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     We cannot and should not try to CLEARCUT OUR WAY OUT OF
CLIMATE CHANGE
   Including clearcutting in your program calls into question the
credibility of the program (particularly for additionality,
verifiability and leakage).  It will allow the facilities with
greatest emissions (cement kilns, power plants and refineries) to
avoid reductions by purchasing highly questionable clearcut
offsets, subsidizing the most aggressive and intrusive forest
harvest techniques. 
    California’s working timberlands are also important for the
ecological services they provide, not only for nature, habitat and
wildlife, but for people too.  Our forests are the lungs of the
earth that purify our air.  Our forests control sedimentation and
temperature of the waters we drink, and on which our salmon depend
for reproduction.  Even aged, clearcut forests are less resilient,
more prone to fire and disease, and provide less diversity of
habitat for the species on which nature and Californians depend.
   Not all offsets are created equal.  This is a novel program and
the accounting issues are complicated.  We should adopt only
programs that will most reliably assure actual sequestration and
avoid those that ignore carbon impacts of entire components of the
activity seeking to be called an “offset” such as clearcuts.  We
should particularly avoid subsidizing clearcuts because they are
extremely difficult to assure additionality, and they also pose big
environmental risks. 
     Protect the integrity of the climate program and resiliency of
California’s forests by: a) eliminating from the offset program
clearcutting of our forests as a way of sequestering carbon; b)
adding provisions to assure that forest projects DO NOT result in
the conversion of naturally managed (uneven aged forests) into
clearcut plantations (even aged forests)