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This is a well thought out report on the role and effectiveness of
forest lands in carbon sequestration.  I have not seen the earlier
protocols but it sounds like this one is a major improvement over
the ones that went before.  This Protocol has a number of
improvements in it.  But the most important ones, I think, are the
ones that allow for a greater increase in forest land with
administrative requirements that are more fare and uniform than was
the case in the earlier protocol.  This one gives much more
importance to the role of public lands and the role of larger
private timber and woodland owners.  The permanence component is of
critical importance.  This requires the onsite monitoring of the
carbon stocks, the filing of annual monitoring reports and
independent verification of the reports.  There now are Project
Implementation Agreements that obligate forest owners to give up
some of their carbon credits to make up for the loss of forest land
.  And a new buffer pool is set up where each participant in the
program contributes so many carbon credits to the pool to
compensate for unavoidable destruction of forest lands by pests or
wildfire.  This protocol also has provisions in it to maintain
forest eco-systems including trees of different ages.  The Protocol
also recognizes the importance of long term wooden products--wood
products made to last 100 years or more either in use or in
landfills.  These products also help sequester carbon.  This
Protocol will be an important part of the larger cap and trade
process now being set up.  Thank you and best wishes, Michael E.
Bailey, 25801 Marguerite Parkway, No. 103, Mission Viejo, CA 92692.