Comment Log Display

As a 2-term member of the AB 32 Environmental Justice Advisory
Committee (EJAC), with over 20 years experience organizing with
environmental justice (EJ) communities, I write with grave concerns
on ARB’s consideration of international forestry offsets, REDD
and/or the Sector-Based Offsets (SBO) scheme and propose the
program be dropped.

I appreciate the improving effort by the ARB to recognize its
responsibility to consult with the EJAC and integrate EJ into AB 32
implementation. The authors of AB 32 recognized that EJ communities
are the most impacted by industrial and climate pollution, and thus
institutionalized EJ participation in the law’s implementation.

Articulated in the Principles of Environmental Justice, the EJ
community’s opposition of offsets and REDD uses the long-view lens
of problematic environmental policies waged under 500 years of
colonization and over 100 years of industrialization. The EJAC has
repeatedly rejected offsets in AB 32 implementation. In the EJAC’s
first term, in the 2008 recommendations, offsets were cited as
problematic along with carbon trading. In the EJAC’s 2014
recommendations, we wanted the offsets program canceled, especially
REDD. And in the current EJAC term, we initially recommend ARB to
halt pursuing REDD international offsets.

We see the design flaw in Cap & Trade in that the ARB has not yet
balanced cost containment for climate polluters, with reducing
climate pollution harms in California EJ communities. An initial
view of GHG emissions through 2013 shows emission increases in the
state’s most disadvantaged communities. Since the top offsets users
to date, like Chevron at 1.7 million metric tons CO2E, are the
biggest industries to take advantage of the the loophole of offsets
by maximizing climate pollution reduction outside of California.
The consequence is thus concentrating climate pollution in EJ
communities, and minimizing benefits to our state—both of which run
counter to the goals of AB 32.

The best safeguards for the SBO program is to drop the program.
While ARB looks at safeguarding international, indigenous and
forest-dwelling communities for the SBO program, it should
guarantee safeguards for EJ communities at home first. ARB cannot
run an international safeguards program without knowing how to do
it in California. ARB must show EJ communities that it won’t allow
climate pollution increases in those areas, and that instead the
primary emissions reductions are actually there. Similar to the
United Nations Declaration of Rights of Indigenous Peoples, there
needs to be free, prior and informed consent of EJ communities in
California for the offsets program. Right now, as it stands, I know
that California’s EJ communities do not consent to the offsets,
REDD or SBO program because of the harms that Cap & Trade is
already causing.  Drop the SBO program now.