Comment Log Display

Dear California Air Resources Board,

As a board member of Rainforest Trust
(https://www.rainforesttrust.org), a US charity focused on tropic
forest conservation, and as a committed conservation philanthropist
focused on preserving large areas of tropical forest with a primary
motivation of mitigating climate change (see:
http://millionacrepledge.org and
http://millionacrepledge.org/byers-santos/ ),  I would like to
submit the following comments in relation to the October 28, 2015
California Air Resources Board meeting regarding the possibility of
introducing tropical forest carbon offset credits to the California
CO2 cap and trade market.  I much appreciation the work of the
California Air Resources Board towards including tropical forest
conservation and restoration offsets, giving the tremendous
importance of tropical rainforest to mitigation of human-caused
climate change.  Respectfully submitted, Brett Byers.


TROPICAL FOREST COULD BE HALF OF THE CLIMATE CHANGE SOLUTION

First, and most importantly, I would like to indicate that, as I
did at the meeting, while CO2 emissions from rainforest destruction
and degradation may only account for 11% to 15% of total worldwide,
tropic forest conservation and restoration has the potential to
provide about 50% of the net CO2 emissions reductions over the next
critical decades that it will take the world to largely stop
burning fossil fuels and to reach peak atmospheric CO2
concentrations, with CO2 levels in the atmosphere then dropping.

There are two primary reasons that could permit tropic forest
conservation to provide half of the climate change solution. 
First, with adequate political will and funding (which are needed
for all climate change solutions), forest conservation and
restoration can be implement much faster than a transition away
from fossil fuel use.  The New York Declaration on Forests
indicates the length of time dramatically reduce and eliminate
forest destruction is measured in years, while estimates
(especially when political realities are considered, as well as the
still rapidly increase in use of fossil fuels in the developing
world) of the time to end fossil fuel use start at 35 years, with
more realistic periods extending to 50 or 85 years.

Second, there are hundreds of millions of acres of tropical forest
that are degraded, often selectively logged, such that the large
trees, which contain the majority of the above-ground-carbon, are
absent.  If these degraded areas are protected, they would absorb
huge quantities of CO2 for 50 to 100 years until the small trees
become large.  No human intervention is needed, as the seed base
and variety of small trees are intact within the degraded forest. 
An amount of as much as over 10 billion tons of CO2 could be
absorbed per year by recovery of degraded forest.  This amount thus
could be nearly 30% of current worldwide CO2 emissions and could be
larger than the current net emissions from continued tropical
forest destruction and degradation, which amounts to another 11% to
14% of total CO2 emissions.

As such, tropical forest conservation and restoration could provide
a critical bridge to the post-fossil fuel era, and could be a major
portion of any climate change solution.

Finally, I note that the amount of carbon stored in tropical
forests worldwide (nearly 2,000 billion tons of CO2 sequestered) is
equal to over half of the carbon stored in proven fossil fuel
reserves (estimated to be about 3,000 billions tons of CO2
emissions on burning of this fuel).  Thus, just as we court very
dangerous climate change by burning all (or even a substantial
fraction of) proven fossil fuel reserves, we face the same danger
by destroying all (or a substantial fraction of) remaining tropical
forest.

Here are citations to articles and papers (many peer-reviewed
academic papers) providing support to the assertions above:
1.  Regarding the 35+ years to convert off of fossil fuels: Mark Z.
Jacobson and Mark A. Delucchi, Providing all global power with
wind, water and solar power, Part I: Technologies, energy
resources, quantities and areas of infrastructure, and materials,
Energy Policy (2011) 39, 1154-1169,
http://www.stanford.edu/group/efmh/jacobson/Articles/I/JDEnPolicyPt1.pdf
.
2.  New York Declaration on Forests: 
http://www.un.org/climatechange/summit/wp-content/uploads/sites/2/2014/07/New-York-Declaration-on-Forest-–-Action-Statement-and-Action-Plan.pdf
.
3.  Peer reviewed articles showing potential of rainforest to
offset CO2 emissions, including via absorption of CO2 by recovering
degraded forests (the second article also indicates that about 500
billion tons of carbon is stored in tropical forests, equal to
nearly 2000 billion tons of CO2 emissions on destruction of such
forests):
a.  Richard A. Houghton, The emissions of carbon from deforestation
and degradation in the tropics: past trends and future potential,
Carbon Management (2013) 4(5), 539–546,
http://research.mblwhoilibrary.org/works/39404 and
http://www.tandfonline.com/doi/pdf/10.4155/cmt.13.41 .
b.  John Grace, Edward Mitchard and Emanuel Gloor, Perturbations in
the carbon budget of the tropics, Global Change Biology (2014) 20,
http://onlinelibrary.wiley.com/doi/10.1111/gcb.12600/full .
c.  There is literature that indicates that tropical forest
conservation and restoration could offset about 30% current
human-caused C02 emissions (see:
http://www.cgdev.org/blog/tropical-forests-offer-24%E2%80%9330-percent-potential-climate-mitigation
and citations from within, including
http://www.cgdev.org/sites/default/files/CGD-Climate-Forest-Paper-Series-11-Goodman-Herold-Maintaining-Tropical-Forests.pdf
).  But note that because it will take decades to eliminate (or at
least dramatically reduce) fossil fuel use, whereas tropical forest
conservation and restoration can be put in place far more quickly,
the cumulative net CO2 emissions from tropical forest conservation
and restoration could be roughly equal to that from reduction in
fossil fuel during the critical period from now until peak
atmospheric CO2 concentration, with tropical rainforest
conservation and restoration providing a crucial bridge to the post
fossil fuel era.

If you would like any of these articles in PDF format or if you
would like further explanation, please contact me.


MULTIPLE MECHANISMS TO ENSURE BENEFIT FROM TROPICAL FOREST CREDITS

With regard to page 35 (item 6) of the ARB Staff White Paper on
this subject found here
http://www.arb.ca.gov/cc/capandtrade/sectorbasedoffsets/ARB%20Staff%20White%20Paper%20Sector-Based%20Offset%20Credits.pdf
, I think that the cap should perhaps be lowered when new sources
of credits (such as REDD) are added.  Another option is to reduce
the crediting baseline relative to the reference the level.  Or, as
degraded forests recover, the reference level could be altered over
time to ensure greater forest conservation over time.  Or these
mechanisms could be applied in combination.


FOCUS ON ELIMINATION OF SELECTIVE LOGGING

Selective logging, while far better than clear cutting of forest,
must end for tropical forest conservation and restoration to reach
its full potential.  As described in my first comment above, about
one-half of the potential of tropic forest to mitigate climate
change could stem from regrowth of degraded (often selectively
logged) tropic forest.  Some refer to selective logging as a
sustainable use of forest.  But it is essential that the ARB not
permit selective logging as a sustainable use of forest, given that
and end of selective logging is a huge part (again, about half) of
tropical forest’s potential to mitigate climate change.  Thus, on
page 26 of the ARB Staff White Paper (in the second paragraph of i.
Leakage), it is essential that selective logging is NOT consider
sustainable forest management.  Other truly sustainable use, such
as harvesting brazil nuts without harming trees, would be
acceptable.


FOCUS ON HALTING BUILDING OF ROADS IN OR ADJACENT TO TROPIC FOREST

On page 25 of the ARB Staff White Paper (in the second paragraph of
ii.  Additionality), I find the mention to road building as a valid
reason to adjust the reference level disturbing.  Road building is
hugely destruction to forests (bring destructive development
because of the road access), and should be strongly discouraged.


OTHER COMMENTS ON ARB WHITE PAPER

On pages 14 to 15 of the ARB Staff White Paper, I think that there
may be a small mistake in description of the albedo effect, as the
paper focuses on high reflectivity as a problem rather than a good
thing.  In my understanding, low reflectivity cause direct
absorption of heat, whereas high reflectivity (such as from ice,
snow or cloud cover) reduces this direct absorption, which direct
absorption is a much bigger issue than any further reflection back
to earth within the atmosphere.

On page 27 of the ARB Staff White Paper (in the ii. Reversals
paragraph carried over from the prior page), I worry that the reset
of the baseline emissions for naturally-caused deforestation could
be a problem, if a warming and drying planet (because of climate
change) would result in more and larger fires in the tropical
forest, and perhaps provisions should be made to avoid this.