| First Name | Paul |
|---|---|
| Last Name | Harper |
| Email Address | pharper@bbwassociates.com |
| Affiliation | |
| Subject | Financial constraints in Forest Offset Protocol |
| Comment | The current language in 6.2.1.3 does not result in a reasonable test of the financial viability of baseline modeling. It should allow comparison with harvest plans filed in the past on the same property that the carbon project is proposed. This is the best and most logical test of whether modeled timber harvesting is financially viable - that is it has happened before in that very same location. In addition, when a comparison is made with a nearby THP, the language in 2.a. states that slopes cannot exceed slopes in the Project Area by MORE than 10%. However, it should say LESS because if a THP is viable on much steeper slopes, then it is certainly viable on gentler slopes, other things being equal. |
| Attachment | |
| Original File Name | |
| Date and Time Comment Was Submitted | 2014-10-17 16:59:44 |
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