First Name | Kate |
---|---|
Last Name | Horner |
Email Address | khorner@foe.org |
Affiliation | Friends of the Earth et al |
Subject | REDD |
Comment | December 12, 2010 Mary D. Nichols Chair, California Air Resources Board 1001 "I" Street P.O. Box 2815 Sacramento, CA 95812 RE: Protection of Indigenous Peoples' and Local Communities' Rights in Cap and Trade Regulation Dear Ms. Nichols, We appreciate the efforts of the California Air Resources Board (CARB) to develop a package of policies necessary to implement California Global Warming Solutions Act of 2006 (AB 32) and to address deforestation in developing countries. Policies aimed at reducing emissions from deforestation and degradation in developing countries can play a critical role in global efforts to fight climate change. However, we are writing to express our concern that international forest programs in the proposed regulation to establish a California cap on greenhouse gas emissions and market-based compliance mechanisms could affect the rights of some of the world’s most vulnerable peoples if appropriate guidelines and safeguards are not included in the regulations. The proposed regulation establishes a program to generate offset credits from reduced deforestation and degradation but does not include language to ensure the rights of indigenous peoples and local communities. California must ensure that the development and implementation of REDD crediting programs do not lead to negative social and environmental consequences. It is therefore vital to include clear guidance requiring the full protection of the rights of indigenous peoples and local communities. We strongly recommend that “Section 95994: Requirements for Sector-Based Offset Crediting Programs” of the cap and trade regulation be amended to include the following provision: “Rights of Indigenous Peoples and Local Communities. The program has requirements to ensure that the rights of indigenous peoples and local communities, including their rights to lands, territories and resources, are fully respected.” As the proposed regulation is currently written, California risks undermining high standards for REDD policy making currently underway in other fora. The World Bank, UN-REDD and the UN Framework Convention on Climate Change have all recognized the rights of indigenous peoples and local communities in REDD (Reduced Emissions from Deforestation and Degradation) policies. As an early mover in REDD policy making, California must build on these efforts rather than risk undermining them. If the rights and participation of indigenous peoples and forest dependent communities are not guaranteed in California’s regulation to establish a REDD crediting program, governments are likely to view avoiding adverse social impacts and respecting rights as merely an extra implementation cost, rather than as a contribution to and prerequisite for REDD effectiveness. Far from being a burden, however, respecting and promoting the rights and traditional knowledge of indigenous peoples and other forest-dependent local communities is an asset to any national or international effort to protect forests and biodiversity while mitigating climate change. For example, Instituto Socioambiental (ISA) has shown that Indigenous territories in the Brazilian Amazon are virtually free from deforestation. In these territories, deforestation is only 1%, compared to an average of 2% in all protected areas, 8% in state level sustainable use protected areas, and 19% outside the protected areas. Ensuring these indigenous and forest-dependent local communities’ rights to land, territories and resources are vital to the long-term efficacy of REDD efforts. Therefore, we urge the Air Resources Board to include clear guidance the requiring the full protection of the rights of indigenous peoples and local communities. We thank you very much for your consideration and look forward to working with you as the regulations for implementation of AB 32 are further developed. Sincerely, Asian Indigenous Women's Network Australian Climate Justice Program Australian Orangutan Project Center for International Environmental Law Civil Society Forum on Climate Justice, Indonesia ClientEarth Earth Day Network FERN Forum pour la Gouvernance et les Droits de l'Homme (FGDH), Congo Brazzaville Friends of the Earth Greenpeace Indonesian Center for Environmental Law International Forum on Globalization Oxfam Rainforest Foundation, US Rainforest Foundation, UK Rainforest Foundation, Norway Tebtebba - Indigenous Peoples' International Centre for Policy Research and Education |
Attachment | www.arb.ca.gov/lists/capandtrade10/1116-carb_letter_on_redd_and_rights_final.pdf |
Original File Name | CARB_Letter_on_REDD_and_Rights_FINAL.pdf |
Date and Time Comment Was Submitted | 2010-12-15 09:44:52 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.