This submission regards the proposal to include forest in exhaustion in the CDM to be little more than an attempt to provide subsidies to industrial tree plantations in circumstances that encourage bad management practices and the establishment of plantations in inappropriate locations. Such a subsidy would insulate the wood growing and processing industries from commercial pressures to improve their efficiency, reduce wastage, increase recycling and select more suitable sites for plantation establishment. The “forests in exhaustion” proposal also risks undermining the recently established REDD+ mechanism by incentivizing the establishment of plantations under the CDM rather than the restoration of natural forest ecosystems under REDD+.
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