Comment Log Display

January 11th, 2010

Mary Nichols
Chairman
California Air Resources Board
1001 "I" Street
P.O. Box 2815 
Sacramento, CA 95812

Dear Ms. Nichols,

The National Wildlife Federation appreciates the opportunity to
comment on the Preliminary Draft Regulation for a California
Cap-and-Trade Program published on November 24th, 2009.  National
Wildlife Federation has over 4 million members, partners and
supporters nation-wide, and is among the primary environmental
organizations in the United States addressing the critical need for
instituting domestic and international forest protection policies
for an effective climate change solution. The loss of our planet’s
tropical forests contributes approximately 15 percent of annual
global greenhouse gas emissions. As an organization with 111,918
active members and supporters in California, we recognize that we
cannot win the fight against climate change without addressing
emissions from global deforestation. 

National Wildlife Federation commends the California Air Resources
Board (ARB) for its continued leadership in advancing California’s
landmark climate legislation. Our organization applauds
California’s exceptional efforts to create the Governors’ Climate
and Forests Task Force and work with other states in the U.S.,
Brazil and Indonesia to tackle greenhouse gas emissions from
tropical forest loss. Our organization supports California’s
efforts to include international forestry efforts, including
Reducing Emissions from Deforestation and Degradation in Developing
Countries (REDD), into the overall framework of the proposed
Cap-and-Trade Program.  

National Wildlife Federation urges the ARB to ensure that
effective environmental and social safeguards are included in the
REDD language of the California Cap-and-Trade Program, along the
lines of the provisions included in the U.S. House of
Representatives H.R. 2454 American Clean Energy and Security Act,
and the Senate Clean Energy Jobs and American Power Act S. 1733.
Our organization recommends consideration of the Climate, Community
& Biodiversity Standards (CCBS) to validate and verify the social
and environmental benefits of forest carbon projects, and to
guarantee that responsible safeguards are included in California’s
planning of carbon credits generated by REDD programs abroad.  

Our organization would like to simultaneously urge the ARB to
ensure that the quantity of offset allowances potentially included
in the California Cap-and-Trade Program does not significantly
reduce incentives for large-scale emissions reductions from
regulated sectors in California. The international offset
provisions in the preliminary Draft Regulation for a Cap-and-Trade
Program could achieve dramatic gains in the reduction of global
warming pollution, however this must be appropriately balanced to
maintain a reasonable price for carbon that will ensure a
transition to low-carbon energy development in future market
incentives for California. Our organization also encourages the
ARB, as it structures the proposed climate Program, to ensure that
any provisions for offsets specifically include measures to benefit
air quality in communities suffering from disproportionate levels
of pollution within California. 

National Wildlife Federation commends California for its
pioneering efforts to initiate state action to stop global
deforestation and address climate change by including tropical
forests under the international offset provisions of its
Cap-and-Trade Program. Such a program could help protect California
jobs by reducing illegal logging and other forms of forest
conversion overseas that result in producing goods that compete in
the global market with Californian foresters, farmers, and
ranchers. At the same time, it could set an essential example for
the rest of the country in pursuing equitable and effective
solutions to global climate change.

Respectfully,


Barbara Bramble
Senior Advisor for International Affairs
National Wildlife Federation