Comment Log Display

I looked at the Subject Protocol, Version 3.0, dated Sept. 1,
2009.

When I reviewed the list of people and organizations in the Work
Group, I was incredulous that some of them could support such a
flawed Protocol when it comes to supporting the clearcutting
language that appears in Section 3.9.2 of the Protocol. (Of course,
I expected this from the timber industry representatives in the
Work Group.) 

Section 3.9.2 Natural Forest Management, states, "Harvesting using
even-age management must be conducted in stands no greater than 40
acres."  I find this language to be most offensive.  Meanwhile, the
California Forest Practice Rules limit the acreage for evenaged
management, in most cases, to 20 acres. Even this is way too much. 


We have seen clear visual evidence of abuse in the forests in
California and elsewhere. Google Earth views and over-flights of
the Sierra provide this evidence.  One example is Sierra Pacific
Industries' (SPI) timber management practices. SPI owns about 1.7
million acres in California.  Their Option A Demonstration of
Maximum Sustainable Production is a 100-year business plan that
will convert 2/3 of their forestland, or 1.1 million acres, to tree
plantations. The great majority of this is produced by clearcutting
and near-clearcutting. This is a visual blight, it stresses the
biological resources on the land, and it contributes to adverse
climate change, according to mounting scientific evidence.  

To protect the public interest, this deforestation needs to be
stopped.  It will require State legislation to end clearcutting and
near-clearcutting (visual retention grouped and dispersed, in SPI's
language). The CARB can do its part.

My recommendation to the authors of the Forest Project Protocol is
to eliminate clearcutting altogether from this document (with minor
exceptions, such as the use of clearcutting to stop the spread of
bug infestations).

Furthermore, it would be a positive step for this body to publicly
take a position against clearcutting. This timber harvest method
and its near-clearcutting relatives serve no useful purpose. It is
harmful to the environment in many ways. Leaving this language in
the Protocol will show that the CARB is putting the interests of
the powerful timber industry before the public trust interests.
This is clearly the wrong priority . . . you need to do the right
thing.