First Name | Kaarsten |
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Last Name | Turner Dalby |
Email Address | kaarsten@forestlandgroup.com |
Affiliation | The Forestland Group, LLC |
Subject | Proposed forestry protocol changes |
Comment | Dear Chairperson Nichols: The Forestland Group, LLC manages over 3.5 million acres of naturally regenerating hardwood forests in 20 US states and four countries. We are the fourth largest private landowner in the United States, and we were the first TIMO to certify our entire portfolio under the FSCTM principles and criteria. We have already registered the largest offset project listed on the ARB. We believe that our forest management objectives are compatible with the current forestry protocol and are contemplating developing additional projects. However, the proposed changes to the forestry protocol would make it impossible for us to do so. While we generally support the proposed Regulatory Review Update, we are concerned with the following provisions: 1. New Basil Area Standards and Associated Buffered Areas The imposition of this requirement will make it practically impossible to develop a forestland carbon project which is not located within California and certain other limited areas of the Pacific Northwest. 2. Modified method for establishing Minimum Baseline Levels (“MBL”) for IFM projects with Initial Carbons Stocking above Common Practice The proposed new method for determining MBL for IFM projects with initial carbon stocking above Common Practice will make many contemplated carbon projects unfeasible. Landowners will be reluctant to develop forest carbon projects on their most highly stocked acreage and will thereby forego the meaningful climate benefits which would result from preventing aggressive harvesting on these tracts. 3. The Common Practice values update for private IFM projects Proposed new Common Practice values do not accurately reflect forest stocking which results from practical “common practice” forest management because the values fail to account for the cyclical effects of the timber market on wood product demand and forest stocks. * * * In addition to the concerns outline above, as I relayed in a meeting to ARB staff last December, we remain concerned with the current definition of a “Forest Owner” and an Offset Project Operator. We strongly believe that these definitions should be modified to reflect the reality with respect to forest ownership over the long term. We typically own our forests for a period of 10 to 15 years, during which time we may develop a carbon project. At the end of this investment period, we typically sell the property, and it may often be sold in several parcels to different buyers. If the selling TIMO has placed a carbon project on the property, it is appropriate for buyers to assume their respective obligations with respect to the project. They should not be expected, however, to become jointly and severally liable for the failure of an unrelated party to comply with the Protocol in the future. Chapter 3.5.1 of the Protocol also requires that a new owner of timberlands must agree to take over the forest project responsibilities and commitments or the project will be terminated and offsets must be retired in an amount equal to or in excess of those which have been issued. This requirement restricts the ability of a timberland owner to sell land which is included in the project for at least 100 years. This has the practical effect of greatly eliminating the number of forest projects which are considered. We believe that forest owners should be allowed to sell or transfer a portion of a forest project free and clear of the forest project responsibilities and commitments provided that the OPO or APD has undertaken additional verification prior to the sale which updates the project baseline, confirms the amount of ARBOCs attributable to the portion of the project which is being sold and withdrawn, and, if the number of ARBOCs exceed a materiality threshold, then the OPO or APD would be required to retire a sufficient number of ARBOCs to account for those attributable to the conveyed property. We greatly appreciate the serious thought and effort which the ARB has devoted to the Regulatory Review Update and hope you will consider the foregoing comments to further refine the Update so that it will further incentivize the development of forest projects. Kind Regards, Kaarsten Turner Dalby Vice President The Forestland Group, LLC |
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Date and Time Comment Was Submitted | 2014-12-15 12:34:10 |
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