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Offsets should not be the price for reversing deforestation. 
Offsets allow increases in ghg emissions for offset purchasers and
co-pollutants not aleady adequately regulated.  Refinery emissions
in particular impact nearby communities of color in California most
vulnerable to impacts of climate change and co-pollutants.
The Tropical Forest Standard does not prevent leakage. 
Enforceability is difficult when the national government such as
Brazil is facilitating forest fires and other methods of
deforestation.  Difficult to assure rate will continue to fall.
Giving credit to one province for reducing the rate of
deforestation when the rest of the nation is increasing
deforestation accomplishes little of value.  Corruption remains a
serious concern in Brazil and will affect enforceability and
determination of baselines used for calculations.  The impact of
planting non-native tree plantations could be destructive of
indigenous populations.  Stick to making existing offsets providing
benefit to California real and enforceable.