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Comment 15 for Greenhouse Gas Accounting Protocols (ghgprot) - Non-Reg.

First NameJames
Last NameMcRitchie
Email Addressjm@corpgov.net
Affiliation
SubjectGreenhouse Gas Accounting Protocols
Comment
Forest offsets should not be permitted unless they are additional
to business as usual. Please don't give credit for clearcutting and
plantation forestry. Plantation trees are net sources of emissions
for decades after clearcutting. Under the current protocols, these
stands can be cut at 100 years. At 100 years, they will just be
starting to store the carbon lost from the previous cutting.  

In order to qualify as an offset, a forest stand should be
protected by a legally binding conservation easement that will
ensure conservation in perpetuity. Voluntary compliance and self
monitoring have no place in cap and trade schemes.  

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Original File Name
Date and Time Comment Was Submitted 2010-02-23 21:12:19

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