AB 491 positions natural and working lands as an explicit component of California’s climate strategy by directing state agencies to plan, measure, and publicly report on nature-based carbon sequestration. The bill defines key terms, creates an expert advisory committee, and directs updates to the state’s Natural and Working Lands Climate Smart Strategy so that land-based actions are linked to the state’s carbon neutrality goals.
For practitioners and regulators, the bill matters because it moves beyond aspirational language: it demands target ranges, common accounting methods, and biennial public data — including expenditures and equity-related benefits — that will shape funding priorities, project design, and how land-based credits can feed into market mechanisms.
At a Glance
What It Does
Frames restoration, conservation, and land-management actions that increase carbon storage as measurable components of California’s climate plan; requires agencies to produce target ranges, adopt standardized tracking methods, and update an existing strategic plan to reach those targets. It also mandates an expert advisory committee to advise modeling, accounting, and implementation.
Who It Affects
State agencies (Natural Resources Agency, State Air Resources Board, CalEPA, Department of Food and Agriculture), project implementers on natural and working lands (forestry, agriculture, wetlands, urban forestry), technical assistance providers, and entities participating in or relying on land-based greenhouse gas accounting for compliance or voluntary markets.
Why It Matters
By tying land-based activities to explicit targets and standardized accounting, the bill will influence which projects receive state support, how credits are treated in market mechanisms, and how adaptation and equity considerations are built into land-management funding decisions.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
AB 491 defines natural carbon sequestration, nature-based climate solutions, and references existing statutory definitions for natural and working lands, vulnerable communities, and related terms so the agencies start from a common vocabulary. The definitions are broad and list example practices — improved forest management, compost, cover crops, riparian and wetland restoration, hedgerows, planned grazing, and urban forestry — signaling that both rural and urban land actions are within scope.
The Natural Resources Agency, working with the State Air Resources Board, CalEPA, and the Department of Food and Agriculture, must set an ambitious range of targets for sequestration and nature-based solutions that align with the state's carbon neutrality goals for three milestone years. The bill requires these targets to be fed into the California Air Resources Board’s scoping plan and for the Natural and Working Lands Climate Smart Strategy to be reviewed and updated to show how the targets will be met.
The update must include concrete elements: descriptions of actions already undertaken, quantified progress on emissions and sequestration, methods used for calculations, evaluation of priority pathways, barriers encountered, and recommendations (including input from the bill’s expert advisory committee).To make progress trackable and comparable, the Air Resources Board must develop standard methods for tracking greenhouse gas emissions and removals from natural and working lands. The statute directs the board to account for carbon dioxide, methane, and nitrous oxide where feasible, and to incorporate climate impacts such as increased fire risk, warming, and reduced precipitation into estimates of future sequestration and emissions trajectories.
The bill further requires that any greenhouse gas reductions or removals used in market-based compliance mechanisms be additional to business-as-usual and that accounting ensure no double counting.Finally, AB 491 mandates public transparency: the Natural Resources Agency must publish progress data on its website by specified dates and every two years thereafter, including state expenditures used to implement these targets and a summary of benefits to low-income and vulnerable communities, disadvantaged farmers, and Native American tribes. The expert advisory committee the bill establishes is explicitly multi-disciplinary — researchers, practitioners, Indigenous and environmental justice representatives — to advise on modeling, standardized accounting, and implementation barriers.
The Five Things You Need to Know
The bill requires the Natural Resources Agency to set target ranges for natural carbon sequestration and nature-based solutions aligned to 2030, 2038, and 2045 milestone years.
The State Air Resources Board must create standardized tracking methods that, where feasible, cover CO2, CH4, and N2O and incorporate climate-driven risks like fire and drought into sequestration estimates.
AB 491 mandates that greenhouse gas reductions and removals used in any market-based compliance mechanism be additional and accounted so they cannot be double counted.
The Natural and Working Lands Climate Smart Strategy must be reviewed and updated with quantified progress, calculation methods, barrier analyses, and recommendations — including input from an expert advisory committee — by a statutory deadline.
The Natural Resources Agency must publish progress and state expenditures related to the targets on its website by the specified date and then every two years, with a required summary of benefits to low-income, disadvantaged, and tribal communities.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Definitions and scope for land-based climate actions
This subsection lays the groundwork by defining the statute's terms: it sets out what counts as natural carbon sequestration and nature-based climate solutions and imports established statutory definitions for 'natural lands' and 'working lands.' The examples listed (forestry, compost, cover crops, tidal wetland restoration, etc.) broaden eligible activities and signal that both conservation and active management count toward the bill’s goals — a practical choice that affects which programs, contracts, and projects will be eligible for support.
Target-setting, planning integration, and prioritization
These paragraphs require the Natural Resources Agency and partner agencies to determine ambitious target ranges for sequestration and nature-based solutions tied to specific milestone years and to integrate those targets into the statewide scoping plan. The provision instructs agencies to prioritize activities that rapidly and cost-effectively increase carbon stocks while also maximizing ecological health and biodiversity — an explicit policy signal that implementation must balance carbon outcomes with ecosystem integrity and resilience.
Expert advisory committee to guide modeling and accounting
The bill mandates a jointly established advisory committee composed of researchers, technical providers, practitioners, and Indigenous and environmental justice representatives. That committee’s remit is practical: review modeling and analyses, advise on standardized accounting, and recommend ways to remove implementation barriers. Because the committee crosses academic, technical, and community representation, agencies will receive both methodological critique and frontline implementation insights — which will be important when technical choices have equity implications.
Standardized methods and consideration of greenhouse gases and climate impacts
This section charges the Air Resources Board with producing methods that agencies must use to track emissions, reductions, and sequestration from natural and working lands. It explicitly calls for including CO2, methane, and nitrous oxide where feasible and requires methods to account for climate-driven factors — like increased fire risk and decreased precipitation — that affect permanence and future sequestration potential. That dual focus on multiple gases and climate impacts raises the technical bar for monitoring and modeling.
Biennial public reporting and expenditure transparency
The bill requires the Natural Resources Agency to publish, by a statutory date and every two years after, website data on progress toward the targets and on state expenditures used to pursue them. The required reporting content includes quantified progress, methods, cobenefits, and a summary of benefits to disadvantaged and tribal communities — building transparency into how public funds translate into climate and equity outcomes.
This bill is one of many.
Codify tracks hundreds of bills on Environment across all five countries.
Explore Environment in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Disadvantaged, low-income, and vulnerable communities — the bill requires reporting on benefits to these groups and centers equity in the strategy review, increasing the likelihood that funding and projects will explicitly address local resilience and community priorities.
- Conservation and restoration practitioners (NGOs, land trusts, ecological consultants) — clearer targets and standardized accounting create demand for verified, fundable projects and reduce uncertainty for program design and grant applications.
- Native American tribes and disadvantaged farmers — the statute names these groups in required reporting and evaluation, which can increase visibility for tribal-led projects and farm-scale practices that deliver sequestration and cobenefits.
- State regulators and planners (NR Agency, CARB, CalEPA, CDFA) — standardized methods and an expert advisory committee give regulators a technical framework to make cross-agency decisions and integrate land-based actions into statewide climate planning.
Who Bears the Cost
- State agencies tasked with implementation (Natural Resources Agency, CARB, CalEPA, Department of Food and Agriculture) — they inherit work: target-setting, model development, strategy updates, public reporting, and administering the advisory committee, which will require budget, staff time, and technical capacity.
- Project developers and landowners — to qualify projects under standardized accounting and additionality rules, implementers may need new monitoring systems, longer-term contracts, or changed management practices, increasing upfront transaction and compliance costs.
- Market participants and compliance programs — the bill’s additionality and anti-double-counting requirements may narrow which land-based removals are eligible for market use or require stricter verification, affecting supply and pricing for credits.
- Technical assistance providers and modeling vendors — demand will increase but so will expectations: they must deliver robust, defensible models and monitoring systems that incorporate multiple greenhouse gases and climate risk assessments.
Key Issues
The Core Tension
The central dilemma is between ambition and certainty: AB 491 pushes for ambitious, near-term sequestration targets tied to carbon neutrality goals while also demanding robust accounting, ecological safeguards, and equity outcomes — but the technical uncertainty (measurement, permanence, additionality) and capacity constraints mean pursuing all three simultaneously will require difficult trade-offs about what counts, who pays, and how risks are managed.
AB 491 raises several implementation challenges that the statute itself does not fully resolve. First, the bill demands standardized accounting that covers multiple gases and accounts for climate-driven risks, but it leaves methodological choices — baselines, permanence assumptions, leakage treatment, and timescale of benefits — to agency rulemaking and advisory input.
Those technical choices materially affect which projects count and how much carbon they are credited with, so they will drive funding flows and private investment more than the high-level targets themselves.
Second, the requirement that removals used for market-based compliance be additional and not double counted introduces enforcement complexity. Verifying additionality on working lands often requires counterfactual modeling and long-term monitoring; ensuring permanence in the face of wildfire, pests, or drought raises questions about buffers, insurance, or reversal liability.
The bill also mandates public reporting of expenditures and equity benefits but does not specify funding sources for the new agency work or for scaling implementation on the ground, creating a potential mismatch between aspiration and fiscal capacity.
Try it yourself.
Ask a question in plain English, or pick a topic below. Results in seconds.