First Name: | Mari Rose |
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Last Name: | Taruc |
Email Address: | mrtaruc@gmail.com |
Affiliation | AB32 Env Justice Advisory Committee |
Subject | Drop the Sector Based Offsets Program |
Comment |
As a 2-term member of the AB 32 Environmental Justice Advisory Committee (EJAC), with over 20 years experience organizing with environmental justice (EJ) communities, I write with grave concerns on ARB’s consideration of international forestry offsets, REDD and/or the Sector-Based Offsets (SBO) scheme and propose the program be dropped. I appreciate the improving effort by the ARB to recognize its responsibility to consult with the EJAC and integrate EJ into AB 32 implementation. The authors of AB 32 recognized that EJ communities are the most impacted by industrial and climate pollution, and thus institutionalized EJ participation in the law’s implementation. Articulated in the Principles of Environmental Justice, the EJ community’s opposition of offsets and REDD uses the long-view lens of problematic environmental policies waged under 500 years of colonization and over 100 years of industrialization. The EJAC has repeatedly rejected offsets in AB 32 implementation. In the EJAC’s first term, in the 2008 recommendations, offsets were cited as problematic along with carbon trading. In the EJAC’s 2014 recommendations, we wanted the offsets program canceled, especially REDD. And in the current EJAC term, we initially recommend ARB to halt pursuing REDD international offsets. We see the design flaw in Cap & Trade in that the ARB has not yet balanced cost containment for climate polluters, with reducing climate pollution harms in California EJ communities. An initial view of GHG emissions through 2013 shows emission increases in the state’s most disadvantaged communities. Since the top offsets users to date, like Chevron at 1.7 million metric tons CO2E, are the biggest industries to take advantage of the the loophole of offsets by maximizing climate pollution reduction outside of California. The consequence is thus concentrating climate pollution in EJ communities, and minimizing benefits to our state—both of which run counter to the goals of AB 32. The best safeguards for the SBO program is to drop the program. While ARB looks at safeguarding international, indigenous and forest-dwelling communities for the SBO program, it should guarantee safeguards for EJ communities at home first. ARB cannot run an international safeguards program without knowing how to do it in California. ARB must show EJ communities that it won’t allow climate pollution increases in those areas, and that instead the primary emissions reductions are actually there. Similar to the United Nations Declaration of Rights of Indigenous Peoples, there needs to be free, prior and informed consent of EJ communities in California for the offsets program. Right now, as it stands, I know that California’s EJ communities do not consent to the offsets, REDD or SBO program because of the harms that Cap & Trade is already causing. Drop the SBO program now. |
Attachment |
Original File Name:
Date and Time Comment Was Submitted: 2016-05-13 15:45:51 |
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