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Dear Ms. Bamberger,

I would like to invite you to take the following comments  into
account for the elaboration of the Californian cap-and-trade
regulation and using international REDD offsets within this
mechanism:

1. Double Counting. The United States of America have assumed a
voluntary economy-wide emissions reduction target. So has Mexico. A
mechanism must be put in place to avoid any double counting towards
UNFCCC-registered targets. Since the Mexican target is explicitly
bound to external support which can be delivered through market
mechanisms, it seems appropriate to allow Mexico to count the
emissions reductions towards their target while not counting them
towards the US target. If they were to be counted towards the US
target, a previous negotiation with the Mexican government is
necessary to clarify the conditions under which the Mexican
government would be willing to exclude these offsets from their own
accounting.
If this double counting issue were to be ignored, the offset
mechanism would constitute a mechanism that reduces ambitions
rather than emissions.

2. Discounting. An option to deal with double counting and also for
taking the principle of common responsibility into account could be
a discount of foreign offsets. With a 50% discount, double counting
would be neutralized. With a further discount, the common
responsibility of non-Annex I countries could be included in a
standardized way. This may also be an alternative to a very
ambitious crediting baseline.

3. Safeguards. Environmental and social safeguards should be
required on an operational level. Proof that both relevant
international and national law is respected should be required for
registering any credits. This can be an incentive for implementing
high social and environmental standards that have remained on paper
so far. The establishment of realistic dispute resolution
mechanisms should be promoted where these do not exist. Complete
public transparency as to the flow of funds for initiatives
resulting in credits could be required, providing a strong
counterbalance to the risk of corruption.

4. Permanence. REDD+ or any forest related emissions reductions or
sequestrations can and must not be equalized to emissions
reductions from fossil sources without cautionary measures. If they
are to be used as offsets, they must effectively guarantee that for
the amount of time that the emissions they are offsetting stay in
the atmosphere they effectively keep the carbon sequestered. In the
face of a changing climate, this is difficult if not impossible to
guarantee for trees. Therefore, robust mechanisms must be developed
that can account for this risk of reversals. Without them, the
offsetting mechanism will simply be an "ambition reduction
mechanism".

5. Shared Liability. One of the possible ways to deal with
non-permanence in forest related emissions reductions could be to
share liability for reversals among the seller and the buyer.
Mechanisms which do that should be explored.

I thank you for the opportunity to comment on the draft regulation
and I hope to have made a contribution that helps you write a
regulation that especially serves future generations. They need our
help and consideration.

kindly,

Kjell Kühne

Original File Name:

Date and Time Comment Was Submitted: 2010-08-20 12:02:10