Comment Log Display

It is with the conservation of California’s native natural heritage
as our highest priority that I must oppose the inclusion of the
Climate Action Reserve’s forest project protocol as part of AB 32,
unless ARB makes the substantial revisions necessary to address the
threats the forest protocol poses to forest ecosystems and wildlife
habitat.

	At their August 31 board meeting, the Climate Action Reserve
adopted revisions to the forest protocol.  At that time, Climate
Action Reserve president Gary Gero announced that his discussions
with the Air Resources Board led him to expect that ARB would
consider adopting the revised protocol for use in the AB 32
cap-and-trade program, without further revising the protocol.  

	I need to make it very clear that the recent revisions adopted by
the Climate Action Reserve do not address the outstanding concerns
about the environmental impacts of the Climate Actions Reserve’s
forest protocol, and do not address the critical flaws that were
previously identified by ARB in their review of the protocol. 
Thus, ARB must substantially revise the Climate Action Reserve
forest protocol before it can be incorporated into any AB 32
compliance mechanism.

	Many individuals and organizations have been advocating for more
than a year for revisions to address the concerns raised by the
forest protocol’s inclusion of forest clearcutting as a carbon
offset project, and the related threats to forest ecosystems and
wildlife habitat.  When these concerns were raised in September
2009, the Climate Action Reserve board promised to address these
issues on an expedited basis.  That never happened.  Instead, they
undertook other revisions, in some cases exacerbating these
concerns.  Under the Climate Action Reserve’s forest protocol: 

• Forest clearcutting and other even-age management practices that
degrade forest ecosystems and wildlife habitat can qualify as
carbon offset projects;
• Forest offset projects may include timber operations that convert
native forest to even-age plantations; 
• Forest offset projects may clearcut an entire watershed on a
50-year rotation, with 40-acre clearcuts implemented at 5-year
intervals;
• Forest offset projects may claim carbon credits for the growth of
trees regenerating after forest clearcutting that occurred at least
ten years prior;
• Many forest projects do not have to account for losses from the
understory, litter and soil, and dead wood carbon pools; 
• Many forest projects do not have to account for losses of lying
dead wood, which can be both a significant carbon pool and a
critical component of wildlife habitat; 
• Forest offset projects are not prohibited from shifting timber
harvesting to elsewhere in their timber operations, and are not
even required to report such “leakage.”
	Unfortunately, the recent revisions fail to address these
concerns, and the Climate Action Reserve announced that they do not
expect to turn to these issues until next year at the earliest,
after the Air Resources Board considers the current version for use
under AB 32.  This is particularly frustrating since the Reserve,
at the request of representatives of the timber industry, expedited
the development and adoption of revisions that will allow timber
operators to claim credit for forest growth that is already planned
to occur under business-as-usual operations. 

	The forest protocol in its current form is inadequate for use by
ARB, as the inclusion of forest clearcutting directly contradicts
AB 32’s requirement to maximize the environmental benefits from a
carbon market program.  Forest clearcutting and the conversion of
native forests to tree plantations pose the greatest risk to the
climate, while simultaneously degrading forest ecosystems, water
quality, and wildlife habitat, and impairing the forest’s
resilience to the impacts of climate change.

	I strongly urge the Air Resources Board to make the changes
necessary to ensure that the forest protocol meets the substantive
requirements of AB 32 and does not incentivize forest clearcutting
and other timber practices that threaten forest ecosystems and
habitats.