Comment Log Display

We’ve heard some compelling comments about how REDD has worked, or
how people hope it will work, but for every example of positive,
there is also an example of negative, as Mr Fyneface has really
described. And those examples of negative experiences  are
extremely risky.

You all have highlighted many important social safeguards, but
there is a fundamental disconnect: how really can you garauntee
that any of these safeguards are met? How do you enforce these? I
totally understand that ARB does not want to expose the state to
being party to human rights violations, but really – how can you
monitor any of these things when you are dealing with projects in
extremely remote and far flung places. 

You mention “a system for monitoring and reporting on safeguards,”
but that was very cursory. That to me is the critical component of
this system, and I have not really heard any details on what that
system looks like and how it is enforced. 

I also hear a lot of effort from you all to distance yourselves
from REDD projects of the past, and as I understand it, the main
point there is that this is a jurisdictional approach. 

I just don’t see how you get away from the potential HR violations.
I know you say that Cross River state is not a jurisdiction you are
looking to link with, but I think Fyneface’s comments reflect the
broader dangers with the program, whether its in Nigeria or
elsewhere, that need to be taken seriously. 

We’ve also been talking a lot about Brazil today - I also just want
to highlight that Brazil is in the middle of major political
upheaval and we have no idea how that will impact the government’s
long term capacity or commitment to implementing equitable,
effective climate programs.  It is exactly that kind of volatility
in other countries that ARB cannot predict and thus highlights some
major challenges to this program. 

I also want to flag that the issues environmental justice
communities are struggling with here in California, are in fact
social issues that also need to be addressed by ARB and I have not
yet heard anything about that. 

So just looking at what is happening here, this is what we see: 

The State of the Air for 2015 just came out. The top five US cities
most impacted by unhealthy ozone days are in California, as are the
top seven cities burdened with unhealthy particle pollution days.

And we know that many of these air quality issues are
disproportionately impacting low-income communities and communities
of color. 

Our current regulations are simply not getting the job done – that
is exactly why ARB is looking at new regs for Short Lived Clmate
Pollutants.  As you explore a new protocol that will allow
polluters to continue, it is absolutely your responsibility to
think about ways to strengthen this. 

I think there are serious questions about the overall offset
program that haven’t been addressed before we expand it. 

We have also been looking at the offsets program more generally.

We have also found that the majority of offset users are large
corporations: the top ten users are: Chevron, CalPine, Tesoro, So
Cal Edison, Shell, PG&E, La Paloma, SDG&E, and NRG. 

These top 10 account for 55% of all offsets; over 60% of companies
do not use ANY offsets. 

These big companies can access this complicated system and get the
cheapest prices for carbon emissions, below even what C02 is being
auctioned at, which is already quite low.

So, it seems to be really only the major polluters using offsets,
not small facilities who would be most hard hit by pricing issues.

So from a cost containment perspective, this expansion seems
entirely unnecessary. And, ARB seems to have already done A LOT to
make it cost effective for corporations to comply with C&T regs, so
additional protocols seem unnecessary. 

And it seems like REDD just give some of the largest corporations
in the world, with multi billionaire dollar budgets, access to an
even lower price to continue polluting. 

And according to the most recent GHG reporting data, oil & gas
emissions have even risen slightly since cap & trade was started. 

I would add that there are even verification concerns with the
CURRENT offsets program. We’ve been trying to better understand
exactly what projects are being paid for by large corporations in
states such as Arkansas and Michigan, and it is extremely difficult
and concerning to understand what really are being approved as
offset projects in the current program, much less one that is
international. 

So my questions to you are: 
•	What is your system for enforcing / monitoring safeguards? 
•	given the intense scrutiny that is required to make these
linkages successful, how is this a good use of your staff time when
there is SO MUCH to be done here in California? 
•	From the cost containment perspective, why is it that you think
more mechanisms are necessary to provide more mechanisms for
companies to pollute when prices are already extremely low 
•	And what exactly are you doing to ensure that CA’s offset program
specifically – not the other activities at ARB - is NOT
exacerbating EJ issues here in California?