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Comment 27 for Cap and Trade Protocols for Rice and Forestry (capandtradeprf14) - 15-1.

First NameSean
Last NameCarney
Email Addressscarney@finitecarbon.com
AffiliationPresident
SubjectComments on Proposed Revisions to the Compliance Offset Protocol for U.S. Forest Projects
Comment
Dear Members of the Board: 

Finite Carbon is an active participant in the California compliance
offset market and is currently developing 19 improved forest
management projects for the program. 

We have chosen to join two letters supported by 20 organizations to
request that the Air Resources Board remove from consideration
three critical items from the proposed revision to the protocol and
form a technical working group to review them further:

1.Modified Even-aged Management requirements – Chapter
3.1(a)(4)(A-E)
2.Modified Minimum Baseline Level determination process for IFM
projects with initial stocking above common practice – Chapter
5.2.1 
3.Modified Common Practice figures and the associated shift in
“high” vs “low” site class delineation - Assessment Area Data File
associated with the Regulatory Review Update of the Forest Protocol
and Appendix F(d)

However, given the current process underway, we have provided
several comments on these issues and our recommendations for
alternative language which I have attached. 

We thank you for your consideration and would be happy to answer
any questions you may have. 

Sincerely, 

Sean Carney

Attachment www.arb.ca.gov/lists/com-attach/83-capandtradeprf14-VDJdMgFuWGIDcVQx.pdf
Original File NameFinite Carbon Forest Compliance Protocol Public Comments 6-4-2015.pdf
Date and Time Comment Was Submitted 2015-06-04 16:02:43

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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