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US Forest Protocol B Supplemental Comment to Submit Article

AB 32 Offsets Challenge B Public Comments on October 19, 2011

Laurie Williams and Allan Zabel, as individuals and as volunteers
for Citizens Climate Lobby

Summary of Evidence that Proposed Compliance Greenhouse Gas Offset
Protocol for U.S. Forest Projects does not meet the AB 32 Integrity
Criteria

Evidence of Failure to Meet Integrity Criteria

In this Supplemental Comment, we submit an article published by the
Harvard Kennedy School of Government that provides additional
evidence that the project-by-project approach in the U.S. Forest
Projects Protocol will include non-additional projects that fail to
meet the AB 32 Integrity Criteria (cited in our prior comments).

Attachment:

International Forest Carbon Sequestration in a Post Kyoto
Agreement, by Plantinga and Richards, Harvard, Kennedy School of
Government, October 2008. 
http://belfercenter.ksg.harvard.edu/files/PlantingaWeb3.pdf  (“We
conclude that project-by-project accounting, as under the Clean
Development Mechanism of the
Kyoto Protocol, is fundamentally flawed due to problems with
additionality, leakage, and
permanence.” At p.5)