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Don't make clearcutting of forests a part of your climate program. 
Don't permit clearcutting in the offset regime.  This is no way to
sequester carbon.  Allowing clearcuts as "offsets" will discredit
the integrity and credibility of the state's entire climate effort.
 DO add stipulations that will ensure against changing natural
forests into clearcut plantations.

Right now, CARB's draft cap&trade regulations risk tolerating an
obvious scam:  Big Polluters like cement plants, electricity
generators and oil refineries will simply duck restrictions by
buying clearcut offsets.  This not only will promote and subsidize
the worst kind of forest cutting techniques but also will pose huge
questions about CARB's program in respect to additionality, leakage
and verifiability. 



4)      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.