Comment Log Display

California has shown impressive leadership in the development of
legislation to mitigate climate change and it is good to see the
progress that is being made through the development of these Draft
Regulations for a California Cap-and-Trade Program.  

It is now understood that the forest sector contributes more than
17% of global greenhouse gas emissions and that activities to
reduce emissions from deforestation and forest degradation (REDD)
and to contribute to conservation, sustainable management of
forests and enhancement of carbon stocks (REDD+) are an essential
component of effective climate change mitigation.  The greatest
potential for REDD+ emissions reductions and removals is in
tropical regions of the world, mostly in developing countries where
these activities also have tremendous potential to generate
significant benefits for some of the poorest communities in the
world who rely on forests and healthy ecosystems for their
livelihoods and also to conserve biodiversity.  The Climate,
Community & Biodiversity Alliance provides a mechanism through the
Climate, Community & Biodiversity (CCB) Standards to identify
projects that deliver robust emissions reductions and removals as
well as significant community and biodiversity benefits through a
set of objective and comprehensive criteria and an independent
auditing system.  There are now 17 projects that have completed the
audit process and over 85 projects that are under development, each
of which represents a real multiple-benefit initiative, verified by
a third party.  Our experience of REDD+ projects in developing
countries shows that REDD+ can be, and is being, implemented in a
way that respects the rights and interests of vulnerable people
such as Indigenous Peoples and the world’s poor, enabling their
participation as partners rather than targets of the project to
conserve and restore forests and enabling them to achieve their own
development goals.  REDD+ projects are diversifying and improving
long-term livelihood security for rural communities for example by
increasing agricultural yields, protecting soil and water resources
and generating employment and also conserving biodiversity by
restoring and protecting natural ecosystems.  These positive social
and environmental outcomes are a tremendous additional potential
benefit from REDD+ that cannot be delivered at the same scale from
any other climate change project type.  

There is strong support for the inclusion of REDD+ in UNFCCC and
US Federal climate change frameworks currently under discussions
and, for the reasons outlined above, REDD+ should be included as an
approved offset type in the California and Western Climate
Initiative cap-and-trade program.  It is good to see that
international forestry offsets are included in the concept
description for offsets and I look forward to seeing further
development of the regulations for this offset type.  California is
well positioned to lead the way on defining how REDD+ can be
integrated into a cap-and-trade program by providing effective and
robust offsets, building on California’s pioneering work with other
states and provinces in the US, Brazil and Indonesia as part of the
Governors’ Climate and Forests Task Force.  While there is an
opportunity for leadership, it will also be important to ensure
consistency with emerging consensus and the developing architecture
for REDD+ at the national (US Federal) and international (UNFCCC)
levels.  

While REDD+ has potential to deliver robust emission reductions
and to deliver significant social and environmental benefits, there
are also risks particularly for Indigenous Peoples and other
vulnerable groups, so ARB should ensure effective social and
environmental standards and safeguards.  I note that the PDR
mentions (p.63) that ARB would only approve offset quantification
methodologies for project types that address any public health,
welfare, social, economic and energy effects and urge clearer
guidance on this issue with adoption of effective social and
environmental standards for REDD+ activities.