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Comment 26 for California Cap-and-Trade Program (capandtrade10) - 45 Day.

First NameJames
Last NameFeichtl
Email Addressjim.feichtl@freight.fedex.com
Affiliation
SubjectCap and Trade 2010
Comment
In overwhelmingly rejecting Prop 23, California voters have given a
historic mandate for immediate action to reduce global warming
pollution. However, the proposed cap and trade rules weaken the
impact of our climate bill by giving away the vast majority of
pollution allowances. Seize the mandate for bold, meaningful action
and remove the massive allowance giveaways outlined in the current
rules.  One of the worst parts of the cap and trade rules being
considered is the inclusion of clearcutting as an improved "forest
management" method under the Forest Project Protocols version 3.2
CAR essentially admits that they do not take into account, critical
elements of clearcutting methods (soil ripping, herbicide
applications, disposal/burning of dead standing and lying wood)
which would greatly affect the amount of carbon that is actually
sequestered. Clearcutting turns a forest from a carbon sink into a
carbon emitter for at least the next 20 years, precisely the time
period where we need to see true reductions in carbon emissions.
The protocols also give 100-yr credit for carbon in wood products.
Anyone who has replaced a wooden deck,fence or roof knows that
these products do no last anywhere near 100 years. They begin
decomposing and releasing CO2 as soon as they are installed. Please
protect the integrity of California’s forests (the lungs and
filters of our air and water), by: a) eliminating from the offset
program clearcutting of our forests as a way of sequestering carbon
and by 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).  

Attachment
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Date and Time Comment Was Submitted 2010-11-27 13:25:03

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