Comment Log Display

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.

Original File Name: Archive.zip

Date and Time Comment Was Submitted: 2015-11-13 17:13:05