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I do not believe that CCAR and CARB are considering unbiased
scientific information in including clearcutting under the forestry
protocols. My discussions with several members of the CCAR working
group and with CARB staff lead me to believe that these groups and
staffs are being unduly influenced by erroneous science which is
being perpetrated by the powerful timber lobbyists.  We are all
well aware of how this happened in the Bush administration and hope
that this perversion of true science due to political pressure will
not occur in California's climate change efforts. I am attaching
the work of a noted climate and forestry expert - Dr. Mark Harmon -
into the CARB record to dispel the myths that have been "accepted"
by CCAR and CARB staff regarding forestry methods and climate
change.

The following is an exerpt from the attachment re
Carbon Sequestration by Younger versus Older Forests. 

"It is very disappointing to find that arguments are still being
made that younger forests are better for climate mitigation than
older ones.  The mistaken basis for this argument is that younger
forests store carbon at faster rates than older forests.  There is
a grain of truth to the assertion that forests at a relatively
young age do have the potential to take up more carbon than older
forests.  But it is also true that forests younger than this
optimum age also take up less carbon.  Indeed immediately after
disturbance very young forests are releasing carbon as the dead
material caused by the disturbance (including timber harvests)
decomposes. Averaged over the entire period between disturbances,
the average flow into a forest equals the amount going out as long
as the same type of disturbance is repeated. This finding has been
repeatedly demonstrated in scientific examinations of this issue.  
The key is therefore not the rate of carbon uptake or release at
any particular time, but the average amount stored over time. I am
not aware of a single scientific study in which the average carbon
store of a forest disturbed by clear cut harvesting at a long
interval is smaller than one disturbed at a shorter interval.  Not
a single study, and I just performed a literature search on this
very issue.  In addition to the interval between disturbances,
another important factor is the amount of carbon removed by each
disturbance.  Timber harvest, clear cutting in particular, removes
more carbon from the forest than any other disturbance (including
fire).  The result is that harvesting forests generally reduces
carbon stores and results in a net release of carbon to the
atmosphere".