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Comment 5 for Cap-and-Trade Regulation Amendments Workshop (ct-amendments-ws) - 1st Workshop.


First Name: Brett
Last Name: Byers
Email Address: brettbyers@millionacrepledge.org
Affiliation: Million Acre Pledge

Subject: maintaining authority to add tropical forest offset credits
Comment:
I have been told that certain members of the California legislature
may be considering amendments to the California CO2 cap-and-trade
program to bar the use of some or all offsets that are outside of
California.  My understanding is that the objection to use of such
credits is that they allow additional pollution in California but
with the offset likely being far away from California.

I would urge the California legislature (and the board members and
staff of the ARB and California EP, and other California government
officials) to resist a removal of such offsets for several
reasons.

First, I note that carbon dioxide pollution knows no boundaries and
defuses through the world atmosphere and causing global warming
worldwide.  As such, the effect of CO2 emissions anywhere in the
world have the same negative impact on California.

Second, I note that fossil fuel use reduction AND tropical forest
conservation (to be encouraged by CA cap and trade tropical forest
offsets as soon as 2018) are both likely needed to avoid 2 degrees
C of warming.  Also, most of the carbon on the surface of the earth
is in tropical forest, so that offsets for this sector must be
outside of California to address carbon sequestration by nature in
a significant way.   See: R.A. Houghton, Brett Byers and Alexander
A. Nassikas, "A role for tropical forest in stabilizing atmospheric
CO2," Nature Climate Change 5, 1022-1023 (2015), doi:
10.1038/nclimate2869 (published online November 25, 2015). 
http://www.nature.com/nclimate/journal/v5/n12/full/nclimate2869.html

Third, I note that California's inclusion of tropical forest
offsets by 2018 would be key as a role model to motivate other
jurisdictions to include tropical forest offsets on their
cap-and-trade markets or in relationship to carbon tax programs (as
a potential use of tax revenue).

Fourth, I note tropical forest offsets (which may be included on
the CA cap-and-trade market as soon as 2018) and conservation has a
double impact on California.  Not only does tropical forest CO2
emissions impact California CO2 levels because of worldwide
diffusion of CO2, but loss of tropical forest (especially in the
Americas where the CA cap-and-trade program seems likely to be
focused) causes drought in California.

Please see these information sources regarding the link between
tropical deforestation and drought in California:

1.  David Medvigy et el, “Simulated Changes in Northwest U.S.
Climate in Response to Amazon Deforestation” Journal of Climate,
November 2013.  DOI: http://dx.doi.org/10.1175/JCLI-D-12-00775.1
http://journals.ametsoc.org/doi/abs/10.1175/JCLI-D-12-00775.1 
http://www.princeton.edu/main/news/archive/S38/31/66M12/index.xml?section=topstories

2.  Deborah Lawrence and Karen Vandecar, “Effects of tropical
deforestation on climate and agriculture”, Nature Climate Change 5,
27–36 (2015), December 18, 2014 (online), doi:10.1038/nclimate2430
http://www.nature.com/nclimate/journal/v5/n1/full/nclimate2430.html

3.  Mike Bettwy, Goddard Space Flight Center, NASA, “Tropical
Deforestation Affects Rainfall in the U.S. and Around the Globe”,
September 13, 2005.
http://www.nasa.gov/centers/goddard/news/topstory/2005/deforest_rainfall.html
http://pratt.duke.edu/about/news/tropical-deforestation-affects-rainfall-us-and-around-globe
 (underlying article published in the April 2005 issue of the
Journal of Hydrometeorology - Roni Avissar was the lead author of
the study: http://journals.ametsoc.org/doi/abs/10.1175/JHM406.1 )

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Date and Time Comment Was Submitted: 2016-10-27 17:10:47



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