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Comment 6 for Comment on the potential for international, sector-based offset credits in the Cap-and-Trade Program (sectorbased2015-ws) - 1st Workshop.
First Name: Gary
Last Name: Hughes
Email Address: ghughes@foe.org
Affiliation: Friends of the Earth - US
Subject: Next Steps for Evaluating the Role of Sector-Based Offset Credits Under the California Cap
Comment:
On behalf of Friends of the Earth–US, this letter and accompanying Appendix is respectfully submitted as a contribution to the development of socially just and environmentally effective climate policy in California. Our organization is grateful for the opportunity to submit this letter and the accompanying materials as documentation that will especially serve to identify and expose inadequate risk analysis by state agencies regarding potential establishment for new rules in the Cap-and-Trade Program. This material, as well as that which has been previously offered over the years in regards to the potential California adoption of a “Reduced Emissions from Deforestation and Degradation (REDD)” based offsets program, will serve ultimately to inform the development of truly just and effective climate policy for the State of California. In brief, after assessment of the various types of risk associated with the potential role of International Forest Sector Based Offsets, or REDD, in the California Cap-and-Trade Program, it is clear that there exists an exceptionally high level of exposure of the program to a multitude of risk factors that will likely undermine the environmental and social effectiveness of the offsets program, and hence both the carbon market and the intended emissions reductions that are the primary objective of AB32. It is also clear that the California Air Resources Board is not obligated or mandated in any way whatsoever to expose the residents of State of California to this risk. In other words, there is no real viable public interest for which the State of California has to embark upon such a risky policy endeavor, especially when there are other more concrete and tangible means by which Californians and California industry can meet both mandated emissions reductions and stated tropical forest protection goals. It is particularly irresponsible to move forward with this policy proposal when unmanaged risk could result in severe implementation problems with, or even outright failure of, the offsets program, putting the entire Cap-and-Trade based climate policy of the State of California in jeopardy. Considering the issues of risk as well as the complexities of rapidly evolving contextual dynamics in potential partner jurisdictions we consider that it is an imperative that there be a full and transparent discussion regarding the economic, social, and political contexts within which REDD based subnational jurisdictional linkages for offsets are proposed. Attached is a zip package with Comment Letter, Appendix List, and Appendix Materials.
Attachment: www.arb.ca.gov/lists/com-attach/6-sectorbased2015-ws-BmdcKAFjWGMBbgRy.zip
Original File Name: Archive.zip
Date and Time Comment Was Submitted: 2015-11-13 17:13:05
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