Comment Log Display

Dear Chairman Nichols:

As your agency implements the provisions of A.B. 32, the board
should be doing everything possible to safeguard the state's
watersheds.  Unfortunately, the current forestry protocols under
cap-and-trade defeat this goal by rewarding forest clearcutting.

While you are considering alternatives to the cap-and-trade
program, as required by recent litigation under CEQA, please also
correct the major flaws in the forestry protocol.

It appears that the ARB regards California's forests as a net
carbon sink, always sequestering more CO2 than they release.  But
this clearly overlooks the possibility that individual timber
companies – especially those doing clearcutting – may be net
emitters of CO2 from their forestlands.

Please hold timber companies accountable for the CO2 they release. 
You can do this by eliminating the provision in the forestry
protocol that allows even-aged harvests (i.e. clearcuts) in
projects qualifying as "offsets" under cap-and-trade.

Sincerely,

Timothy A Makovkin