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Dear ARB,

I write in strong support of accelerating sector-based credits for
tropical forest protection within the California cap-and-trade
program in time for use in the third compliance period.

California now faces the urgent, important, and globally
significant challenge of reducing its greenhouse gas emissions by
40% below 1990 levels by 2030, as recently signed into law by
Governor Brown. To achieve this worthy goal effectively,
efficiently, and equitably, ARB will need to employ many measures,
including strengthening cap-and-trade by incorporating sector-based
credits for tropical forest protection. As detailed in previous
public comments (e.g. “Eight reasons for California to lead on
climate and tropical forests,” October 2015) during ARB’s thorough
and open public consultation process, inclusion of sectoral offset
credits for tropical forest protection can:
•	Fight climate change abroad as well as at home
•	Contain costs for California companies and their customers
•	Make California the standard-setter for the world
•	Provide side benefits for sustainable development goals and
biodiversity conservation
•	Adapt a model that has already been tested using public funds
•	Support indigenous peoples’ rights and aspirations
•	Demonstrate that technical issues are surmountable
•	Jumpstart actions in other states and provinces that could
finance tropical forest protection

For all these reasons, ARB should accelerate the inclusion of
sector-based credits for tropical forest protection within the
California cap-and-trade program in time for use in the third
compliance period.

Thank you,

Jonah Busch, Ph.D.
Center for Global Development
2055 L St, Fifth Floor
Washington, DC 20009

References:
“Eight Reasons for California to Lead on Climate and Tropical
Forests.” Jonah Busch. Center for Global Development Blog. October
27th, 2015.
http://www.cgdev.org/blog/eight-reasons-california-lead-climate-and-tropical-forests