Comment Log Display

Josie Hickel
Chugach Alaska Corporation 
3800 Centerpoint Drive, Suite 1200
Anchorage, AK 99503

California Air Resources Board
1001 I Street
Sacramento, CA  95812

November 4, 2016

Re:	Comments of Chugach Alaska Corporation on ARB’s October 21
Cap-and-Trade 	Regulation Workshop and the Proposal to Reduce the
Offset Credit Usage Limit

Dear Air Resources Board Staff:

Thank you for giving us the opportunity to comment on the
California Air Resources Board’s (ARB) October 21st workshop
presentation. We would like to address the portion of the workshop
regarding AB 197 and Post-2020 Cap-and-Trade Program Design, and in
particular ARB’s proposal to lower the offset credit usage limit of
8%.
Chugach Alaska Corporation (Chugach), an Alaska Native Regional
Corporation, was established in 1972 pursuant to the Alaska Native
Claims Settlement Act of 1971. We represent more than 2,500 Alaska
Native shareholders historically residing in the Chugach region. We
have a deep commitment to preserving the cultural heritage of our
shareholders, and our lands are at the very core of that heritage.
Our landholdings include 5,000 miles of coastline that follow the
southern tip of the Kenai Peninsula, on through the Kenai Fjords,
Prince William Sound, and the Gulf of Alaska.  Our lands are filled
with timber, minerals and wildlife, which we manage for the benefit
of our shareholders consistent with our cultural values. 
We are guided by principles of subsistence use and historical
preservation in utilizing our land.  We are currently in the
process of developing our own forest offset project, which we
believe will provide economic opportunities within our communities,
preserve our lands in a manner consistent with our values, and give
us an opportunity to do our part in combatting a warming climate.
The effects of climate change no doubt threaten traditional
subsistence lifestyles that support many of our Native
shareholders, and jeopardize the very resources that are at the
heart of our cultural heritage. We are concerned with ARB’s
proposal to reduce the ability to use offset credits – a move that
would bring into question the offset credit program and the many
benefits it provides.
We applaud California’s initiative in leading many of the efforts
against a warming climate.  ARB’s efforts have paved a way to
realizing a solution to a problem that transcends borders.  The
offset program is a vital part of this path forward, as it helps
stabilize the costs of the Cap-and-Trade Program and ensures its
continued vitality as a mechanism to slow climate change.  While
the cost containment features of the offset program are among the
most touted, the additional benefits are what resonate with
Chugach. The offset program has provided us the capacity to assist
in the fight against climate change in a manner that preserves our
values and our resources, while providing economic opportunities to
our Alaska Native shareholders. The program incentivizes
participation across jurisdictions and peoples, helping to create a
diverse and unified front to stem the tide of our warming climate.
That is precisely what is needed to combat a problem that touches
every area of the globe.
Hundreds of thousands of acres of healthy forests, managed under
the program’s protocols, make it indisputable that the program
works. Millions of tons of carbon have been sequestered.  These
forests also help maintain essential wildlife habitats and preserve
the balance of fragile ecosystems around the country. In addition,
developing such a project in the Chugach region will help us
preserve our ancient heritage, values and way of life.
We hear loud and clear the voices of those that have suffered as a
result of the development of resources and industrialization. Our
Native shareholders who maintain a subsistence way of living are
under a persistent threat of their resources being depleted due to
climate change, a problem that has also been exasperated at times
by resource development. The offset program, however, far from
aggravating these problems, provides a means to address them.
Alleviating the impacts of climate change can only serve to protect
the interests of every person the world over.
All of these benefits would be put in jeopardy if ARB were to
continue with its proposal to reduce the offset credit usage limit.
Cost stability would be diminished. Incentives to participate in
the program would be reduced. The capacity of the program to
activate a network of joined partners in the fight against climate
change would be reduced. Chugach respectfully requests that ARB not
reduce these benefits by reducing the offset credit usage limit. 

Sincerely,

Josie Hickel
SVP Energy & Resources
Chugach Alaska Corporation