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Comment 13 for : April 28, 2016 Cap-and-Trade Workshop on Sector-Based Offsets (sectorbased4-ws) - 1st Workshop.
First Name: Documentary
Last Name: Projects
Email Address: documentaryprojects@yahoo.com
Affiliation: millions of forest people not heard from
Subject: Existing ARB standards do not ensure social safeguards
Comment:
Require a social safeguard standard or a REDD amendment that stipulates the recognition and enforcement of forest people’s resource and land tenure, and human rights prior to California’s International Sector-based Offsets program’s use of REDD offsets (See additional recommendations are at the end of these comments) The existing standards mentioned by ARB staff, in combination or independently, do not contain criteria that are sufficient to ensure social safeguards. The current REDD agreement & its social safeguards do not require the recognition and enforcement of customary and statutory resource and land tenure, and human rights for forest peoples prior to REDD funding or payment, they should. All the social standards cited by California’s International Sector-based Offsets program are ultimately qualified by non binding terms such as respect, promote, support, address or recognize, none require resource and land tenure and human rights prior to the program’s involvement. The world’s unprotected forests and their peoples primarily exist because the deforestation of these forests were not able to produce net profits or because in rare instances the inhabitants had sufficient land tenure (LT) and human rights (HR) to protect their forests and themselves. REDD is creating economic incentives to now make these forests and their peoples more profitable to exploit, but without requiring the enforcement of the rights that will protect all forest peoples, their forests & create well regulated markets. REDD projects without requiring these rights will be more prone to carbon sequestration reversals, deforestation leakage to other Jurisdiction, social and political damage and risk, and will be less transferable. Nevertheless carbon credit entrepreneurs, Government entities and NGOs have started promoting REDD without first requiring the enforcement of these rights in the last remote forests; some of these promoters lobbied at the California’s International Sector-based Offset program workshop held on 4/28/2016 by California Air Resources Board (CARB). Environmental NGO’s, like Forest Trends, Earth Innovation Institute, Ecosystem Marketplace and Environmental Defense Fund have supported & presented inspiring communities from Acre Brazil other Jurisdictions. Several of these communities had their representatives hosted by some of these environmental organizations in order to lobby for their community’s sale of REDD Carbon Credits at the CARB 4/28/16 workshop. These forest people from Acre, represent amazingly successful & privileged communities, that will probable be able to trade their Carbon offsets even without CARB’s involvement. They are extraordinary model communities, that through the bloody struggles of people like Chico Mendes & allied Forest Peoples and the support of environmentalist & land reformers, have forged better LT and HR than the vast majority of forest people worldwide. Acre Brazil is an outlier, they are the 1%, of forest people, that have LT & HR that while still inadequate, are desperately needed by 99% of all forest people. At this workshop, REDD supporters presented a few model communities confident enough in their land ownership and human rights to participate in and support REDD activities, but they are a minuscule minority of the world’s forest people. The vast majority of forest people need those rights now and will need them even more if exposed to REDD schemes. Given the history of land tenure and conflict in most Tropical countries with large remaining forests, it is implausible and inefficient to believe that rights being “requested” at the country level, per the current REDD agreement and standards, will ensure social safeguards and prevent political risk. After remote forests & their peoples are targeted by REDD without requiring these rights, it will be a rearguard nightmare to try to stem the suffering, dislocation & acculturation. One of the most cost effective methods of ethically sequestering carbon, REDD’s main goal, is by recognizing and enforcing the land & resource tenure of forest people. A. Agrawal’s study “shows that the larger the forest area under community ownership the higher the probability for better biodiversity maintenance, community livelihoods and carbon sequestration.” “The growing evidence that communities and households with secure tenure rights protect, maintain and conserve forests is an important consideration for the world’s climate if REDD schemes go forward, and even if they do not.” according to Agrawal, A. (2008) ‘Livelihoods, carbon and diversity of community forests: trade offs and win wins?’ World Bank SOCIAL DEVELOPMENT WORKING PAPERS Paper No. 120/December 2009 stated, "…the cost range of recognizing community tenure rights (average $3.31/ha) is several times lower than the yearly costs estimates for …. an international REDD scheme ($400/ha/year to $20,000/ha/year).” "…a relatively insignificant investment in recognizing tenure rights has the potential to significantly improve the world’s carbon sequestration and management capacity…, prioritizing policies and actions aimed at recognizing forest community tenure rights can be a cost-effective step to improve the likelihood that REDD programs meet their goals.” The promotion of REDD without requiring LT & HR prior to funding or payments makes the vast majority of forest people & their forests much more endangered. This is noted by Jorge Furagaro Kuetgaje, climate coordinator for COICA, the Indigenous People of the Amazon Basin, “For us to continue to conserve the tropical forests … we need to have strong rights to those forests. Death should not be the price we pay for playing our part in preventing the emissions that fuel climate change.” Tropical forested countries also have very poor land tenure rights enforcement records for forest people. “Living on Earth” radio reported, that, “governments own about 75 percent of the world’s forests, less than ten percent legally belong to communities. In Indonesia, 65 million people live off forests, most of them have no official rights to the land they consider theirs. In the eyes of the Forest Ministries, they’re squatters occupying a national resource”. The human rights and land tenure enforcement record of tropical forested countries is alarming. Global Witness’s Nov. 30, 2015 Press release stated, “At least 640 land and environmental activists have been killed since the 2009 climate negotiations in Copenhagen - some shot by police during protests, others gunned down by hired assassins." Global Witness also stated, “Most murders occurred in Latin America and Asia with far fewer reported in Africa, however this may be (due) to a lack of information…justice is rarely given to murder victims. Killers are rarely brought to trial and often acquitted when they are. In Brazil, fewer than 10 percent of such murders go to trial, and only 1 percent see convictions.” In addition to the ethics of this endangerment, CARB’s utilization of REDD without LT & HR binding prerequisites presents grave political risks for California, forest people and REDD schemes. As the world’s 1/8th largest economy, California’s response to the REDD program is likely to set a global precedent; that is why it should not increase negative social impact and political risk, as well as global warming. California could continue trendsetting by reducing Global warming, and promoting the rule of law and biological sustainability in one stroke. It is more important to get this rule making done right than done fast, therefore we recommend: 1. CARB lawyers should review all the standards CARB has cited including those in their footnotes and the REDD agreement (including UNFCCC principles established in the Cancun Agreement) and issue a legal opinion as to whether these documents stipulate the recognition and enforcement of forest people’s customary and statutory resource and land tenure, and human rights prior to California’s International Sector-based Offsets program’s use of REDD offsets (herein LT & HR prerequisites). 2. CARB lawyers should stipulate standards that require forest people’s LT & HR prerequisites that seem to be lacking in REDD and the various social standard cited? With those rights stipulated, the 99% of Forest People not represented in their workshop, could have a better chance of achieving what Acre’s communities are striving for & have not yet achieved. 3. If such standards do not exist then CARB should develop a suite of standards that require these LT & HR prerequisites. 4. CARB should then schedule further LT & HR prerequisite safeguard workshops that are video-archived and transcribed. 5. CARB should provide longer stakeholder comment periods. 6. CARB should either require LT & HR prerequisite safeguards or a REDD amendment that stipulates these LT & HR prerequisites prior to its involvement. CARB should not increase economic interest in those forests by promoting REDD schemes without requiring LT & HR prerequisites in order to prevent subsequent social, environmental and political harm. The preceding comments and recommendations focused narrowly on the need for binding social standard prerequisites, and not on efficacy of Carbon Offsets which is also problematic. (see Methodological and Ideological Options, Comprehensive carbon stock and flow accounting: A national framework to support climate change mitigation by I. Ajani et al., Ecological Economics 89 (2013) p61–72. Untangling the confusion around land carbon science and climate change mitigation policy by Brendan Mackey et al., NATURE CLIMATE CHANGE | VOL 3 | JUNE 2013 | www.nature.com/natureclimatechange )
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Date and Time Comment Was Submitted: 2016-05-13 16:13:36
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