Forests Forever Action Alerts

Now is the time to fix the flawed forest protocol!

Clean-air agency weighs alternatives to cap-and-trade

A recent court-ordered one-year postponement of California's new cap-and-trade program for reducing greenhouse gas (GHG) emissions has confronted forest defenders with an opportunity and a challenge.

Between now and July 28, comments are due on an official analysis of alternatives to the state's already-adopted cap-and-trade program.

Now is the time for forest activists to step up pressure on the state to reform its deeply flawed cap-and-trade protocol for forests.

The state Air Resources Board's (ARB's) regulation, or protocol, as now drawn, irresponsibly allows forest clearcuts to qualify for clean-air credits.

Your voice on the alternatives needs to be heard!


Tell the ARB it should be doing everything possible to safeguard the state's watersheds, and the current forestry protocols under cap-and-trade defeat this goal by rewarding clearcutting.

(See sidebar at left for a summary of the ARB's forest-protocol flaws.)

Let the ARB know that while it is considering alternatives to the cap-and-trade program it should correct the major flaws in the forest protocols.

In effect, as it stands now with the current cap-and-trade forest protocol, the ARB will be rewarding timber companies for despoiling the land.

The deadline for comments on the draft alternatives document is Thu., July 28 by 5 p.m. Pacific Time.

Comments to the ARB may be made online here.

To see sample letters, click here or the image below:

Sample Letters

A draft of the cap-and-trade alternatives document can be obtained from the ARB's website here.


Credit environmental justice advocates for getting the court to postpone the cap-and-trade program.

A San Francisco judge in March ruled that the state ARB had not sufficiently considered alternatives to the carbon-trading program, as required under the California Environmental Quality Act.

The judge agreed with several neighborhood organizations and environmental-justice groups that cap-and-trade would allow industrial plants to avoid installing the strictest pollution controls.

By court order the ARB is now drafting an analysis of alternatives to cap-and-trade. The results are slated to be considered for final adoption by the ARB Aug. 24.

The current cap-and-trade plan was adopted last year by ARB as part of A.B. 32, the Global Warming Solutions Act of 2006. It originally was scheduled to be put into operation in January 2012.

The delay in implementation to January 2013, which resulted from the court’s ruling, gives forest activists more time to impress upon the ARB the need to rectify its cap-and-trade scheme's glaring forest-clearcutting loophole.

As we have said repeatedly in recent months, the ARB's cap-and-trade program perversely rewards landowners for clearcutting their forests. In essence, the ARB's forest protocol could give dollars to landowners who degrade and diminish water quality and quantity across vast regions of the state.

The facts are clear: forest clearcuts dramatically impair water quality and quantity in affected watersheds. They potentially impact the resources, amenities and pockebooks of millions of Californians.

For a plain-English exposition of the cap-and-trade forest offsets issue, see "Clearcutters hop on cap-and-trade" on the Forests Forever homepage.

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The trouble with the current forest protocol

Forests Forever recently published a detailed exposition of the forest protocols problem, which you can read unabridged here. The article’s main points again are as follows:

• The California Air Resources Board's (ARB) cap-and-trade program, aimed at reducing greenhouse gas (GHG) emissions, perversely rewards landowners for clearcutting their forests. Yet clearcutting releases massive quantities of GHGs. In essence, the ARB's forest protocol (rules and procedures that specify the forest sector’s role in cap-and-trade) would hand over millions of dollars to forestland owners to degrade and diminish water quality and quantity across vast regions of the state while releasing tons of CO2 into the atmosphere.

• A timberland owner can cherry-pick which project-area parcels on his or her holdings to register as "offsets" in the cap-and-trade program. At the same time, the same owner can shift destructive logging practices – including clearcutting – to lands outside the project-area boundaries – an unsavory practice known as "leakage."

• The ARB does little to discourage and nothing to police such leakage in the forest sector.

• If every possible "leak" in the forest sector isn't plugged at the get-go, cap-and-trade could help foster the plundering of our forests, stripping their many benefits and resources, while releasing their vast stores of carbon in the process.

• The ARB categorically treats California's forests as a net carbon sink, always sequestering more CO2 than they release. But the ARB overlooks the possibility that individual timber companies – especially those doing clearcutting – may be net emitters of CO2 from their forestlands.

It's the fact that the timber owners doing the clearcutting are poised to rake in huge sums of money in the name of controlling greenhouse gases (GHGs) even as they clearcut their forests, releasing huge quantities of GHGs

As part of A.B. 32, California’s landmark statute to limit GHG emissions, the ARB has adopted cap-and-trade forestry protocols that ignore the heavy atmospheric and terrestrial impacts of forest clearcutting, even as they encourage clearcutting to take place.

A key element in the cap-and-trade program adopted last year by the ARB is a protocol that allows timber companies to sell carbon “offsets” to other industries. The buyers use the offset credits as needed to stay within the emissions cap set for them by law.

Under the protocol, a timberland owner can cherry-pick which project-area parcels to register as offsets. At the same time, this owner can shift destructive logging practices – including clearcutting – to lands outside the project-area boundaries.

The undesirable practice of shifting clearcuts outside of project boundaries, referred to in cap-and-trade parlance as "leakage," distorts GHG accounting and defeats efforts to control emissions.

If forestry ”leaks” aren’t plugged at the start, cap-and-trade might end up doing nothing more than accelerating the draining our forests of their many rich resources – releasing their vast stores of carbon in the process, undercutting the very purpose of A.B. 32 – only to provide offsets to a market that allows polluting industries to postpone installing true pollution controls for years!

To make sense ecologically and economically, forest offset projects must be “additional,” meaning that they guarantee sequestration or retention of carbon stocks above and beyond what would otherwise have occurred on the project land.

Only sustainable forestry practices above and beyond business as usual should be credited as offsets


Forests Forever:
Their Ecology, Restoration, and Protection
John J. Berger

from Forests Forever Foundation
and the Center for American Places