June 1, 2007
CDM Executive Board
UNFCCC Secretariat
Dear Chair,
I am writing to you in response to the ‘call for public input on new procedures to
demonstrate the eligibility of lands for afforestation and reforestation activities’.
The comments below refer to the “Draft procedures to demonstrate the eligibility of lands
for afforestation and reforestation project activities” EB 31.
Comments:
Para 1. (a). “ Demonstrate that the land at the moment the project starts does not contain
forest by providing transparent information that:”
iii. The land is not temporarily unstocked, as a result of human intervention such as
harvesting or natural causes.
The ‘draft procedures to demonstrate eligibility of lands for AR project activities’ should
consider as exception to the rule that land areas, cultivated with fast growing species of
forests over the period following December 31, 1989, generally exotic, with short rotations
(five to seven years), but which are under current degradation conditions (after 2000), shall
also be eligible for afforestation or reforestation (evidences should be provided by project
proponents).
Best Regards,
Ricardo Vianna