Comment Log Display

April 8, 2016

Comments of the Nature Conservancy on ARB sector-based credit
workshop March 22, 2016

Thank you for  the  opportunity to  submit comments on your 
workshop of March 22, 2016 focused  on  adding international
sector-based  credits to  the AB 32  Cap and  Trade  program from 
tropical  forest  protection.   The Nature Conservancy has
extensive research and implementation experience in this issue and
participated in this and  many other workshops  on  this topic 
previously.  In addition, Michelle  Passero, Senior Climate Policy
Analyst  at the Nature Conservancy  was  a member of  the  REDD
Offset Working Group (ROW) and participated  in the development  of
 its recommendations.    Following are some comments to the issues
and questions you discussed at the  workshop. 

•	The Nature  Conservancy supports the process ARB is  conducting 
to develop  and eventually adopt regulations to  amend  the AB  32 
Cap  and  Trade  program  to include international sector-based
credits from avoided loss of tropical  forests.   We urge ARB to
continue this work expeditiously and complete the regulatory
process so that credits can be approved  and accepted in the third
compliance period.  We appreciate  the detailed white  paper and 
schedule  you released  last  October.  This  action  has allowed
time for  stakeholders to  understand the issues involved in
developing a  draft regulation and to participate effectively in
the several workshops you have been conducting this spring.  
	
•	A substantial body of high quality material has been developed to
inform this process that should be useful  to you: 

o	Last year the UN Framework Convention on Climate Change completed
its multi-year process of developing guidance for Reducing 
Emissions  from Deforestation  and Forest Degradation and
Enhancement  of Carbon Stocks (REDD+), addressing issues such as
monitoring, MRV, baselines, and social and environmental
safeguards. 
o	Additionally, the ARB staff white  paper from the October
workshop  and the  paper for  this March, 2016 workshop combined
with the recommendations  from the ROW provide information  to 
address  questions  raised at the  workshop.  The Nature
Conservancy supports the REDD Offset Working  group (ROW)
recommendations and suggests you refer  to them in designing the
proposed amendment.  
o	Another resource that should be useful to you is the Carbon  Fund
 Methodological Framework published by the World Bank’s Forest
Carbon Partnership Facility
o	 “Protecting the Climate Forests,” a  report produced by the
Commission on Climate and Tropical Forests is another applicable
document that may be  useful. 

•	As a general principle,  we  recommend  that you provide a
guidance framework that still provides  flexibility in the rule for
 the host  jurisdiction to craft a  program  that fits  their
particular  circumstances.  For example, the host  jurisdiction  is
best positioned to understand  when  a change  to its reference
level is  warranted, suffice that it still meets environmental
integrity guidelines set by ARB.

•	As for scope, we agree with staff and the ROW recommendation to
begin by including reduced emissions from deforestation and forest
degradation but recommend that ARB also allow for a jurisdiction
with proven success in this realm to add reductions from carbon
stock enhancements from reforestation, improved forest management
and other activities to  its program, as long as all significant
sources of land-use emissions are also being addressed. 

•	A baseline should be consistent with UNFCCC guidance, and derived
from the average emissions  level from  a recent ten year  period
consistent  with the ROW recommendations.

•	We  support the ARB staff  recommendation” to develop a set of
quality standards and evaluate the design  of a jurisdiction’s  own
MRV program against  those standards.  The MRV  program  should be 
robust, transparent  and consistent with UNFCCC guidance and the
ROW  recommendations.  As recommended by the  FCPF, the monitoring 
program should be able  to  detect reversals.  

Thank you for the opportunity to  comment on this  process and  for
your good work developing the amendment to  the  Cap and Trade 
program to include sector-based  credits from tropical  forests. 
We will continue to participate in the process.  


(these comments are  also attached to ensure that the  links
connect)