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Is California steamrolling REDD offsets into its cap and trade scheme?

California steamrollingCalifornia is currently considering whether to allow REDD credits into its Global Warming Solutions Act (AB 32). For several years, there has been a (sometimes heated) debate about this issue, some of which REDD-Monitor has documented.

But California’s decision-making process isn’t taking this debate into account. Instead, it is pushing through with a series of workshops that are supposed to address the technical problems associated with REDD.

The fundamental issues, such as the continued pollution in California that REDD offsets would allow are ignored, as Larry Lohmann points out in his submission to the California Air Resources Board’s October 2015 White Paper about including REDD credits.

The resistance to REDD credits continues in California, because it will provide a loophole for polluters in California and because of the impacts of REDD on the livelihoods of local communities and indigenous peoples living in REDD areas.

On 18 March 2016, a group of environmental justice NGOs wrote to Mary Nichols, chairperson of the California Air Resources Board, requesting a delay of the technical workshops on international sector-based offsets. The letter notes that,

The rushed timing barely affords attentive California residents the ability to engage in a substantial manner, much less allowing affected communities on the ground in the tropical forest regions in question time to be informed of the meeting and to consider participation. This is of great concern, and undermines transparency and public participation, especially in those regions to be most impacted by this possible program.

They have not received any reply to their letter, which is posted in full here:

March 18th, 2016
Chairperson Mary Nichols
California Air Resources Board
1101 I St., Sacramento CA
RE: Request to Delay Technical Workshops on International Sector-based Offsets
Our organizations write to express our profound concern about the rushed pace with which the
California Air Resource Board (CARB) is moving forward with the development of a framework for International Sector-based Offsets. We write with an urgent request that the March 22 technical workshop and subsequent workshops be postponed and re-scheduled. The current scheduling does not permit the concerned public and affected communities to provide the opportunity for fair and substantial engagement regarding this high risk and exceptionally controversial climate change mitigation policy proposal.
On Saturday March 12 ARB notified the public, with 10 days of advance notice, of a technical workshop to be held on Tuesday, March 22 regarding the potential development of an International Sector-based Offsets scheme which would be featured in a proposed future expansion of the California Cap-and-Trade Program. Previous to this March 22 meeting, on March 18 at noon, less than 48 business hours before the convening of the technical workshop, ARB is to have published a technical White Paper to inform the March 22 technical workshop. Also included in the public notice of March 12 was notice of two more future technical workshops on the International Sector-based Offsets topic, on April 5 and 28, with no information on when a white paper or supplemental materials would be published.
The rushed timing barely affords attentive California residents the ability to engage in a substantial manner, much less allowing affected communities on the ground in the tropical forest regions in question time to be informed of the meeting and to consider participation. This is of great concern, and undermines transparency and public participation, especially in those regions to be most impacted by this possible program.
Such a rushed schedule is not only unnecessary, it also undermines CARB’s commitment to transparency and thorough public process. In addition, concerns from environmental justice organizations have yet to be directly addressed by the California Air Resources Board. The California Environmental Justice Alliance and the Asian Pacific Environmental Network both submitted comment letters in November of 2015 on ARB’s proposal to include international, sector-based offsets and have yet to receive any response. We have additional concerns that the Environmental Justice Advisory Committee and international community leaders who have significant concerns regarding this proposal have also yet to be substantively engaged in the process.
It is imperative that the CARB have a well thought out and effective plan to solicit stakeholder feedback from the communities in California that will be directly affected by this offsets program, as well as the indigenous communities in the tropical regions that would be host to the International Sector-based Offsets Program. To our knowledge, CARB has made no effort to speak directly with community and indigenous leaders who have expressed significant concerns with the program. Until such a plan for public participation is designed, the CARB must put these workshops and related policy framework decisions on hold.
We urgently request that all the technical workshops, and specifically the March 22nd workshop, be postponed until a full public participation plan can be developed. The March 22 technical workshop and subsequent technical workshops, and their related White Papers, should be rescheduled in a manner that guarantees that California residents from many diverse backgrounds are able to participate. This must include a meeting directly with communities who would be most impacted: environmental justice groups and communities in the areas where REDD programs would be implemented, including those who have concerns.
Thank you for your consideration of this request and we look forward to a response.
Amy Vanderwarker, California Environmental Justice Alliance
Gary Hughes, Friends of the Earth
Martha Arguello, Physicians for Social Responsibility – LA and Member of the Environmental
Justice Advisory Committee
Katie Valenzuela Garcia, Member, Environmental Justice Advisory Committee
Mari Rose Taruc, Member, Environmental Justice Advisory Committee
Adam Zuckerman, Amazon Watch
Parin Shah, Asian Pacific Environmental Network
Alberto Saldamando, Indigenous Environmental Network
Yvette Lopez, Pacoima Beautiful

Richard Corey, Rajinder Sahota and Jason Gray, California Air Resources Board

Secretary Rodriguez, California Environmental Protection Agency

Arsenio Mataka, Assistant Secretary for Environmental Justice And Tribal Affairs

Dean Florez, California Air Resources Board Member

Diane Takvorian, California Air Resources Board Member

Phil Serna, California Air Resources Board Member


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  1. California has been considering REDD+ since 2010 – if not longer – including repeated public workshops and hearings. Not sure how 6 years of public dialog amounts to steamrolling?

  2. It would be shame and grave mistake to ignore the the voice of the vocelesseses

  3. @Kate Dillon Levin (#1) – Thanks for this. I’m not arguing that California is moving quickly. Steamrollers are not fast. My point is that the California Air Resources Board is not taking account of the problems with REDD.

    Larry Lohmann’s response to the October 2015 White Paper looks at the way CARB is avoiding dealing with the problems of REDD:

    The real White Paper on the role of sector-based offset credits in California climate policy is equally tightly organized around the assumption that such credits are capable of contributing to climate mitigation. Equally, it ignores, glosses over, or denies the science that contradicts that assumption.

    Lohmann gives two examples of the way CARB evades the problems of carbon offsetting and REDD:

    The first is the way that the White Paper is compelled to deny basic facts that we know about the nature of uncertainty, in particular the distinction between history and counterfactual history. The second is the way that the White Paper is forced repeatedly to ignore the basic climatic difference between carbon emissions of fossil origin and carbon emissions of biotic origin. Either one of these scientific errors, both of which are committed throughout the White Paper, is sufficient to invalidate the paper’s underlying assumption that sector-based offsets can help mitigate climate change.

    REDD-Monitor has documented some of the debate about including REDD in California’s cap and trade scheme in a series of posts, collected here.

    Could you point me to a report where CARB has taken the criticisms of REDD on board (in particular the two examples that Larry Lohmann puts forward) and found ways of dealing with them?

  4. HI Chris – thank you for the thoughtful response. I wonder if you’ve attended the ROW public workshops and read the October White paper yourself? Because Lohmann’s criticisms are indeed addressed directly in the paper, including explaining how it arrived at the assumption that managing land use change is a legitimate emissions reduction activity – as also agreed to in the Paris Agreement. His concerns were also addressed during live, public events – many if not all were streaming – including one where Amy Vanderwarker, one of the signatories to the letter published above, made a public statement. And by steamrolling you may not have been referring to time, but indeed the whole article above accuses the CARB of ‘rushing.’ I am glad REDD+ is under a microscope, and there are many ways in which REDD+, implemented poorly, could go very wrong. But have you visited an unmanaged forest in a developing tropical country – I ask if the status quo is ok with you? Because when I have been in Bolivia, Peru, and Indonesia I am NOT ok with how local and indigenous peoples are treated under the status quo, I am not ok with how the landscapes have been degraded for economic gain that benefits few while harming many. REDD+ brings vital land use and tenure issues to the policy fore and we should be fighting for getting it right.