Comment Log Display

Redwood Chapter
55A Ridgway Avenue, Santa Rosa, CA
P.O. Box 466, Santa Rosa CA 95402
(707) 544-7651 
Fax (707) 544-9861
http://www.redwood.sierraclub.org/

Clerk of the Board, 
Air Resources Board
1001 I Street 
Sacramento, California 95814
December 12, 2010

Re: Cap and Trade Program, Clearcuts

The Redwood Chapter of the Sierra Club, the nation’s largest and
oldest environmental organization, represents more than 9000 Club
members in northwestern California.

On December 16, 2010, the Air Resources Board (ARB) is scheduled to
consider adoption of the regulations for its Cap & Trade Program. 
One portion of the regulations would allow the largest emitters of
greenhouse gases (GHGs) to offset some of their emissions (instead
of reducing them) by buying credits for sequestration of extra
carbon in California’s forests in three ways: a) reforestation; b)
preventing conversion of forest land to other uses (golf courses,
development and shopping centers); and, c) “improved forest
management practices.”   Unfortunately there is nothing explicit in
the protocol that will prevent a clear cutter from using these
subsidies to convert our naturally managed forest into clearcut
“tree plantations". 

To allow clearcutting in your program would call into question the
credibility of the program. It would 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. California’s working timberlands are important for the
ecological services they provide. Our forests are the lungs of the
earth, and control sedimentation and temperature of the waters we
drink, and on which our salmon depend for reproduction.  Evenaged,
clearcut forests are less resilient, more prone to fire and
disease, and provide less diversity of habitat for the species on
which nature and Californians depend.

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.  Please 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.

Sincerely,
Diane Beck, Conservation Chair
Redwood Chapter, Sierra Club