First Name | Bruce |
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Last Name | Castle |
Email Address | blcastle@comcast.net |
Affiliation | |
Subject | Forest Project Protocol - Clearcutting |
Comment | I looked at the Subject Protocol, Version 3.0, dated Sept. 1, 2009. When I reviewed the list of people and organizations in the Work Group, I was incredulous that some of them could support such a flawed Protocol when it comes to supporting the clearcutting language that appears in Section 3.9.2 of the Protocol. (Of course, I expected this from the timber industry representatives in the Work Group.) Section 3.9.2 Natural Forest Management, states, "Harvesting using even-age management must be conducted in stands no greater than 40 acres." I find this language to be most offensive. Meanwhile, the California Forest Practice Rules limit the acreage for evenaged management, in most cases, to 20 acres. Even this is way too much. We have seen clear visual evidence of abuse in the forests in California and elsewhere. Google Earth views and over-flights of the Sierra provide this evidence. One example is Sierra Pacific Industries' (SPI) timber management practices. SPI owns about 1.7 million acres in California. Their Option A Demonstration of Maximum Sustainable Production is a 100-year business plan that will convert 2/3 of their forestland, or 1.1 million acres, to tree plantations. The great majority of this is produced by clearcutting and near-clearcutting. This is a visual blight, it stresses the biological resources on the land, and it contributes to adverse climate change, according to mounting scientific evidence. To protect the public interest, this deforestation needs to be stopped. It will require State legislation to end clearcutting and near-clearcutting (visual retention grouped and dispersed, in SPI's language). The CARB can do its part. My recommendation to the authors of the Forest Project Protocol is to eliminate clearcutting altogether from this document (with minor exceptions, such as the use of clearcutting to stop the spread of bug infestations). Furthermore, it would be a positive step for this body to publicly take a position against clearcutting. This timber harvest method and its near-clearcutting relatives serve no useful purpose. It is harmful to the environment in many ways. Leaving this language in the Protocol will show that the CARB is putting the interests of the powerful timber industry before the public trust interests. This is clearly the wrong priority . . . you need to do the right thing. |
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Date and Time Comment Was Submitted | 2009-09-22 21:22:19 |
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