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Tradewater, LLC, strongly encourages the Air Resources Board to
maintain the current 8% offset usage limit post-2020, and to
continue to permit the reduction of greenhouse gasses through
verifiable offset projects throughout the United States.

Tradewater is an offset project development firm based in Chicago. 
We have developed a program that collects and destroys
chlorofluorocarbon refrigerants from California and across the
United States.  We have also just completed the first reporting
period for a project that is preventing methane from being released
into the atmosphere from an abandoned mine.  Our staff have engaged
in projects that have resulted in the destruction of approximately
1,000,000 tons of greenhouse gasses - all because of the California
offset program.

The inclusion of offsets in the California program is essential to
its success.  California cannot avoid the devastating impacts of
climate change if it acts alone.  Carbon is a global pollutant and
climate risk to California is not jurisdictionally constrained to
reductions within the state.  This means that California benefits
even when offset projects lead to reductions in other parts of the
United States.  And it also means that California needs the rest of
the country – and the world – to join its efforts in order to
prevent the harms of global warming.  

The offset provisions of the Cap-and-Trade program have stimulated
innovation and investment that has removed over 24 million metric
tons of CO2e in the form of emissions reductions and sequestration
in the form of compliance offset credits since 2013.  This is an
important accomplishment that will only grow as the California
program continues.  Curtailing the use of offsets will dampen the
investment in projects that are essential to addressing climate
change.