| Comment | The current CCAR Climate Change Forestry Protocols do not
adequately address the significant soil emissions caused by
clearcutting practices. The attached picture shows a recent
clearcut in Calaveras County, CA. It clearly shows the deep tilling
that commonly occurs following clearcutting. It is very well
documented in numerous studies that CO2 emissions from this type of
activity are significant. The picture also shows that most of the
"litter and duff" and other material has been destroyed. The area
contains little lying dead wood, and of course the ecosystem in
this clearcut has been destroyed. Please note this is only a 20
acre clearcut and in 5 years the remaining adjacent forest can also
be clearcut under the protocols. Clearcutting and inadequate
emissions accounting is not acceptable
Susan A. Robinson
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