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Comment 14 for Comment on the potential for international, sector-based offset credits in the Cap-and-Trade Program (sectorbased2015-ws) - 1st Workshop.
First Name: Laurie
Last Name: Williams
Email Address: williams.zabel@gmail.com
Affiliation: Citizens Climate Lobby
Subject: Input on Process for Considering REDD offsets
Comment:
The workshop and presentations provided to date have given an inadequate opportunity for those who have grave concerns about the proposed REDD program to participate. Time should be scheduled for parties with concerns about impacts on native communities in developing countries, additionality, demand shifting that results in deforestation to other locations, low carbon pricing and perverse incentives to make presentations as well as to participate by submitting written comments. CARB staff appear to have prematurely become cheer leaders for this approach without acknowledging the many serious problems associated with the proposed approach to deforestation. Please include me on all future communications regarding this topic. Among the concerns I would like to express and have CARB consider further are: 1. Given the urgency of climate change, it appears that international efforts to increase forest cover and carbon sequestration must be in addition to reducing fossil fuel burning, not instead of reduced fossil fuel use, as proposed here. The push for full availability of offsets means that very few if any of the required reductions in GHG emissions attributable to the current AB32 cap and trade program would be actual fossil fuel emission reductions in California as opposed to offsets. 2. Reduced deforestation assumptions regarding baseline would allow profit taking in situations where deforestation continues. There is no requirement for national increases in forest cover and carbon sequestration to obtain incentive payments. 3. Additionality is unprovable because the price for offsets is not known when a project begins and may be very low in the future, as has happened in Europe's ETS. This volatility undermines any claim that the project would not have occurred but for the offset price and favors projects that represent the continuation of business as usual, which will always be the least expensive projects. 4. Beginning this program will make it more difficult for governments to appropriately regulate forest activities, as it will create a huge group of people who seek to continue being paid to continue this program run by for profit carbon traders, carbon offset developers and carbon verifiers. 5. A subnational program maximizes opportunities for demand shift to other locations with the result that a different forest is cut and there is no net benefit from the program. 6. The program would interfere with international efforts to secure a gradual and predictable increase in carbon prices worldwide, which economists agree Would be the most effective way to insure a rapid transition to cleaner energy. This program aims to keep carbon prices low, which can be done more efficiently with a floor price and ceiling price for allowances. 7. Deforestation would be most effectively addressed by incentives for national increases in total forest cover and sequestration that are well funded and not linked to lowering carbon prices. I request a response from CARB to each of these points and look forward participating future consideration of this proposal. Respectfully, Laurie Williams Volunteer Citizens Climate Lobby Williams.zabel@gmail.com Oakland,CA
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Date and Time Comment Was Submitted: 2015-11-16 11:20:56
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