Comment Log Display

Comment Log Display

Below is the comment you selected to display.
Comment 33 for Comment on the potential for international, sector-based offset credits in the Cap-and-Trade Program (sectorbased2015-ws) - 1st Workshop.


First Name: Larry
Last Name: Lohmann
Email Address: larrylohmann@gn.apc.org
Affiliation: The Corner House

Subject: Comments on White Paper on Sector-Based Offsets
Comment:

State of California
---
Air Resources Board 
---
“Scoping Next Steps for Evaluating the Potential Role of
Sector-Based Offset Credits under the California Cap-and-Trade
Program, Including from Jurisdictional 'Reducing Emissions from
Deforestation and Forest Degradation' Programs”



COMMENTS


Just for fun, let's suppose that one day a certain office in one of
the many government office buildings in Sacramento produces a State
of California Staff White Paper to help the state decide what steps
to take next to evaluate the possible role of a time machine
industry in the development and growth of the state's economy. 

The title of this imaginary White Paper specifies that time machine
manufacture only has a “potential” role in California's economy. At
the time of its release, no official decision has been made whether
or not to go forward with the time machine project. Despite this
pro forma reserve, however, the White Paper never allows itself to
get bogged down in doubts about whether a time machine could
actually work. Displaying a commendable and timely “Yes we can!”
attitude throughout, it instead dwells on the benefits the project
could bring assuming it were feasible. 

Economy-wide cost savings are of course one key incentive for going
ahead with the idea. Travellers to the future would be able to
bring back finished blueprints for all sorts of devices and
products yet to be developed, making possible enormous R&D savings.
By the same token, inconvenient economic crises afflicting
present-day California could be prevented by qualified time
travelers twiddling with the past events that led up to them.
Indeed, whole sections of the White Paper are devoted to detailing
such benefits (pp. 8, 11-12, 40) and describing various threats
faced by California citizens and enterprises that could be met in
part through the innovation of time travel (pp. 9-11). 

Nor does the White Paper neglect to mention the ways that the time
machine project would help sustain Califonia's leadership in
creating models for the development of such high-concept industries
worldwide (pp. 12-13). The White Paper also lists a number of added
co-benefits or positive externalities that can be expected to be
associated the development of a temporal displacement industry (pp.
13-15). These include favorable effects on biodiversity (retrieving
the lost DNA of extinct species for cloning so that today's biomes
can be replenished), as well as the possibility of temporarily
exporting convicted criminals to the future to relieve overcrowding
in California's prisons. 

Far from just enumerating the benefits of time travel, however, the
White Paper also pays attention to the nuts and bolts of time
machine development. Sensitive to both the economic importance of
global supply chains and the advantages of close engagement with
other governments in addressing the need for time travel, it
explores the benefits of linking California's prospective time
machine sector with those being developed in other jurisdictions.
It notes potential for further cooperation between California and
Indonesia, Ivory Coast, Nigeria, Peru, Spain, Norway and Quebec, as
well as various US states (pp. 17-21), and cites already-existing
memoranda of understanding with Chiapas, Mexico and Acre, Brazil.
Acre’s technical capabilities and enabling legal environment with
respect to time-machine development are singled out for particular
approbation (pp. 42-45). The White Paper also emphasizes how far
technical developments in time travel have proceeded, spelling out
some of the latest advances in cosmology, string theory, wormholes,
and overall understanding of the space-time continuum, in the
application of which California's universities play a leading role
(pp. 18-22).

In accordance with California's emphasis on stakeholder
participation, the process of review and consultation of which the
White Paper forms a part places great importance on inviting
testimony from a wide variety of experts, as well as
representatives of groups who have previously been affected by the
infrastructure associated with the temporal displacement sector.
However, in keeping with its overall positive, can-do spirit, the
policy team did not regard considerations about the impossibility
of time travel to fall within the remit of the inquiry represented
by the White Paper. None of the experts consulted, therefore, was
polled explicitly about whether a time-machine construction project
could actually be carried out. Most of those giving testimony were
content with this omission and were happy simply to give their
views about what their field contributes, or could contribute, to
any effort to develop time travel. A few experts did depart from
this format, stating that in their judgment the project would be
unwise or a waste of state revenues and should be abandoned.
However, these stakeholders were gently urged to rephrase their
protests in terms of how best to overcome difficulties and
safeguard the time machine project against the repercussions of
certain inevitable problems that would arise in its implementation.


Thus the White Paper features, on pp. 40-41, a table with three
columns headed “Issue”, “Additional Work”, and “Reason for
Additional Work” (excerpts below). 


Issue
Additional Work
Reason
Getting from singularity or wormhole theory to a working physical
transport mechanism of modest size
Assess how researchers in other jurisdictions have addressed the
issue; evaluate what counts as acceptable size
A time machine must be suitable in size and fittings for human
passengers
Ensuring that temporal displacement mechanisms are sufficiently
accurate to deposit passengers at pre-specified dates
Determine satisfactory methodology for manufacturing and
calibrating time-travel equipment to internationally-recognized
standards
Efficient economic exploitation of information-exchange across
temporal regions necessitates robust accuracy in 
Time-travellers accidentally killing their own ancestors

Coordinate training programs for time-travellers; research and
institute insurance measures
Safeguards are essential to ensure against the sudden disappearance
of the present
Safeguards for passenger survival and health
Select optimal mechanisms for protection against disruptions in
space-time continuum; ensure the
 continuation of health safeguards
 with a monitoring, reporting, and
 verification system
Economic benefits depend on the presence of humans able to to
select suitable future technologies for transfer to the present;
human rights concerns are also important


Under “Issue” appear entries such as “Getting from singularity or
wormhole theory to a working physical transport mechanism of modest
size”. Since there is no column headed “Whether the Issue Calls
into Question the Time Machine Development Project”, the table
proceeds directly to practical means for addressing the issue in
question (“Additional Work”). Similarly, since there is no column
entitled “Reason (If Any) for Not Doing Additional Work”, the table
proceeds directly from there to a column justifying the additional
work. 

For convenience, all testimony and references used in the White
Paper are fitted into this general framework. This has a notably
streamlining effect on conventional scientific reasoning. Instead
of considering whether time travel technology has a role in
fostering California's economic growth, the White Paper simply
reinterprets scientific findings to support the assumption that it
must do so. Instead of considering whether time travel is possible,
the White Paper can simply assume that it is, using the procedures
of petitio principii to optimize science's efficiency in arriving
at the necessary conclusions. 

***

The White Paper on “Scoping Next Steps for Evaluating the Potential
Role of Sector-Based Offset Credits under the California
Cap-and-Trade Program” released on 19 October is, of course,
completely different from our White Paper on time travel. For one
thing, although imaginative, it's not imaginary. 

Yet the two are similar enough that the evaluation of one can serve
as a guide to the evaluation of the other. In particular, the
overall approach to science that the two White Papers take is
structurally identical. 

The imaginary White Paper on the potential role of time machines in
the California economy is organized around the assumption that
human time travel is possible and. Accordingly, the paper is
unwilling to countenance inconvenient science. The real White Paper
on the role of sector-based offset credits in California climate
policy is equally tightly organized around the assumption that such
credits are capable of contributing to climate mitigation. Equally,
it ignores, glosses over, or denies the science that contradicts
that assumption.

Let me take two examples. The first is the way that the White Paper
is compelled to deny basic facts that we know about the nature of
uncertainty, in particular the distinction between history and
counterfactual history. The second is the way that the White Paper
is forced repeatedly to ignore the basic climatic difference
between carbon emissions of fossil origin and carbon emissions of
biotic origin. Either one of these scientific errors, both of which
are committed pervasively throughout the White Paper, is sufficient
to invalidate the paper's underlying assumption that sector-based
offsets can help mitigate climate change.

Uncertainty first. Like project-based offsets, the sector-based
offsets treated in the White Paper require the setting of a
“reference level” or baseline of emissions. In the case of
sector-based offsets, this baseline takes the form of an “emissions
reduction target for the particular sector within the boundary of
the jurisdiction” issuing the offset (p. 1). It is against the
“Business-As-Usual” reductions specified by this baseline that
“real, measurable and long-term” additional reductions must be
proved to have occurred through the jurisdiction's “own efforts” if
credits are to be granted and sold (p. 24). Sector-based offsets
thus require that the consequences of the events of counterfactual
history be calculable with a certainty and precision commensurate
with those attaching to the events of actual history. To put it
another way, the emissions levels actually achieved under the
jurisdiction's regulation can, in principle, be specified in a
single more or less precise number. So can the reductions achieved
beyond this level. But in order to attribute the difference between
the two numbers to the jurisdiction's additional “own efforts”, it
must be shown that without those efforts, a precisely specifiable
level of reductions would not have taken place. That means being
able to calculate numerically the difference between what did
happen and what would have happened had conditions been different.
As the White Paper itself puts it, because an emission reduction
from a REDD program is 'additional' only if it would not have
happened in the absence of the project or program, it must be
determined whether the forest in question “was or is actually
destined for deforestation” (p. 35). This “destiny” can be
calculated, according to the REDD Offset Working Group from which
the White Paper takes many of its cues, simply by extrapolating the
“10-year historic average emissions due to deforestation” in a
given forest area into the future (p. 24) – even though the White
Paper itself hints, on p. 31, that there exist incentives to
maximize credit production not only by falsifying such numbers, but
also by making special, destructive interventions in forests
themselves, opening the notion of such estimates to further
ridicule.

The term “destined”, in short, inadvertently betrays the
unscientific nature of the REDD premise. The well-known FAO
forester Jack Westoby put this sort of pseudo-science in its place
more than 25 years ago when he noted that projecting then-prevalent
US heroin-consumption trends into the future yielded the conclusion
that “every man, woman and child in the US will be a junkie by
2020”. Because of the “certainty equivalence” that sector-based as
well as other offsets must posit between counterfactual and real
history, all offset credits are necessarily scientifically bogus.
To mix them with the allowances granted or auctioned under cap and
trade proper is to guarantee that the hybrid that results will be
unable even to achieve verifiable emissions goals, to say nothing
of climate goals. What is perhaps even worse, incidentally, is that
while sector offset economics requires that participating
technicians pretend to be able to calculate destiny, it is only the
destiny of farmers, forest dwellers and others who lie outside the
circle of REDD credit-generators (project operators or partner
jurisdictions (p. 25)). The latter must methodologically be treated
as, by contrast, in possession of self-determination – making this
pseudo-science not only pseudo but also inherently colonialist in
nature. A detailed discussion of this issue, however, will have to
be excluded from this particular Comment.

Second, the supposed climatic “equivalence” between carbon dioxide
emissions from fossil sources and carbon dioxide emissions from
biotic sources. On p. 24, the White Paper notes that measurements
of carbon uptake from forest growth are “complicated” by the
diversity of carbon pools within tropical forests, for example,
“above-ground biomass (i.e., tree trunks, etc.) versus below-ground
carbon pools (i.e., roots and soil carbon).” What the paper
neglects to mention is that there is also a difference between the
pools of carbon more or less locked underground in coal, oil and
gas and above-ground carbon pools such as those of forests and
grasslands. While the carbon dioxide emissions from fossil fuels
are chemically identical to those from burning or damaged forests,
they are not climatically identical. Industrial emissions add
permanently to the above-ground carbon pool circulating among
forests, grasslands, the air and the surface layers of the oceans;
biotic emissions do not. Furthermore, the prevention of
fossil-based emissions has different knock-on effects from the
prevention of emissions from biotic sources, and these differences
will result in different impacts on long-term emissions
trajectories and thus on global warming. With careful policy
design, the prevention of fossil-based emissions can be organized
in aggregate ways that contribute to a permanent shift away from
fossil fuels, while, as many have pointed out, the prevention of
biotic emissions is likely only to delay this necessary transition.
The White Paper's persistent lumping together of the carbon dioxide
from fossil fuel combustion with the carbon dioxide from
deforestation and forest degradation is therefore incorrect from
the point of view of climatology. The fact that this scientific
mistake is repeated in the very term “REDD” that the White Paper
has inherited from the United Nations and other organizations is no
excuse given the high stakes involved as well as the capability of
the California scientific community advising ARB to make its own
independent judgments.

The confusion between fossil emissions and biotic emissions by
itself invalidates the White Paper's arguments that the inclusion
of sector-based REDD credits would be a climatically positive
addition to California's cap and trade program. To take just three
brief examples:

On pp. 9-11, the White Paper states that “reducing emissions from
tropical deforestation also reduces impacts of global climate
change on California”. The implication is that because REDD offsets
reduce “emissions”, they will also reduce the impacts of climate
change on California. But both the premise and the inference are
false. First, REDD offsets do not reduce global molecule emissions
even in those cases where a REDD project succeeds in reducing
emissions from local forests. The credits from a REDD project that
are sold to California greenhouse gas polluters would be designed
to allow exemptions from laws that would otherwise prevent those
polluters' emission of an equal number of carbon dioxide molecules;
that is the raison d'etre for REDD credits. To put it another way,
the boundaries of a sector-based REDD offset program are not the
boundaries of the jurisdiction that administers the program.
Rather, they extend across the globe to California and include the
fossil-based industries located there. Hence even in principle REDD
offsets cannot reduce the impacts of climate change on California.
In fact, they would be likely to worsen those impacts due both to
the fact that prevention of biotic emissions cannot “compensate”
for fossil emissions in climatic terms and to the fact that the
lack of equivalence between counterfactual history and actual
history makes the necessary measurements impossible. Second, it is
misleading to say that REDD projects even reduce “emissions”, even
in local forest areas where they manage to be “successful”. This is
because any emissions from forests that REDD projects happened to
prevent are different in nature from the emissions from California
industries. Hence, again, the claim that the White Paper makes
throughout that jurisdictional, sector-based offset credits are a
cost-effective means of making greenhouse gas emissions
“reductions” is unacceptable from a scientific point of view.

On p. 4, the White Paper cites estimates that emissions solely from
tropical deforestation and forest degradation account for 11-14 per
cent of global greenhouse gas emissions. While these molecular
figures may well be correct, they do not imply that tropical
deforestation and forest degradation are responsible for 11-14 per
cent of global warming. That would only be the case if fossil
emissions were equivalent to biotic emissions in terms of climate
history, which they are not. It is thus unscientific to use such
numbers to attempt top reduce the share of responsibility for
climate change that falls on the extractors and users of fossil
fuels.

On pp. 39-40, the White Paper claims, in response to stakeholder
concerns, that “polluters’ obligations to reduce emissions will not
be diminished by the potential inclusion of a REDD program”. This
is a confusion based, again, on the failure to distinguish fossil
and biotic emissions. By paying for pollution rights generated by
sector-based REDD offset programs, California industries would
indeed be able to evade otherwise legally-binding obligations to
reduce fossil-based emissions; that's the reason they would buy
them. Yet even in the unlikely circumstance that these offset
credits represented lowered biotic emissions, they would not
represent lowered fossil emissions, which are, climatically
speaking, a very different and far more serious thing. California
polluters, who are responsible for so much social and environmental
damage within the state, would therefore indeed find themselves
under less obligation to address both fossil-emissions and
climate-change issues.


Larry Lohmann
Co-Director
The Corner House
Station Road
Sturminster Newton, Dorset
DT10 1BB
UK
larrylohmann@gn.apc.org
www.thecornerhouse.org.uk





Attachment: www.arb.ca.gov/lists/com-attach/33-sectorbased2015-ws-Uj5QOVI7BDpRNlQ6.pdf

Original File Name: LOHMANN COMMENTS ON WHITE PAPER.pdf

Date and Time Comment Was Submitted: 2015-11-16 16:48:02



If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.


Board Comments Home

preload