First Name | Lew |
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Last Name | Douglas |
Email Address | lpdouglas@gmail.com |
Affiliation | |
Subject | Regulations for Cap and Trade |
Comment | Including clearcutting in your program calls into question the credibility of the program (particularly for additionality, verifiability and leakage). It will allow the facilities with greatest emissions (cement kilns, power plants and refineries) to avoid reductions by purchasing highly questionable clearcut offsets, subsidizing the most aggressive and intrusive forest harvest techniques. Even aged, clearcut forests are less resilient, more prone to fire and disease, and provide less diversity of habitat for the species on which nature and Californians depend. Not all offsets are created equal. This is a novel program and the accounting issues are complicated. We should adopt only programs that will most reliably assure actual sequestration and avoid those that ignore carbon impacts of entire components of the activity seeking to be called an “offset” such as clearcuts. We should particularly avoid subsidizing clearcuts because they are extremely difficult to assure additionality, and they also pose big environmental risks. Please protect the integrity of the climate program and resiliency of California’s forests by: a) eliminating from the offset program clearcutting of our forests as a way of sequestering carbon; b) adding provisions to assure that forest projects that result in the conversion of naturally managed (uneven aged forests) into clearcut plantations (even aged forests). Thank you. |
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Original File Name | |
Date and Time Comment Was Submitted | 2010-12-05 17:28:43 |
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