in Brazil, USA

Letter from California senator Bob Wieckowski: “I write to express our strong opposition to the Air Resources Board’s Tropical Forest Standard”

“The TFS [Tropical Forest Standard] approach risks producing a landslide of false credits due to the challenges with ensuring credited reductions are permanent, non-leaking, and additional, and the inherent possibility that other jurisdictions buying and selling TFS credits will interpret the TFS’ protections liberally. California should not lend its name to these efforts nor commit to the implausible project of monitoring other governments’ use of the TFS going forward.”

That’s from a letter dated 13 August 2019 from State Senator Bob Wieckowski to Jared Blumenfeld, Secretary of the California Environmental Protection Agency, and Mary Nichols, Chair of the California Air Resources Board.

In November 2018, an Air Resources Board hearing postponed making a decision on whether to endorse the Tropical Forest Standard. The Air Resources Board is set to consider an updated Tropical Forest Standard at a public meeting on 19 September 2019.

Permanence, leakage, and additionality

Wieckowski’s letter highlights the problems of permanence, leakage, and additionality. These are structural problems that REDD has faced from the beginning, that have never been adequately addressed (as another recent letter to the Air Resources Board from four State Assembly members acknowledged).

  • Permanance: Wieckowski highlights the Brazilian state of Acre, which the Air Resources Board described in 2016 as, “ready to be considered for linkage” with California’s cap-and-trade scheme.

    Earlier this year, ProPublica journalist Lisa Song wrote that,

    Everyone is looking to Acre as the prime testing ground. “Acre’s program is the most advanced,” a board spokesman said in an email. Supporters kept sending me brochures that used words like “pioneer,” “innovative” and “new business models” and showed smiling residents harvesting Brazil nuts instead of cutting down the rainforest.

    Wieckowski points out that despite the on-going jurisdictional REDD programme in Acre, deforestation rates have been increasing. Between 2017 and 2018, deforestation shot up by 83%.

    REDD proponents point to provisions in the Tropical Forest Standard to address such “reversals”. A 10% credit buffer pool will be created, to replace invalidated credits. Wieckowski writes that,

    [T]he buffer pool could quickly be swamped by the effects of natural diasasters, changes in global commodity prices, or political regime changes. Notably, Brazilian President Bolsonaro has weakened environmental protections in the Amazon and threatened to open protected rainforest areas to industrial development.

  • Leakage: In his letter, Wieckowski points out that the main causes of tropical deforestation are cattle ranching, palm oil and soy plantations, mining and timber production. All of these can move easily. If deforestation in one state is strictly regulated, new production can simply move to less well regulated states.

    Wieckoski writes that,

    [I]f deforestation merely shifts (or “leaks”) deforestation away from TFS jurisdictions, then TFS credits will not represent real emission reductions. The TFS leakage provisions are contradictory and fall far short of best practice in leakage assessment. Even with best practice measures, leakage is hard to prevent and impossible to accurately quantify.

  • Additionality: The main reason the Clean Development Mechanism has been discredited, Wieckowski writes, “is lack of additionality – that is, that CDM offset credits were awarded to activities that were already going to happen.”

    The Tropical Forest Standard attempts to address this in part with a relatively strict crediting baseline, but as Wieckowski notes, “even a strict baseline can result in large quantities of non-additional credits as a consequence of unpredictable deforestation dynamics in tropical regions”.

REDD targets small-scale landholders

Wieckowski points out that market-financed conservation is not structured to address the main causes of tropical forest loss. “Nearly all forest-carbon offset projects and jurisdictional programs to date have used payments to limit forest-based livelihood activities of small-scale landholders,” Wieckowski writes.

The reason for this is that market mechanisms seek out the cheapest offsets. Compensating agribusiness, logging, and mining corporations for reducing forest destruction is too expensive. The political power of these industries in many countries makes the effectiveness of these payments even more doubtful, Wieckowski notes.

The focus on small-scale landholders results in two serious problems:

  1. Poor environmental integrity: “Programs that mainly target small-scale landholders rather than the large-scale drivers of deforestation are unlikely to create permanent and deep reductions in deforestation rates. Advocates of project and jurisdictional results-based conservation programs have been unable to find evidence that these programs have delivered significant emissions reductions.”
  2. Restricting small-scale landholders’ use of forests risks causing harm to indigenous and other forest communities: “This poses a serious reputational risk to California. Payments for forest protection have been associated with restricted use of dispossession, violent in some cases, of farm and forest communities from the lands they depend upon. Many tropical forest regions have been and continue to be sites of land-grabbing and green-grabbing for ‘carbon farms.’ Decades of experience have shown that safeguard requirement meant to prevent harm can be met on paper while violated in practice.”

No shortage of investments that California can make at home

Wieckowski points out that there is “no shortage of additional investments that California can make at home to lead the way on climate change mitigation”. Doing so would improve the lives of Californians living near oil industry operations and facing the health impacts of California’s fossil fuel dependence.

California can also move to stop imports of products and commodities that cause tropical deforestation.

Wieckowski concludes his letter as follows:

[B]y endorsing the TFS, California would put our state’s reputation and support behind a controversial climate policy approach that risks weakening global climate agreements and being associates with human rights abuses and other social harms.

Let us work together to pursue real, lasting, and just solutions to tropical deforestation. Leaving the TFS behind is a necessary step in this process.


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