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June 30, 2014

California Air Resources Board
1001 I Street
Sacramento, CA 95812-2828

Re: June 20 ARB workshop on revision of protocols, including forest
projects protocol

I am writing on behalf of the Alaska Chapter of The Nature
Conservancy to express our strong support for an amendment to the
Compliance Offset Protocol U.S. Forest Projects to remove the
Alaska exclusion so that Alaskan corporations and other eligible
landowners may participate in the carbon market by developing
compliance forest offset projects.
Alaska’s coastal forests support among the highest standing carbon
biomass of any terrestrial ecosystem.  Removing the Alaska
exclusion will give landowners an alternative to timber harvest and
will reward sustainable forest management and protect important old
growth forests.  Allowing Alaska forest projects into California’s
carbon market will contribute to the success of the offset program.
 Alaska forest carbon offset projects could generate millions of
compliance offsets, while achieving social, environmental, and
economic benefit to Alaska Native and resident populations. 
The two largest forests in the National Forest system are located
in Alaska.  The Tongass National Forest in Southeast Alaska
encompasses nearly 17 million acres and the Chugach National Forest
in South-central Alaska more than 5 million acres.  Adjacent to, or
within the boundaries of these two large national forests, there
exists nearly 1.5 million acres of private lands. According to the
USDA’s Forestry Sciences Lab, the baseline inventory for these
southern Alaska forests average between 22 to 30 tons of carbon
captured per acre.  
When the ARB originally adopted the forest protocol, forest
projects in Alaska were made ineligible “due to lack of
region-specific data”. Subsequently, region-specific data for the
South-central and Southeast portions of Alaska was formally
transmitted to the ARB in 2012; however, the exclusion of forest
projects in Alaska has not yet been corrected.
In summary, the Alaska Chapter of The Nature Conservancy strongly
supports removal of the Alaska exemption.  This action, if taken,
will enhance long-term carbon storage while protecting some of the
world’s finest forest ecosystems.

Sincerely,
 
Randall H. Hagenstein
Alaska State Director