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Comment 3 for : April 28, 2016 Cap-and-Trade Workshop on Sector-Based Offsets (sectorbased4-ws) - 1st Workshop.
First Name: Amy
Last Name: Vanderwarker
Email Address: amy@caleja.org
Affiliation: California EJ Alliance
Subject: Comments given at ARB workshop on April 28th regarding
Comment:
We’ve heard some compelling comments about how REDD has worked, or how people hope it will work, but for every example of positive, there is also an example of negative, as Mr Fyneface has really described. And those examples of negative experiences are extremely risky. You all have highlighted many important social safeguards, but there is a fundamental disconnect: how really can you garauntee that any of these safeguards are met? How do you enforce these? I totally understand that ARB does not want to expose the state to being party to human rights violations, but really – how can you monitor any of these things when you are dealing with projects in extremely remote and far flung places. You mention “a system for monitoring and reporting on safeguards,” but that was very cursory. That to me is the critical component of this system, and I have not really heard any details on what that system looks like and how it is enforced. I also hear a lot of effort from you all to distance yourselves from REDD projects of the past, and as I understand it, the main point there is that this is a jurisdictional approach. I just don’t see how you get away from the potential HR violations. I know you say that Cross River state is not a jurisdiction you are looking to link with, but I think Fyneface’s comments reflect the broader dangers with the program, whether its in Nigeria or elsewhere, that need to be taken seriously. We’ve also been talking a lot about Brazil today - I also just want to highlight that Brazil is in the middle of major political upheaval and we have no idea how that will impact the government’s long term capacity or commitment to implementing equitable, effective climate programs. It is exactly that kind of volatility in other countries that ARB cannot predict and thus highlights some major challenges to this program. I also want to flag that the issues environmental justice communities are struggling with here in California, are in fact social issues that also need to be addressed by ARB and I have not yet heard anything about that. So just looking at what is happening here, this is what we see: The State of the Air for 2015 just came out. The top five US cities most impacted by unhealthy ozone days are in California, as are the top seven cities burdened with unhealthy particle pollution days. And we know that many of these air quality issues are disproportionately impacting low-income communities and communities of color. Our current regulations are simply not getting the job done – that is exactly why ARB is looking at new regs for Short Lived Clmate Pollutants. As you explore a new protocol that will allow polluters to continue, it is absolutely your responsibility to think about ways to strengthen this. I think there are serious questions about the overall offset program that haven’t been addressed before we expand it. We have also been looking at the offsets program more generally. We have also found that the majority of offset users are large corporations: the top ten users are: Chevron, CalPine, Tesoro, So Cal Edison, Shell, PG&E, La Paloma, SDG&E, and NRG. These top 10 account for 55% of all offsets; over 60% of companies do not use ANY offsets. These big companies can access this complicated system and get the cheapest prices for carbon emissions, below even what C02 is being auctioned at, which is already quite low. So, it seems to be really only the major polluters using offsets, not small facilities who would be most hard hit by pricing issues. So from a cost containment perspective, this expansion seems entirely unnecessary. And, ARB seems to have already done A LOT to make it cost effective for corporations to comply with C&T regs, so additional protocols seem unnecessary. And it seems like REDD just give some of the largest corporations in the world, with multi billionaire dollar budgets, access to an even lower price to continue polluting. And according to the most recent GHG reporting data, oil & gas emissions have even risen slightly since cap & trade was started. I would add that there are even verification concerns with the CURRENT offsets program. We’ve been trying to better understand exactly what projects are being paid for by large corporations in states such as Arkansas and Michigan, and it is extremely difficult and concerning to understand what really are being approved as offset projects in the current program, much less one that is international. So my questions to you are: • What is your system for enforcing / monitoring safeguards? • given the intense scrutiny that is required to make these linkages successful, how is this a good use of your staff time when there is SO MUCH to be done here in California? • From the cost containment perspective, why is it that you think more mechanisms are necessary to provide more mechanisms for companies to pollute when prices are already extremely low • And what exactly are you doing to ensure that CA’s offset program specifically – not the other activities at ARB - is NOT exacerbating EJ issues here in California?
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Date and Time Comment Was Submitted: 2016-04-29 17:31:36
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