Comment Log Display

Dear Mr. Cliff and Ms. Sahota,

Thank you for the opportunity to comment on CARB’s consideration of
rice cultivation and coal mine methane offsets protocols. As
mentioned in your March 28 presentation, offsets credits must meet
the same accuracy requirements as emissions under the cap, which
means comparable levels of additionality, verifiability, and the
treatment of measurement uncertainty. I appreciated CARB’s
statements at the March 28 public meeting that even though CARB was
not yet able to fully answer questions about the level of
additionality, verifiability, and conservativeness of its proposed
protocols, CARB plans to perform these analyses as part of the
process of developing these protocols and before making the
decision to bring these protocols to the Board for adoption. 

Below are some of the questions asked at the March 28 meeting
related to additionality, verification, and conservativeness in
slightly elaborated form, for further analysis during the protocol
assessment process. These questions apply to both protocols. 

On additionality:
-	To what extent are the credited activities already occurring
without offsets crediting? Why are they being performed? How are
conditions changing that may cause implementation rates to increase
or decrease in the near future without carbon offsets?
-	Is the expected income from offsets credits large enough to
incentivize an increase in the credited activities several times
more than without-offsets implementation rates, taking into account
monitoring and verification costs and the costs and risks to
participating farmers/coal mine owners? 
-	In other words, what indications do you have that the protocols
will effectively change activity implementation rates and avoid
crediting more than a small proportion of credits from activities
that would happen without the offsets program? 

On verifiability: 
-	For the rice cultivation protocol, how are the changed timing of
flooding and drainage, baling of straw and fertilizer use verified?

-	For both protocols, are the values used to estimate project
emissions reductions adequately verifiable by a verifier? 

On “perverse incentives” and emissions measurement uncertainty:
-	Might a coal mine methane offsets protocol increase the
profitability of coal production and thus incentivize an increase
in coal production, counter to the goals of AB 32? 
-	Where are the largest uncertainties in measuring changes in
emissions from the credited practices?
-	How large are the uncertainties when considered together? 
-	How does the protocol address those uncertainties in a
conservative manner? 

Thank you again for the opportunity to comment and raise questions.