between SLR and hazard mitigation should be better developed here and referenced in the Emergency Management chapter, as that connection is fundamental to making the Coastal Commission SLR guidance work. The chapter would be made substantially more robust by describing how the Plan is meant to inform the management decisions of the agencies tasked with managing those infrastructure elements (CalTrans and the California Energy Commission).

3) The Plan states that “Sea-level rise presents very significant fiscal risks” (p155). This is certainly true, and the chapter could include significant additional detail on the range of fiscal risks. Economic impacts can consist of effects on the natural environment, or on the ecosystem services, including changes in erosion caused from rising tides, loss of habitat due to increased flooding and erosion, reduced beach width, and sand retention. Other economic impacts arise from the loss of vitality of the regional economy. The Plan should explicitly acknowledge that climate change impacts are anticipated to reduce the tourism sector of an economy, and this may have a ripple effect throughout the region and reduce the numbers of jobs and income.

4) The map on p156 sends an unsettling message about the state’s SLR adaptation priorities. It seems insensitive for the Plan to highlight the suite of very profitable companies in the South Bay whose facilities are vulnerable to SLR, when there are many disadvantaged communities who are at least as vulnerable to the physical changes, but lack the resources to adapt. We recommend that the Plan include a map displaying disadvantaged communities at risk from SLR and coastal hazards, consistent with CalEPA’s EnviroScreen method, and a map illustrating the state facilities at risk from SLR and coastal hazards, as these are the primary purview of this Plan.

5) We are pleased that the Plan highlights the multiple benefits of wetlands. As the Plan highlights, a substantial percentage of the state’s original wetland expanse has been lost to conversion, and many of these benefits have been lost as well. A number of critical knowledge gaps limit our ability to comprehensively quantify the values of wetlands, as well as our ability to protect them in their current and future locations. Specifically, we lack the analytic ability to predict the future location of many of our wetlands, as traditional modeling approaches (i.e., SLAMM) fail to accurately capture the dynamics of many California estuaries. In addition, we lack a standardized approach to account for the carbon sequestration role of coastal wetlands. Finally, the hazard mitigation value – including wave attenuation, surge reduction, and other coastal hazard mitigation – of west coast wetlands is not well quantified. These three knowledge gaps should be fully evaluated in the Science Needs Assessment recommended on p174-175, and the economic

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value of coastal natural resources and the impact to these resources of sea level rise should be the primary focus of the economic research proposed on p172.

6) The discussion of the state’s achievements to date should be updated to include the release of the Coastal Commission’s Sea Level Rise Policy Guidance. This is a tremendous accomplishment, and – perhaps – the most significant contribution the State has made to date to promote SLR adaptation action (p168). In addition, the Bay Conservation and Development Commission’s Bay Plan Amendment incorporating SLR should also be mentioned (p169).

7) Although the State’s investment in local vulnerability assessments is significant (p168, 171), it is – unfortunately – dwarfed by the need. The three recent grant rounds administered by Ocean Protection Council/California Coastal Commission/State Coastal Conservancy amply demonstrated that there are many more communities eager to get SLR planning underway than there are funds to support these activities. The state needs to create a long-term, dedicated funding source to support local SLR adaptation planning, as well as to support implementation of the plans once they have been created.

8) California is fortunate to have several sophisticated, dynamic, fine-scale models at its disposal to assess the impact of SLR on coastal communities (see, e.g., models developed for Coastal Resilience Ventura (www.coastalresilience.org/ventura); Our Coast Our Future (www.prbo.org/ocof)). Rather than develop new models, the State should develop a program to provide comprehensive, dynamic inundation modeling of all coastal areas of the state using existing models (p173). This underscores the opportunity to use existing tools and resources to integrate climate change considerations into standard state business practice.

9) The “Hazard Avoidance for New Development” recommendation is a good start, but should be strengthened. As currently drafted, the recommendation admonishes the state to “not build or plan to build, lease, fund, or permit any significant new structures or infrastructure that will require new protection from sea-level rise, storm surges or coastal erosion during the expected life of the structure” (p174). It goes on to provide for what should be done in the event that such development does occur. Further, there is an entire recommendation for innovative design of structures that violate the hazard avoidance principle. This sends the wrong message: the policy of the state should be – simply – that new development in the hazard zones should be avoided, as was explicitly stated in the 2009 CAS. This stronger, clearer construct for hazard avoidance should be applied across all sectors in the Plan.

10) We are very pleased that FEMA’s programs (the National Flood Insurance Program and the Hazard Mitigation Assistance Programs) are highlighted in the context of SLR and coastal risk (p159 et seq.). However, this section could benefit from information on how state and local planning can inform FEMA’s prioritization of hazard mitigation resources. For example, through participation in the Community Rating System, communities can encourage flood risk mitigation and open space preservation, and offer reduced premiums as a result. Similarly, inclusion of adaptation strategies in the State Hazard Mitigation Plan or Local Hazard Mitigation Plans make those strategies eligible for funding under FEMA’s Hazard Mitigation Assistance program.

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Recommendation 3, pertaining to the “Integration of Climate Risk Considerations…Into Emergency Management Activities” (p174) should be elaborated upon, providing specific reference to these and other relevant hazards mitigation planning activities. In addition, we strongly recommend that the state prioritize hazard mitigation activities that wisely integrate the natural buffering capacity of coastal habitats like wetlands and beaches into an overall plan for protecting coastal communities from sea level rise.

11) We agree that innovative shoreline management projects should be supported by the state (p175), but urge the Plan to explicitly prioritize pilot projects that demonstrate the efficacy of managed retreat, rolling easements, wetland restoration/construction, and other natural infrastructure approaches.

12) The Plan should include a recommendation that the agencies managing the most significant coastal lands and other assets – specifically State Lands, State Parks, and CalTrans – should develop (or update) system-wide sea level rise adaptation strategies. These strategies should adopt guiding principles that ensure that the long-term management of these public assets does not result in any significant loss of coastal natural resources, and agencies should undertake to demonstrate – to the extent possible – how natural resources can be a component of a comprehensive plan to protect the state’s assets.

* * * * *

Thank you for the opportunity to provide these comments. As stated above, the draft Ocean and Coastal Chapter sets a strong foundation, and reflects a high level of commitment on the part of the state to better understand and manage the impacts of climate change on ocean and coastal resources. Thank you for your hard work on this, and please feel free to contact me if you have any questions.

Sincerely,

Sarah Newkirk David Lewis Coastal Project Director , TNC-CA Save the Bay

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Comments on the Safeguarding California Plan:

an update to the 2009 State Climate Change Adaptation Strategy November 1, 2013

The Nature Conservancy, Defenders of Wildlife, Pacific Forest Trust, Point Blue Conservation Science, Environmental Defense Fund, Audubon California, Save The Bay, Greenbelt Alliance, Climate Resolve, the California Native Plant Society, the Big Sur Land Trust, the Pacific Institute, Peninsula Open Space Trust, California Resources Conservation Districts, and Bolsa Chica Land Trust are pleased to submit these comments on the Safeguarding California Plan (SCP), a multi-sector strategy to guide the state’s efforts in adapting and reducing risk from climate change. California is leading the way on a host of policies, programs, and plans intended to prevent, prepare for, and adapt to climate change. These measures are spread across a range of sectors and agencies, encompassing a wide spectrum of strategies to reduce greenhouse gas emissions while simultaneously helping California to respond to the unavoidable and escalating impacts of a changing climate. Given such a large and diverse portfolio of climate change strategies and plans spread across state government, we believe that the state’s efforts can be most effective if they are guided by a shared set of goals and principles to coordinate their design and implementation. Below, we propose a set of Core Goals and Climate-Smart Principles to guide state climate planning activities that include a preference for natural infrastructure as a climate change adaptation response. Adopting these goals and principles as part of the Safeguarding

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California Plan will not only allow for synergy across climate planning activities, but will also provide a foundation for integration across the various sectors in the plan, facilitating coordination between the many departments and agencies involved in addressing this global challenge. In conclusion, we respectfully request that the California Natural Resources Agency adopt these Core Goals and Climate-Smart Principles and incorporate them into its Safeguarding California Plan. The climate is changing and impacts are happening now, here and around the globe. The time has come for comprehensive and integrated plans and actions that include nature-based, Climate-Smart solutions to help California and its communities prepare for the changes that will come. Thank you for your leadership on this important initiative.

Core Goals for Safeguarding California Plan 1. Goals: We recommend that the SCP adopt the following core set of goals to provide direction and focus to the SCP and to promote continuity among the sections focused on specific sectors.

1. Assess vulnerabilities and risks from climate change 2. Increase the resilience of the state’s built and natural environments 3. Increase the state’s preparedness for extreme climate events 4. Protect public health from the effects of climate change 5. Protect California wildlife and habitats from the effects of climate change 6. Maximize restoration, and protection of natural resources to reduce risk of extreme

events and carbon pollution 7. Create resilient communities through public information, outreach and planning 8. Reduce, avoid and track greenhouse gas emissions and reductions 9. Facilitate advancement of science and tools to support research, planning and policy

in CA 10. Serve as a global model and share lessons learned to leverage action beyond state

borders

Climate-Smart Principles for Policy Makers and Planners We also recommend the SCP incorporate the set of Climate Smart Principles for Planners and Policy Makers presented below and apply them generally and in the sector-specific sections. Like the core goals, adoption of these principles will help the SCP prepare California to cope with the impacts of climate change effectively and do so most efficiently by promoting coordination amongst the sectors. Climate-Smart strategies and actions specifically address impacts of climate change in concert with other threats and promote nature-based solutions to:

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• Reduce risk to human and natural communities, and enhance ability to adapt; • Reduce greenhouse gas (GHG) emissions and enhance ecosystem services; • Sustain vibrant, diverse communities and ecosystems over time

2. Climate-Smart Planning Principles:

1. PLAN AHEAD TO REDUCE RISK FROM EXTREME EVENTS – Decision makers should avoid approving new projects or development in areas that would be at increased risk from climate change impacts, especially from extreme events like flood, wildfire, and sea level rise. Prevention is the easiest and cheapest strategy to safeguard Californians from the risks of extreme events exacerbated by climate change. The goal is straightforward: keep people and wildlife out of harm’s way. Be smart – don’t build in places likely to be at risk from future climate impacts This principle should also be recommended to local government because local land use decisions are key in determining the patterns of growth on the landscape and can play a crucial role in reducing risk from climate change to people, private property and natural resources. The plan and subsequent decisions should rely on comparative analyses of various scenarios to reduce unavoidable impacts focusing on Climate-Smart actions that reduce risk, are cost effective and maximize benefits.

2. FOCUS ON FUTURE CONDITIONS, not the past. Potential climate changes and their impacts should be considered in planning and projects over a meaningful time horizon, at least up to 2050. The scale of the potential impacts and the level of uncertainty today necessitate consideration over several decades. Longer-term planning can help agencies avoid mal-adaptation - actions that might work today but in the long run, inhibit or prevent future climate adaptation actions that are identified as the climate changes. The plan and subsequent decisions should use a range of plausible future scenarios, including extreme ones, to address uncertainty in both near- and long-term time frames.

3. PRIORITIZE NATURAL INFRASTRUCTURE over engineered actions where

feasible. Agencies should establish a preference for green or nature-based responses to the maximum extent feasible including restoration, conservation and projects on agricultural land, forests, wetlands, and grasslands. This policy is a good mechanism to catalyze cross-sector, cost-effective action. Green responses can provide many benefits in addition to reducing risk to people and resources from climate driven extreme events. For example, green responses like forest conservation can provide benefits to the atmosphere and help regulate the climate by reducing or avoiding emissions of greenhouse gas (GHG) and increasing carbon sequestration over time as the trees continue to grow while also protecting drinking water supply and quality. Green responses can also provide economic, recreational, habitat, and cultural benefits. Often they can be cheaper and quicker to implement then engineered, or grey, responses. Green responses can also be used as a first step, delaying the time and the extent of an eventual grey response. Priority should be given to these multi-benefit actions.

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4. COLLABORATE & COMMUNICATE ACROSS SECTORS – identify activities that meet goals of multiple sectors like water and energy or forests and biodiversity; establish and expand non-traditional alliances to accelerate effective problem solving (e.g., between/among public & private resource managers, scientists, decision-makers); share knowledge, communicate openly, convey hope; engage local communities, e.g., youth, to instill Climate-Smart planning ethic for long term success.

5. DESIGN AND GIVE PRIORITY TO ACTIONS THAT PRODUCE MULTIPLE BENEFITS Adopt landscape or watershed scale analyses; focus on natural system function and services in addition to risk reduction including water and food security, habitat for fish and wildlife, recreation, jobs, and quality of life amenities.

6. QUANTIFY THE GREENHOUSE GAS EMISSIONS REDUCED AND AVOIDED – Evaluate changes in carbon stocks and give preference to actions that also help address the source of climate change – GHG emissions. This information will also be important in securing more funding by fully informing the climate benefits of the various activities. The ultimate objective is for these actions to have an overall net environmental benefit.

7. EMPLOY ADAPTIVE AND FLEXIBLE APPROACHES for most timely, effective responses to continual change in climate, ecology and economics; include adaptive management framework with regular monitoring and reassessments to actively apply learning from what works and what doesn’t.

3. General recommendations to include in the SCP:

The SCP should recommend that all state capital outlay projects of $500,000

or more include a climate impact and risk management analysis up to 2050. This action will help the state make fiscally sound and prudent investments in its efforts to reduce the risk of extreme events.

The SCP should recommend an update to CEQA guidelines such that all Environmental Impact Statements and Mitigated Negative Declarations effectively incorporate considerations of climate change adaptation with support from the state’s climate mapping tools such as Cal-Adapt. This will enable agencies to robustly analyze proposed actions, project alternatives, and potential mitigation actions as well as their long-term feasibility as they relate to climate change.

In designing and implementing responses to climate change, planners and

decision-makers should quantify the economic benefits from the activity and the full suite of nature’s services to the greatest extent possible. This

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information will be important in allocating scarce resources cost effectively, in building support for climate action generally, and potentially, in securing funding for climate change response actions.

The SCP should include mechanisms that promote transparency in state decision making and create opportunities for meaningful public input.

To the fullest extent possible, the state should include mechanisms in the SCP to integrate it with the many other state, regional, and national climate response planning processes currently underway such as the National Fish, Wildlife and Plants Climate Adaptation Strategy. Applying the goals and Climate-Smart Principles described above will result in coordinated, cost effective, efficient planning that will help Safeguard California from the escalating impacts of climate change.

The SCP should evaluate the short- and long-term strategies established in the 2009 State Climate Change Adaptation Strategy and 2010 update as well as provide a comprehensive report of deliverables that resulted from these identified strategies. This will help stakeholders assess whether or not strategies have been successfully implemented and where there is room for improvement.

Planners should establish a process for future monitoring and evaluation of the goals and strategies outlined in the SCP and all updates thereafter. This will provide stakeholders with a method to identify successful strategies and areas that need improvement.

Planners should select actions based on risks and benefits, prioritizing “no risk” actions, which have a high probability of producing beneficial climate adaptation outcomes and little or no-risk of failure to implement successfully.

Planners should guide planning, policy, and decision-making with evidence-based research and data.

Planners should implement equitable adaptation measures, considering the vulnerability of communities or ecosystems to climate change impacts as well as the effects of adaptation activities on those communities.

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