Forest Project Baseline Determination
Interpretation of California Forest Practice Rules in the Context of the Climate Action Reserve’s Preliminary Guidance on Forest Project Protocol, Section 6.2.1.1
Recent discussions between California landowners, environmental groups, the Climate Action Reserve, and government agencies have focused on the nature of legal requirements under California’s Forest Practice Rules and how they should be interpreted for the purposes of determining a baseline for forest projects under the Climate Action Reserve’s Forest Project Protocol (FPP). Specifically, the question is whether the California Forest Practice Rules’ requirements related to Maximum Sustained Production of High Quality Wood Products (14 CCR 913.11 (933.11, 953.11)) should be considered a “legal constraint” on the baseline for improved forest management projects, as specified in Section 6.2.1.1 of the FPP.
Preliminary Guidance
The Climate Action Reserve staff has drafted preliminary guidance that would require treating Maximum Sustained Production (MSP) plans filed with the California Department of Forestry and Fire (CalFIRE) as a “legal constraint.” Under this guidance, project proponents would have to model a baseline growth and harvest regime that reflects the same mix of silviculture and management intensity used in the MSP document.
DRAFT Preliminary Guidance on California MSP Requirements (February 24, 2010)
Alternative Proposals
The Reserve received one alternative proposal for the interpretation and application of legal requirements under California’s Forest Practice Rules. This proposal was presented and discussed at the March 18 workshop.
Pacific Forest Trust Alternative Proposal
- PFT Comments in Support of Alternative Proposal
- California Forestry Association et al. Comments in Support of PFT Proposal
Staff Response to Comments on Draft Guidance and Alternative Proposal
Reserve staff has responded to public comments received on the Reserve draft guidance and the alternative proposal. The summary document is available below.
Staff Response to Public Comments on Forest Project Baseline Guidance (June 24, 2010)
Final Proposed Revisions
Reserve staff has proposed clarifications and amendments to Section 6.2.1 and 6.2.1.1 of the Forest Project Protocol Version 3.1, taking into consideration the public comments received on the Reserve draft guidance and alternative proposal. Public comments on the final proposed amendments can be submitted through this webpage below.
Proposed Amendments Relative to Baseline Determination, FPP Version 3.1 (June 24, 2010)
Rationale for Proposed Amendments Relative to Baseline Determination, FPP Version 3.1 (June 24, 2010)
Public Comment Process
Please submit comments on the final proposed amendments no later than 5 PM PDT on July 30, 2010 in Word or PDF format via the online form below:
Public Comments on the Reserve Draft Guidance and Alternative Proposal
Previously Received Public Comments on the Interpretation of California’s Forest Practice Rules
Public Workshop
The Reserve heard from a number of stakeholders regarding the interpretation of California’s Forest Practice Rules and held a public workshop to bring stakeholders, the public, and the Reserve together to fully examine and understand this issue. The workshop took place on Thursday, March 18, 2010 at the California EPA Building in Sacramento. Workshop materials can be found below.
Webinar Participation Guidance
Slide Deck: Forest Project Protocol v3.1 Overview
Slide Deck: Guidance on Interpreting Requirements Under Section 6.2.1.1
Please contact Policy Team with questions or comments.