Comment Log Display

Dear California Air Resources Board Members, 

Earth Innovation Institute (EII) would like to first congratulate
the California Air Resources Board (ARB) and its staff on
continuing the regulatory process to bring offsets from reduced
emissions in deforestation and forest degradation into California’s
Cap and Trade Program. EII works actively in many of the
jurisdictions that are members of the Governors’ Climate and
Forests task force (GCF), where deforestation is the largest source
of emissions. These states and provinces are developing some of the
most ambitious climate change programs in the world, and their
joint commitment through the Rio Branco Declaration could represent
a total of 4.4 Gt of avoided CO₂ emissions by 2030. Many of
the states have already achieved enormous reductions in
deforestation, but have so far received very little recognition or
financial support. The program proposed by California sends a
critical signal to these regions that their efforts to reduce
deforestation are recognized and valued, as a necessary component
of the global effort to mitigate climate change.  

Our staff participated in the workshop on October 28th and has
reviewed the associated whitepaper, and we are impressed with ARB’s
rigorous consideration of technical structures necessary to
implement this program. I participated in the REDD+ Offset Working
Group, and EII is supportive of ARB’s review of the ROW
Recommendations and intention to build on these frameworks to
deliver high-quality, compliance-grade offsets into the Cap and
Trade Program. We believe that the process laid out by ARB in the
workshop and White Paper will ensure the atmospheric integrity of
California’s program, provide critical social and environmental
safeguards, and support continued development of low-emission rural
development strategies in the tropics. California is a global
standard-setter in environmental regulation and climate action, and
this program is yet another example of that leadership. 

We agree that there is great value in moving this process forward
in time of the third compliance period of the Cap and Trade
Program. We look forward to continuing to participate in the public
process to finalize these regulatory frameworks, and would like to
offer our support. 

Sincerely,
Dr. Daniel Nepstad
Executive Director, Earth Innovation Institute