| Comment | The current language in 6.2.1.3 does not result in a reasonable
test of the financial viability of baseline modeling. It should
allow comparison with harvest plans filed in the past on the same
property that the carbon project is proposed. This is the best and
most logical test of whether modeled timber harvesting is
financially viable - that is it has happened before in that very
same location.
In addition, when a comparison is made with a nearby THP, the
language in 2.a. states that slopes cannot exceed slopes in the
Project Area by MORE than 10%. However, it should say LESS because
if a THP is viable on much steeper slopes, then it is certainly
viable on gentler slopes, other things being equal.
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