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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.  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.  

Please 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 that result in the
conversion of naturally managed (uneven aged forests) into clearcut
plantations (even aged forests).

Thank you.