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   Including clearcutting in your program calls into question the
credibility of the program (particularly for additionality,
verifiability and leakage).  It will allow the facilities with
greatest emissions (cement kilns, power plants and refineries) to
avoid reductions by purchasing highly questionable clearcut
offsets, subsidizing the most aggressive and intrusive forest
harvest techniques.  
Protect the integrity of the climate program and resiliency of
California’s forests by eliminating from the offset program
clearcutting of our forests as a way of sequestering carbon.