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I am writing with sensitivity to express some concerns about the
Updated California Tropical Forest Standard. I have commented on
this case before. I am a professor at the London School of
Economics, and have some 20 years experience in tropical
environmental policy. My concerns are that the sections addressing
leakage and safeguards are (as yet) too vague to have meaning. The
risk of these problems is that the Standard itself might lose
effectiveness, but also that there is a reputational risk that the
Standard might have negative impacts on local forest users in
tropical countries that might be highlighted by activist and human
rights organizations. 

Concerning leakage: the problem is that the text of the proposed
Standard is too vague, and should include best practices for
leakage accounting, including over the lifecycle of the proposed
production. This problem undermines the environmental objectives of
the Standard.

Concerning safeguards: the text of the proposed Standard is again
too vague, and leaves judgement about negative impact to subjective
judgment. Admittedly, the Standard is using the framework discussed
in the Cancun Agreement and REDD+SES Version 2. But these
frameworks are considered to be works in progress, and are likely
to be updated, and indeed are currently widely criticized by some
groups engaged in environment and development policy as
insufficient. I hope it is possible for the California Standard to
go one or more steps further than this current incomplete
framework, and to create a better system of ensuring that
carbon-forest schemes do not engage in negative impacts such as
displacing settlements; restricting agricultural livelihoods;
unfair and poorly communicated penalties for community
participants; and other factors detrimental to local development
such as debt.

Best wishes.