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I am very concerned that the draft regulations might permit timber
management plans that are environmentally damaging and GHG
intensive, such as clear-cuts.  We are very concerned about the
dangers of such practices for watersheds and fish populations. 

This issue has been publicly discussed for many months, which
suggests that the solution is either complicated or politically
difficult.  In such circumstances, I favor putting the burden of
negotiation on the timber companies rather than on the
environmentalists.  For now, just leave forestry out of the
regulations.  In a short period of time the industry will come up
with an acceptable solution and it can be amended into the rules.

At present California has little experience with offsets.  It is
important for the program to learn to walk before it tries running
into difficult areas.  If the proposed draft is adopted, the owners
of cement kilns, power plants and refineries will have an open
season to invest in clearcut offsets which will subsidize highly
damaging forest harvest techniques.