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Comment 4 for Comment on the potential for international, sector-based offset credits in the Cap-and-Trade Program (sectorbased2015-ws) - 1st Workshop.
First Name: Brett
Last Name: Byers
Email Address: brett@rainforesttrust.org
Affiliation: Rainforest Trust
Subject: Comments Regarding Tropical Forest Offset Credits
Comment:
Dear California Air Resources Board, As a board member of Rainforest Trust (https://www.rainforesttrust.org), a US charity focused on tropic forest conservation, and as a committed conservation philanthropist focused on preserving large areas of tropical forest with a primary motivation of mitigating climate change (see: http://millionacrepledge.org and http://millionacrepledge.org/byers-santos/ ), I would like to submit the following comments in relation to the October 28, 2015 California Air Resources Board meeting regarding the possibility of introducing tropical forest carbon offset credits to the California CO2 cap and trade market. I much appreciation the work of the California Air Resources Board towards including tropical forest conservation and restoration offsets, giving the tremendous importance of tropical rainforest to mitigation of human-caused climate change. Respectfully submitted, Brett Byers. TROPICAL FOREST COULD BE HALF OF THE CLIMATE CHANGE SOLUTION First, and most importantly, I would like to indicate that, as I did at the meeting, while CO2 emissions from rainforest destruction and degradation may only account for 11% to 15% of total worldwide, tropic forest conservation and restoration has the potential to provide about 50% of the net CO2 emissions reductions over the next critical decades that it will take the world to largely stop burning fossil fuels and to reach peak atmospheric CO2 concentrations, with CO2 levels in the atmosphere then dropping. There are two primary reasons that could permit tropic forest conservation to provide half of the climate change solution. First, with adequate political will and funding (which are needed for all climate change solutions), forest conservation and restoration can be implement much faster than a transition away from fossil fuel use. The New York Declaration on Forests indicates the length of time dramatically reduce and eliminate forest destruction is measured in years, while estimates (especially when political realities are considered, as well as the still rapidly increase in use of fossil fuels in the developing world) of the time to end fossil fuel use start at 35 years, with more realistic periods extending to 50 or 85 years. Second, there are hundreds of millions of acres of tropical forest that are degraded, often selectively logged, such that the large trees, which contain the majority of the above-ground-carbon, are absent. If these degraded areas are protected, they would absorb huge quantities of CO2 for 50 to 100 years until the small trees become large. No human intervention is needed, as the seed base and variety of small trees are intact within the degraded forest. An amount of as much as over 10 billion tons of CO2 could be absorbed per year by recovery of degraded forest. This amount thus could be nearly 30% of current worldwide CO2 emissions and could be larger than the current net emissions from continued tropical forest destruction and degradation, which amounts to another 11% to 14% of total CO2 emissions. As such, tropical forest conservation and restoration could provide a critical bridge to the post-fossil fuel era, and could be a major portion of any climate change solution. Finally, I note that the amount of carbon stored in tropical forests worldwide (nearly 2,000 billion tons of CO2 sequestered) is equal to over half of the carbon stored in proven fossil fuel reserves (estimated to be about 3,000 billions tons of CO2 emissions on burning of this fuel). Thus, just as we court very dangerous climate change by burning all (or even a substantial fraction of) proven fossil fuel reserves, we face the same danger by destroying all (or a substantial fraction of) remaining tropical forest. Here are citations to articles and papers (many peer-reviewed academic papers) providing support to the assertions above: 1. Regarding the 35+ years to convert off of fossil fuels: Mark Z. Jacobson and Mark A. Delucchi, Providing all global power with wind, water and solar power, Part I: Technologies, energy resources, quantities and areas of infrastructure, and materials, Energy Policy (2011) 39, 1154-1169, http://www.stanford.edu/group/efmh/jacobson/Articles/I/JDEnPolicyPt1.pdf . 2. New York Declaration on Forests: http://www.un.org/climatechange/summit/wp-content/uploads/sites/2/2014/07/New-York-Declaration-on-Forest-–-Action-Statement-and-Action-Plan.pdf . 3. Peer reviewed articles showing potential of rainforest to offset CO2 emissions, including via absorption of CO2 by recovering degraded forests (the second article also indicates that about 500 billion tons of carbon is stored in tropical forests, equal to nearly 2000 billion tons of CO2 emissions on destruction of such forests): a. Richard A. Houghton, The emissions of carbon from deforestation and degradation in the tropics: past trends and future potential, Carbon Management (2013) 4(5), 539–546, http://research.mblwhoilibrary.org/works/39404 and http://www.tandfonline.com/doi/pdf/10.4155/cmt.13.41 . b. John Grace, Edward Mitchard and Emanuel Gloor, Perturbations in the carbon budget of the tropics, Global Change Biology (2014) 20, http://onlinelibrary.wiley.com/doi/10.1111/gcb.12600/full . c. There is literature that indicates that tropical forest conservation and restoration could offset about 30% current human-caused C02 emissions (see: http://www.cgdev.org/blog/tropical-forests-offer-24%E2%80%9330-percent-potential-climate-mitigation and citations from within, including http://www.cgdev.org/sites/default/files/CGD-Climate-Forest-Paper-Series-11-Goodman-Herold-Maintaining-Tropical-Forests.pdf ). But note that because it will take decades to eliminate (or at least dramatically reduce) fossil fuel use, whereas tropical forest conservation and restoration can be put in place far more quickly, the cumulative net CO2 emissions from tropical forest conservation and restoration could be roughly equal to that from reduction in fossil fuel during the critical period from now until peak atmospheric CO2 concentration, with tropical rainforest conservation and restoration providing a crucial bridge to the post fossil fuel era. If you would like any of these articles in PDF format or if you would like further explanation, please contact me. MULTIPLE MECHANISMS TO ENSURE BENEFIT FROM TROPICAL FOREST CREDITS With regard to page 35 (item 6) of the ARB Staff White Paper on this subject found here http://www.arb.ca.gov/cc/capandtrade/sectorbasedoffsets/ARB%20Staff%20White%20Paper%20Sector-Based%20Offset%20Credits.pdf , I think that the cap should perhaps be lowered when new sources of credits (such as REDD) are added. Another option is to reduce the crediting baseline relative to the reference the level. Or, as degraded forests recover, the reference level could be altered over time to ensure greater forest conservation over time. Or these mechanisms could be applied in combination. FOCUS ON ELIMINATION OF SELECTIVE LOGGING Selective logging, while far better than clear cutting of forest, must end for tropical forest conservation and restoration to reach its full potential. As described in my first comment above, about one-half of the potential of tropic forest to mitigate climate change could stem from regrowth of degraded (often selectively logged) tropic forest. Some refer to selective logging as a sustainable use of forest. But it is essential that the ARB not permit selective logging as a sustainable use of forest, given that and end of selective logging is a huge part (again, about half) of tropical forest’s potential to mitigate climate change. Thus, on page 26 of the ARB Staff White Paper (in the second paragraph of i. Leakage), it is essential that selective logging is NOT consider sustainable forest management. Other truly sustainable use, such as harvesting brazil nuts without harming trees, would be acceptable. FOCUS ON HALTING BUILDING OF ROADS IN OR ADJACENT TO TROPIC FOREST On page 25 of the ARB Staff White Paper (in the second paragraph of ii. Additionality), I find the mention to road building as a valid reason to adjust the reference level disturbing. Road building is hugely destruction to forests (bring destructive development because of the road access), and should be strongly discouraged. OTHER COMMENTS ON ARB WHITE PAPER On pages 14 to 15 of the ARB Staff White Paper, I think that there may be a small mistake in description of the albedo effect, as the paper focuses on high reflectivity as a problem rather than a good thing. In my understanding, low reflectivity cause direct absorption of heat, whereas high reflectivity (such as from ice, snow or cloud cover) reduces this direct absorption, which direct absorption is a much bigger issue than any further reflection back to earth within the atmosphere. On page 27 of the ARB Staff White Paper (in the ii. Reversals paragraph carried over from the prior page), I worry that the reset of the baseline emissions for naturally-caused deforestation could be a problem, if a warming and drying planet (because of climate change) would result in more and larger fires in the tropical forest, and perhaps provisions should be made to avoid this.
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Date and Time Comment Was Submitted: 2015-11-13 09:32:39
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