First Name | Edward |
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Last Name | Mainland |
Email Address | emainland@comcast.net |
Affiliation | Sierra Club California |
Subject | No Clearcutting Our Way Out of Climate Change |
Comment | Don't make clearcutting of forests a part of your climate program. Don't permit clearcutting in the offset regime. This is no way to sequester carbon. Allowing clearcuts as "offsets" will discredit the integrity and credibility of the state's entire climate effort. DO add stipulations that will ensure against changing natural forests into clearcut plantations. Right now, CARB's draft cap&trade regulations risk tolerating an obvious scam: Big Polluters like cement plants, electricity generators and oil refineries will simply duck restrictions by buying clearcut offsets. This not only will promote and subsidize the worst kind of forest cutting techniques but also will pose huge questions about CARB's program in respect to additionality, leakage and verifiability. 4) Not all offsets are created equal. This is a novel program and the accounting issues are complicated. We should adopt only programs that will most reliably assure actual sequestration and avoid those that ignore carbon impacts of entire components of the activity seeking to be called an “offset” such as clearcuts. We should particularly avoid subsidizing clearcuts because they are extremely difficult to assure additionality, and they also pose big environmental risks. |
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Date and Time Comment Was Submitted | 2010-11-17 16:26:43 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.