Comment Log Display

Chairman Mary Nichols and Members of the Board 
California Air Resources Board 
1001 “I” Street 
Sacramento, CA 95812 
Re: Comments on the Proposed Regulation to Implement the California
Cap-and-Trade Program 
Dear Chairman Nichols and Members of the Board: 

Thank you for the opportunity to comment on the proposed California
cap-and-trade regulation., I commend CARB for work on this
regulation.  I offer suggestions on how CARB can improve the
aspects of the program within the proposed framework relating to
REDD(reducing emissions from deforestation and forest degradation
in developing countries; and the role of conservation, sustainable
management of forests and enhancement of forest carbon stocks in
developing countries). 

AS .” AB 32 requires that the reductions be real, permanent,
quantifiable, verifiable, and enforceable.  The REDD program must
established and incorporated an effective public participation and
participatory management process that provides for the consultation
and full involvement of forest-dependent communities in affected
areas during the planning, design, implementation, monitoring, and
evaluation of program activities. …. establishing a REDD model for
subnational programs that is of high quality and replicable.

I ask CARB to incorporate the following recommendations: 

1. That a Board approved REDD sector-based crediting programs
should require that within the Subnational REDD Program resource
rights be made statutory and binding for all indigenous people and
other forest peoples whose rights do not conflict with the rights
of adjoining indigenous peoples.

2.  The Board review a World Bank analysis of the importance of
land tenure to REDD+. 
The World Bank states about,”the role of community-owned forests in
carbon sequestration …"  That"…the larger the forest area under
community ownership the higher the probability for better
biodiversity maintenance, community livelihoods and carbon
sequestration.”
“The growing evidence that communities and households with secure
tenure rights protect, maintain and conserve forests is an
important consideration for the world’s climate if REDD schemes go
forward, and even if they do not.”  
 
….The cost range of recognizing community tenure rights (average
$3.31/ha) is several times lower than the yearly costs estimates
for …. an international REDD scheme ($400/ha/year to
$20,000/ha/year)…”  “ … a relatively insignificant  investment in
recognizing tenure rights has the potential to significantly
improve the world’s carbon sequestration and management capacity…” 
“ … prioritizing policies and actions aimed at recognizing forest
community tenure rights can be a cost-effective step to improve the
likelihood that REDD programs meet their goals.  World Bank SOCIAL
DEVELOPMENT WORKING PAPERS Paper No. 120/December 2009.

3. The Standards Committee has developed Standards for design and
implementation of REDD.  These standards could assit in the Setting
a Framework and Criteria for Subnational REDD Programs.  
SEE http://www.climate-standards.org/redd+/

Using “-a Board approved REDD sector-based crediting programs” is
laudable goal as presented in Staff Report: Initial Statement of
Reasons (ISOR) but current draft of Draft decision [-/CP.16] 
“Outcome of the work of the Ad Hoc Working Group on long-term
Cooperative Action under the Convention”  will not effectively
sequester carbon and could further impoverish forest  communities
and their forests.  Nor will REDD achieve numerous criteria set in
the ISOR

The rule of law is a prerequisite for sustainable forest
management. I learned this while filming and interviewing Aristeo
Blanco, a member of a Mexican tropical forestry community that has
managed and marketed certified eco friendly products for over 16
years.

Standing in his community’s towering bio diverse forest, Aristeo
patted a huge mahogany tree ladened with vines and bromeliads. He
explained that it takes over 85 years for it to get that big and
ready to harvest. But, if his family doesn't have the security that
their forest will remain theirs, how can they or their descendants
plan to benefit from growing trees. Instead they’ll fell and burn
them so they can plant crops, which they are more likely to
harvest. Even with their land title, if they do not have the right
to negotiate for their sustainable lumber's fair price, then they
can not afford the cost to manage its growth and regeneration for
an 85 years life cycle. But because they have community title to
their forest, human rights and economic incentives, they are
managing and protecting it for the long term.

This is a rarity. Living on Earth reports that “governments own
about 75 percent of the world's forests, less than ten percent
legally belong to communities. In Indonesia, 65 million people live
off forests—most of them have no official rights to the land they
consider theirs. In the eyes of the Forestry Ministry, they're
squatters occupying a national resource.” Governments have not
protected these forests as effectively as people, like Aristeo, who
are on a level legal playing field. England’s Telegarph posted,
“Illegal logging in Brazil. 13 million hectares (50,000 square
miles) of forest are cut down each year - the equivalent of the
size of England - to provide timber or make way for grazing.”

 
Those who have title and benefit from their forests have a stake in
their future and are the most likely to protect them. Governments
have not protected these forests as effectively as those few forest
peoples, that have human and tenure rights, and can depend on and
defend their forest.  Rights we take for granted but now must be
extended to forest people.  One of the most cost and
environmentally effective next steps will be to stipulate that
prior to REDD+ funding human rights and resource tenure be enforced
statutory rights.