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Comment 14 for Comment on the potential for international, sector-based offset credits in the Cap-and-Trade Program (sectorbased2015-ws) - 1st Workshop.


First Name: Laurie
Last Name: Williams
Email Address: williams.zabel@gmail.com
Affiliation: Citizens Climate Lobby

Subject: Input on Process for Considering REDD offsets
Comment:
The workshop and presentations provided to date have given an
inadequate opportunity for those who have grave concerns about the
proposed REDD program to participate.  Time should be scheduled for
parties with concerns about impacts on native communities in
developing countries, additionality, demand shifting that results
in deforestation to other locations, low carbon pricing and
perverse incentives to make presentations as well as to participate
by submitting written comments.  CARB staff appear to have
prematurely become cheer leaders for this approach without
acknowledging the many serious problems associated with the
proposed approach to deforestation. 
Please include me on all future communications regarding this
topic. 
Among the concerns I would like to express and have CARB consider
further are:
1. Given the urgency of climate change, it appears that
international efforts to increase forest cover and carbon
sequestration must be in addition to reducing fossil fuel burning,
not instead of reduced fossil fuel use, as proposed here. The push
for full availability of offsets means that very few if any of the
required reductions in GHG emissions attributable to the current
AB32 cap and trade program would be actual fossil fuel emission
reductions in California as opposed to offsets. 
2. Reduced deforestation assumptions regarding baseline would allow
profit taking in situations where deforestation continues.  There
is no requirement for national increases in forest cover and carbon
sequestration to obtain incentive payments. 
3. Additionality is unprovable because the price for offsets is not
known when a project begins and may be very low in the future, as
has happened in Europe's ETS. This volatility undermines any claim
that the project would not have occurred but for the offset price
and favors projects that represent the continuation of business as
usual, which will always be the least expensive projects. 
4. Beginning this program will make it more difficult for
governments to appropriately regulate forest activities, as it will
create a huge group of people who seek to continue being paid to
continue this program run by for profit carbon traders, carbon
offset developers and carbon verifiers. 
5. A subnational program maximizes opportunities for demand shift
to other locations with the result that a different forest is cut
and there is no net benefit from the program. 
6. The program would interfere with international efforts to secure
a gradual and predictable increase in carbon prices worldwide,
which economists agree Would be the most effective way to insure a
rapid transition to cleaner energy. This program aims to keep
carbon prices low, which can be done more efficiently with a floor
price and ceiling price for allowances. 
7. Deforestation would be most effectively addressed by incentives
for national increases in total forest cover and sequestration that
are well funded and not linked to lowering carbon prices. 
I request a response from CARB to each of these points and look
forward participating future consideration of this proposal. 
Respectfully, Laurie Williams
Volunteer Citizens Climate Lobby
Williams.zabel@gmail.com
Oakland,CA
 

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Date and Time Comment Was Submitted: 2015-11-16 11:20:56



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