Comment Log Display

March 16, 2018 

Re: Preliminary Discussion Draft of Potential Changes to the
Regulation for the California Cap on Greenhouse Gas Emissions and
Market-Based Compliance Mechanisms

Dear Chair Nichols, Board Members, and Staff: 

Thank you for this opportunity to comment on the preliminary
discussion draft of potential changes to the cap-and-trade
regulations. We urge that the new requirements for Direct
Environmental Benefits of offset projects to California are applied
fairly and do not change the viability of offsets that have already
been issued or of projects that were already under development when
as guidance is finalized. We suggest that the new criteria around
direct environmental benefits be applied only to offset credits
generated by new projects going forward from the new requirements
as they are adopted, not retroactively to the credits that have
already been generated, or to projects currently under development
under the existing rules. 

Family forest owners, tribal groups, community forests, and many
others around the nation have developed offset projects in good
faith-requiring years of time and significant investments-under the
existing offset protocols. The millions of acres of forest carbon
offsets in 30 states is a mark of California's leadership across
the nation in the fight against climate change. Requiring the
credits that have already been generated or projects which have
already incurred significant costs to meet the new legislative
requirement represents a "moving of the goalposts" that is unfair
to those who have already committed significant personal and
financial resources in the offset program. 

The repercussions of changing the playing field for existing offset
projects could have implications far beyond California's boarders.
As neighboring states and regional partners such as Oregon and
potentially Washington seek to develop their own cap-and-trade or
cap and invest programs, it will likely be much harder to build
support if landowners with projects already under development for
California's system are left with stranded assets and negative
perceptions of cap-and-trade. If other states don't follow
California's example in regulating emissions then the impact on our
air and waters will be much worse than with this new policy. 

We support ARB's proposal to stipulate that forest offset projects
in watersheds that flow into California meet the DEB requirement.
We would also suggest that benefits to migratory wildlife be
considered.  As other project types and locations are evaluated, we
encourage ARB to recognize that improved forest management and
other offset actions do benefit California by reducing the levels
of this global gas, even if those actions are not undertaken in
areas directly adjacent to the state. 

We appreciate your taking these comments under consideration. If
you would like to discuss them further, I can be reached at
415-561-0700 ext. 14 or lwayburn@pacificforest.org. 

Sincerely, 

Laurie Wayburn
President, Pacific Forest Trust

Original File Name: PFT Comments on Cap and Trade Reg Changes.pdf

Date and Time Comment Was Submitted: 2018-03-16 16:40:03