Comment Log Display

December 1, 2010
 
The Honorable Mary Nichols, Chair
California Air Resources Board

RE: The First Carbon Offset Program Should Not Encourage Forest
Clearcutting
Dear Ms. Nichols and members of the California Air Resources Board,


We are writing to you today to urge the California Air Resources
Board (ARB) to amend the proposed cap-and-trade rule to exclude
forest clearcutting from the carbon offset program, in order to
protect forests and the wildlife that rely on them.  We implore you
not to make forest clearcutting the face of AB 32. California
cannot and should not try to clearcut our way out of climate
change.

ARB’s proposed cap-and-trade rule currently not only explicitly
invites forest clearcutting as a carbon offset project, but also
incentivizes the conversion of natural forests into tree farms.
This is no solution to climate change, and further threatens forest
ecosystems and wildlife already at risk from global warming. 

Forest clearcutting and the conversion of native forests to tree
plantations pose great 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. 

In its current form, the forest protocol lacks credibility because
it would subsidize the most intensive and environmentally risky
timber operations in order to provide carbon offsets that would
allow power plants, oil refineries, and industrial polluters to
avoid upgrading their facilities to adopt less polluting
technologies. At the same time, the forest protocol fails to
account for greenhouse gas emissions associated with logging slash
and debris, dead trees, roots and soil, all of which are much
greater for forest clearcutting than for native forest management.
This is no gold standard. 

Not all offsets are created equal. ARB should consider only
programs that can reliably assure carbon sequestration and avoid
those that introduce additional environmental risks. We can not
clearcut our way out of climate change. Rather than promoting the
conversion of native forests to a patchwork of 40 acre clearcuts,
California should use this opportunity to incentivize the best
kinds and “green” forms of forest management, which can benefit
both the climate and the forest. 

The forest protocol offers many other options that meet these
criteria: reforestation projects; preventing the conversion of
forests to development; and the conservation of forest resources.

For all these reasons, we urge the Air Resources Board to uphold
the vision and initial intentions of the forest carbon program and
AB 32, by amending the forest protocol to protect forest ecosystems
and resources.

1) First and foremost, do not include forest clearcutting as part
of the California’s cap-and-trade offset program.

2) In addition, the forest protocol should not be part of the
proposed cap-and-trade rule unless, at the minimum, the following
critical amendments are adopted:

a. A Forest Project may not include conversion of native forest
stands comprised of multiple ages or mixed native species to
even-age or monoculture management, and may not include even-age
management of any stand that had been converted to even-age or
monoculture management in the harvest cycle preceding the
registration of the Forest Project.

b. Forest carbon offset projects must account for changes in down
and dead wood and soil carbon pools. 
Forest Projects that include timber harvesting are required to
account for changes in the following forest carbon pools: lying
dead wood, and soil carbon.

Healthy forests are a critical component of California’s
environment, economy, and quality of life, providing jobs and
recreational opportunities, wildlife habitat, clean air and clean
water. Healthy and resilient forests are also an important
component of California’s effort to reduce statewide greenhouse gas
emissions, and ARB should consider only programs that can both
reliably assure the value of carbon offset projects and protect
forest from additional environmental risks. 

The failure to fully account for the carbon consequences of harvest
practices poses risks to the integrity of the entire program and
increases the potential for unintended impacts to our forests. 

We urge you to make these crucial amendments in order to ensure
that California’s cap-and-trade rule does not subsidize
environmentally damaging forest management activities or the
conversion of natural forests into tree farms. 
Thank you.


Sincerely,

Roy & Diane Bozarth

Modesto, CA