Introduction
The California Natural Resources Agency adopted amendments to Appendix G of the CEQA Guidelines on December 30, 2009. The amendments were effective as of March 18, 2010. The title of this section was changed from “Agriculture Resources” to “Agriculture and Forestry Resources” and two (2) questions pertaining to forest and timberland (Questions c and d) were added. In addition, guidance on where information could be found with respect to forest and timberland resources was added to the “Guide to the CEQA Initial Study Checklist 2010.”
The reasons for revising this section of Appendix G are described below.
According to the California Natural Resources Agency, Final Statement of Reasons for Regulatory Action, December 2009, “The amendments would add several questions addressing forest resources in the section on Agricultural Resources. Forestry questions are appropriately addressed in the Appendix G checklist for several reasons. First, forests and forest resources are directly linked to both GHG emissions and efforts to reduce those emissions. For example, conversion of forests to non-forest uses may result in direct emissions of GHG emissions. (See, e.g., California Energy Commission Baseline GHG Emissions for Forest, Range, and Agricultural Lands in California (March, 2004) at p. 19.)
“Such conversion would also remove existing carbon stock (i.e., carbon stored in vegetation), as well as a significant carbon sink (i.e., rather than emitting GHGs, forests remove GHGs from the atmosphere). (Scoping Plan, Appendix C, at p. C-168.) Thus, such conversions are an indication of potential GHG emissions. Changes in forest land or timberland zoning may also ultimately lead to conversions, which could result in GHG emissions, aesthetic impacts, impacts to biological resources and water quality impacts, among others.
“Thus, these additions are reasonably necessary to ensure that lead agencies consider the full range of potential impacts in their initial studies. In the same way that an EIR must address conversion of prime agricultural land or wetlands as part of a project (addressing the whole of the action requires analyzing land clearance in advance of project development), so should it analyze forest removal. Agriculture and Forest Resources deals with project impacts that may affect agricultural land, forest land, and timberland either directly (through removal of such lands by project development) or indirectly (by contributing to factors that result in the