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Dear California Air Resources Board,

My name is Jared Stapp, and I recently completed my doctorate at UC
Berkeley in the Department of Environmental Science, Policy, &
Management. My primary dissertation work was an analysis of the
U.S. Forest Projects Compliance Offset Protocol, and I would like
to share the abstract and summary of that work, which has been
submitted for publication and is still in the review process. I
hope the board will consider our findings.

Thank you,
Jared Stapp

ABSTRACT:

"Carbon offsets are widely promoted as a strategy to lower the cost
of emission reductions, but recent findings suggest that offsets
may not reduce emissions by the amount claimed. In a compliance
market, offsets increase net emissions if they do not reflect real
emission reductions beyond the baseline scenario. Few studies have
examined the additionality of forest carbon offsets within
California's U.S. Forest Projects compliance offset protocol, one
of the largest forest offset programs in the world. Here we examine
additionality in California's offset protocol. Since 2012, most of
California's offset credits (84%) have been awarded to improved
forest management (IFM) projects. Using a novel database of IFM
project characteristics, locations, and remotely sensed forest
disturbance data indicative of forest management activity, we find
that IFM projects have been primarily allocated to forests with
high carbon stocks (127% higher than regional averages) and low
historical disturbance (28% less disturbance than regional averages
since 1985). Quasi-experimental analysis suggests limited
additionality, as forest offset projects creation did not
significantly lower forest disturbance rates 3 and 5 years after
project implementation relative to similar non-project lands. These
results indicate that California's forest offset protocol may
contribute to an increasingly large carbon debt."

Original File Name:

Date and Time Comment Was Submitted: 2022-12-11 09:12:44