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These comments are a response to the Appendix on Forests. 

The discussion of forestry in these appendices fails to mention
key debates that currently rage between the timber industry and
the majority of forestry scientists. The practice of clearcutting
has expanded exponentially in the last decade. It’s very
surprising that there is no mention of this practice in the
forestry section. To assume that it makes no difference what type
of harvesting methods are used, as this section seems to do, flies
in the face of current research by forestry scientists. I have
outlined below some of the major points made by forestry science
on this issue, and included footnotes to some major studies. 

It is obvious that healthy forests can serve as a source of carbon
sequestration. But how those forests are managed has a huge impact
on whether they sequester carbon, and if so, in what quantity, or
whether in fact carbon emissions caused by certain forest
management processes outweigh carbon absorption. The timber
industry currently argues that their standard procedures of
clearcutting, which involve cutting down older forests and
replacing them with plantations of young trees, will help combat
global warming. They argue that since young trees absorb more
carbon than older ones, the net result will be a reduction in
greenhouse gases. 

This argument is based on a misunderstanding of what happens to
mature forests if they are clearcut. Mature forests continue to
store carbon in ever greater quantities for many decades as they
age, and cutting them down releases much of that carbon into the
atmosphere, thus contributing to global warming. Young trees do
absorb carbon quickly, and when a forest is logged, some of its
carbon may be stored for years or decades in wood products. But
when forests are clearcut, large quantities of CO2 are also
released to the atmosphere - immediately through the disturbance
of forest soils, and over time through the decomposition of
leaves, branches, and other detritus of timber production. One
study found that even when storage of carbon in timber products is
considered, the conversion of 5 million hectares of mature forest
to plantations in the Pacific Northwest over the last 100 years
resulted in a net increase of over 1.5 billion tons of carbon to
the atmosphere. (Harmon, M.E., W.K. Ferrell and J.K. Franklin,
1990. “Effects on carbon storage of conversion of old-growth
forests to young forests.” Science  (9 February 1990), 247, 699.)
Clear-cutting followed by replanting thus clearly contributes to
global warming. 

Forests and agricultural lands in the United States have been
slowly diminishing in their role of sequestering carbon since
1960. (Executive Summary, “Global Warming in Depth,” The PEW
Center on Global Climate Change,” cited on the web at
http://www.pewclimate.org/global-warming-indepth/all_reports/carbon_sequestration/exe.)
The major causes of this shift are the increasing practice of
clearcutting coupled with clearing forests for development. From
1990 to 2001, as forests on private lands have been increasingly
clearcut, managed unsustainably, or cleared for development,
carbon sequestration decreased by approximately 20 percent.
(“Forest Carbon Sequestration: How It Works,” Catalyst: The
Magazine of the Union of Concerned Scientists 3:2 (Fall 2004),
cited on the web at
http://www.ucusa.org/publications/catlyst/fa04-catalyst-forest-carbon-sequestration.html)
According to Olga Krankina, Professor of Forestry at Oregon State
University, it takes approximately 100 years of growth for a new
forest to regain the amount of carbon storage that older forests
maintain.  National Forests  currently store three times as much
carbon as those on private land, because they are managed
differently and clearcutting is no longer permitted on National
Forest land. (Olga Krankina, “Forest Management and Mitigation of
Climate Change,” lecture at “Clearcutting the Climate Conference,”
Eugene Oregon, January 256, 2008). If this pattern of increased
clearcutting continues, forests will shift from net sources of
carbon sequestration to net sources of carbon emissions. 

To conclude, the CARB needs to do a thorough analysis of the issue
of the role of forestry in carbon sequestration. It looks like the
information contained in these appendices is drawn from the
arguments of the timber industry and the Board of Forestry. By not
including the competing narrative presented by the leading forest
scientists in this country and abroad the results are not
science-based. This smacks of the practices we have seen in the
Bush administration over the last eight years- ignoring or
misrepresenting scientific information in favor of serving the
needs of industry. California, a leader in the fight against
global warming, deserves better.