Comment Log Display

2829 Lakewood Ranch Road
Weed, CA  96094
February 18, 2010

Clerk of the Board
Air Resources Board
1001 I Street 
Sacramento, CA  95814
(Submitted my email)


SUBJECT:  Proposed Withdrawal of Board Adoption of Approved Forest
Protocols

Dear Board Members:

	The Northern California Society of American Foresters (NorCal
SAF) includes roughly 700 foresters in northern California.  Our
primary mission is to advance the science, education, technology,
and practice of forestry.  NorCal SAF strenuously opposes
withdrawal of Air Resources Board (Board) adoption of Climate
Action Reserve (CAR) forest protocols.  Forests play an important
role in carbon sequestration.  Forest Carbon Project Protocol
Version 3.0 is essential to allow forest owners to participate in
carbon markets and to contribute in a verifiable way to meeting
California’s ambitious goals for greenhouse gas reductions.  The
Board adopted forest and urban forest project protocols less than
five months ago.  NorCal SAF is unaware of any new information that
has come to light in the interim that could possibly justify this
abrupt and disruptive reversal of state policy.  Withdrawing
adoption would drastically undermine all progress to date to
encourage forest owners to participate in carbon markets and would
eliminate a key incentive for them to remove or reduce atmospheric
carbon.

We agree that the forest protocols and the process for protocol
development can and should be improved as California moves from
voluntary- to compliance-based approaches to greenhouse gas
reduction.  However, the way to do that is by adaptive management,
i.e., by having forest owners, carbon project developers,
third-party offset verifiers, and forest scientists work with the
protocols to learn their strengths and weaknesses and the best ways
to respond thereto.  Rather than withdrawing adoption of the
protocols at this early, highly vulnerable stage, the Board should
be signaling its sustained support for legitimate forest carbon
projects and verifiable carbon offsets.  Several Board members have
expressed potentially legitimate concerns about some forest
practices such as clearcutting.  But please consider that, for
achieving the climate goals of AB32, the Board should focus on
whether forest practices will in fact result in net carbon
sequestration; the non-climate environmental impacts that may or
may not result from such forest practices are the purview of other
regulatory agencies, including CalFire, the Board of Forestry, the
Department of Fish and Game, and the regional water boards.

Withdrawing adoption now would likely upset stakeholder confidence
in CAR so thoroughly as to preclude its survival.  It would invite
lawsuits that portend large liabilities for state taxpayers from
forest owners who have invested in CAR forest carbon projects
mistakenly presuming that Board adoption in fact meant adoption. 
Responding to the threat of litigation by making the proposed
about-face in state policy would send the worst possible signal to
AB32’s future regulated community about the ability of the Board to
regulate in good faith.

Thank you for your consideration.

					Sincerely,

					 
Nicholas Dennis, Ph.D., Chairman
					Northern California Society of American Foresters