First Name | Laurie & Allan |
---|---|
Last Name | Williams/Zabel |
Email Address | williams.zabel@gmail.com |
Affiliation | Citizens Climate Lobby & as Individuals |
Subject | Supplemental Comment Regarding US Forest Protocol |
Comment | US Forest Protocol B Supplemental Comment to Submit Article AB 32 Offsets Challenge B Public Comments on October 19, 2011 Laurie Williams and Allan Zabel, as individuals and as volunteers for Citizens Climate Lobby Summary of Evidence that Proposed Compliance Greenhouse Gas Offset Protocol for U.S. Forest Projects does not meet the AB 32 Integrity Criteria Evidence of Failure to Meet Integrity Criteria In this Supplemental Comment, we submit an article published by the Harvard Kennedy School of Government that provides additional evidence that the project-by-project approach in the U.S. Forest Projects Protocol will include non-additional projects that fail to meet the AB 32 Integrity Criteria (cited in our prior comments). Attachment: International Forest Carbon Sequestration in a Post Kyoto Agreement, by Plantinga and Richards, Harvard, Kennedy School of Government, October 2008. http://belfercenter.ksg.harvard.edu/files/PlantingaWeb3.pdf (“We conclude that project-by-project accounting, as under the Clean Development Mechanism of the Kyoto Protocol, is fundamentally flawed due to problems with additionality, leakage, and permanence.” At p.5) |
Attachment | www.arb.ca.gov/lists/capandtrade11/105-supplemental_us_forest_comment.zip |
Original File Name | Supplemental US Forest Comment.zip |
Date and Time Comment Was Submitted | 2011-10-19 11:05:26 |
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