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Dear Chairman Nichols:

While the ARB is considering alternatives to the cap-and-trade
program, please also correct the major flaws in your agency's
forestry protocol.

As it stands now with the current cap-and-trade forestry protocol,
California will be rewarding timber companies for despoiling the
land and emitting large volumes of CO2.

The protocol allows forest clearcuts (a.k.a even-aged management)
that can dramatically impair water quality and quantity in affected
watersheds.  The clearcuts you permit to qualify as "offsets"
potentially impact the health and well-being of millions of
Californians, as well as future generations.

Please correct the forestry protocol to allow "offset" projects to
include only uneven-age forests — which not only sequester CO2 but
preserve wildlife habitat and other values.

Sincerely,

Paul Stoft ScD