First Name | Laurie & Allan |
---|---|
Last Name | Williams/Zabel |
Email Address | williams.zabel@gmail.com |
Affiliation | Citizens Climate Lobby & as Individuals |
Subject | Comment Regarding US Forest Protocol |
Comment | US Forest Protocol B Summary of Evidence AB 32 Offsets Challenge B Public Comments on October 19, 2011 Laurie Williams and Allan Zabel, as individuals and as volunteers for Citizens Climate Lobby Summary of Evidence that Proposed Compliance Greenhouse Gas Offset Protocol for U.S. Forest Projects does not meet the AB 32 Integrity Criteria Standard in Protocol: The proposed U.S. Forest Protocol would provide offset credits for three different types of projects: reforestation, improved forestry management practices, and avoided conversion of existing forests. Each project type fails to meet one or more of the AB 32 Integrity Criteria described below. (We incorporate by reference all of our prior comments, including our comments submitted on Dec. 13, 2010, Aug. 10, 2011, Sept. 27, 2011, Oct. 18 and 19.) AB 32 Integrity Criteria: A(d) Any regulation adopted by the state board pursuant to this part or Part 5 (commencing with Section 38570) shall ensure all of the following: (1) The greenhouse gas emission reductions achieved are real, permanent, quantifiable, verifiable, and enforceable by the state board. (2) For regulations pursuant to Part 5 (commencing with Section 38570), the reduction is in addition to any greenhouse gas emission reduction otherwise required by law or regulation, and any other greenhouse gas emission reduction that otherwise would occur. (See AB32 at Section 38562(d).) Evidence of Failure to Meet Integrity Criteria 1. Already Happening – rather than “in addition to” emission reductions “that otherwise would occur:” All three types of projects covered by the U.S. Forest Protocol are already happening, without the added incentive of greenhouse gas offsets from the AB 32 program. a. Numerous Ongoing Projects: The Climate Action Reserve (ACAR@) operates a registry that includes projects that will be eligible to apply for early-action credits for U.S. Forest Projects, including all three types of projects allowed under the U.S. Forest Protocol. See CAR Registry website at https://thereserve1.apx.com/myModule/rpt/myrpt.asp?r=111. Some of these projects began more than 5 years ago, before AB32 was enacted. As a result, it is clear that these projects were viable without the offset incentive provided by AB 32 offset credits and do not meet the AB 32 Integrity Criteria. b. Preservation Organizations: Organizations whose stated mission is the preservation of forest land have projects listed in the CAR registry. The Northeast Wilderness Trust states on its website that A[t]he mission of the Northeast Wilderness Trust is to conserve forever wild landscapes for nature and people.@ The Northeast Wilderness Trust has at least two projects in the CAR registry. These projects are designated as CAR655 and CAR681. The Nature Conservancy states on its website that A[t]he mission of The Nature Conservancy is to preserve the plants, animals and natural communities that represent the diversity of life on Earth by protecting the lands and waters they need to survive.@ The Nature Conservancy has at least five projects in the CAR registry. These projects are designated as CAR680, CAR686, CAR696, CAR697, and CAR699. While it is understandable that these organizations would like the additional income that may be provided by offset credits to do their valuable work, it is impossible to determine which or what percentage of their CAR projects exist solely because of the extra funding that may be available as a result of the availability of the CAR registry and/or the AB 32 offset credit payments. The very nature of these organizations and their claimed reason for existence indicates that these organizations would undertake projects of the type they have placed in the registry, and would almost certainly continue to do so, without any greenhouse gas (“GHG”) offset credit payments. (See CAR Registry website https://thereserve1.apx.com/myModule/rpt/myrpt.asp?r=111 and Attachment 1, American Forests’ Tree Planting program website, 2011.) 2. The Proposed Protocol’s Tests Will Include Non-Additional Projects: The proposed U.S. Forest Protocol includes three types of projects: (1) reforestation projects, including: (a) areas with less than 10 percent tree canopy cover for at least 10 years, and (b) areas with a significant disturbance that has removed at least 20% of land’s above ground live biomass in trees, (Section 2.1.1, page 9 of Protocol) (2) improved forestry management practices, and (3) avoided conversion of existing forests. The procedures provided for each of these projects in the U.S. Forest Protocol will result in issuance of offset credits for non-additional projects. 1. Reforestation Projects: As evidenced by the descriptions of projects in Attachment 1, many projects are ongoing that meet the criteria laid out in the proposed Protocol for reforestation. Projects are untaken to provide wind breaks, to reforest areas that have been impacted by fire, drought and pests. It will be impossible to determine the percentage of projects that would have occurred but for the incentive of the AB 32 offset credits. 2. Improved Forestry Management Projects: By its terms, the proposed Protocol, allows any activity that is above “common practice” in the relevant Forest Assessment Area to qualify for AB 32 offset credits. This would appear to include even projects that have been ongoing for some time. Since this will always be a range of management practices, any management practice that are “above average” will quality for offsets and this will has the potential to include a large percentage of what is already occurring in each Assessment Area. The Protocol=s reliance on the Acommon practice@ standard as the baseline for determining additionality means that forestry management practices which are merely above-average will be eligible to generate AB 32 offset credits. By definition, an average means that many already-existing management practices will be credited as though they did not occur in the course of business-as usual. 3. Avoided Conversion Projects: The project type relies on an economic analysis. It requires project developers to document that there may be a more profitable use to which a particular forest area could be put. This turning-the-knobs type exercise (to get the answer you are looking for) will be speculative and subjective and will not be objective verification or enforcement. Under these tests, it is clear that the proposed U.S. Forests Project Protocol will necessarily include non-additional projects that count activities that are ongoing and would have happened without the AB 32 offset credit incentive. However, it will be impossible to know what percentage of the projects would have happened with or without that incentive, give the nature of the tests that verifiers and the Air Resources Board would apply. As a result, the proposed Protocol fails to meet the AB 32 integrity criteria and should not be approved. 3. Leakage completely undercuts the ability of avoided conversion projects to generate additional reductions. a. World Market Negates Additionality: Wood products exist in a world market. The supply of, and demand for, wood products involves almost every habitable land area of the planet, with wood products being shipped and traded on a global basis. See, e.g., Global Trade Network website at http://www.globalwood.org. Avoided conversion of any particular tract or area of forest will in no meaningful way affect either the supply of or demand for wood products. Therefore, if any particular tract or area of forest is preserved rather than cut, and the demand for wood products remains unaffected, another tract or area of forest will be cut to supply the demand for wood products. This shifting of supply will negate any GHG emissions benefit because there will be no net gain in world-wide forest biomass and the attendant sequestration of carbon. The proposed U.S. Forest Projects Protocol completely ignores this problem. This sort of ASecondary Effect@ is supposed to be taken into account and references are made to “Section O,@ but no such section appears to be included in the Protocol. (See, e.g. Protocol at p. 27.) 4. Impacts from Climate Change – Increases in Forest Death and Wild Fires: Increased prevalence and future likelihood of both Aforest death@ and forest fires as a result of climate change creates such high risks of project failures that such projects fail the integrity criterion of Apermanence,@ notwithstanding the Forest Buffer Account created by the U.S. Forest Projects Protocol. See Attachments 2 and 3. 5. Subjectivity and Complexity of Standards will make Additionality Unenforceable: Many aspects of the U.S. Forest Protocol are highly subjective and are, therefore, both unenforceable and would allow claimed GHG reductions or sequestration which would happen anyway, without an offset incentive. The net result of the problems described above is that, if the proposed U.S. Forest Projects Protocol is approved non-additional projects will receive AB 32 offset credits. This in turn will result in California’s “capped” sectors emitting greenhouse gases above the alleged “cap” on their emissions. As noted in our earlier comments, since the least additional projects will generally be the cheapest, the flaws in the U.S. Forests Protocol will open the door to non-additional offset credits that will undermine the integrity of the AB 32 program. The Protocol should not be approved. List of Attachments 1. Tree Planting, by American Forests, www.AmericanForests.org, List of ongoing U.S. projects, in partnership with various organizations and U.S. federal agencies. https://www.etree.com/TreePlanting.aspx?cc=US&lang=en&bhjs=0&fla=0 2. The Science of the Total Environment, Climate Change and Forest Fires, March 4, 2000 http://www.usgcrp.gov/usgcrp/Library/nationalassessment/forests/forests5.pdf 3. NY Times, With Deaths of Forests a Loss of Key Climate Protectors, by Justin Giller, October 1, 2011 http://www.nytimes.com/2011/10/01/science/earth/01forest.html?pagewanted=all |
Attachment | www.arb.ca.gov/lists/capandtrade11/103-us_forest_docs_10-11.zip |
Original File Name | US Forest docs 10-11.zip |
Date and Time Comment Was Submitted | 2011-10-19 10:47:39 |
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