September 19, 2016
I am writing in regards to the notice of public hearing to consider amendments to the California Cap on Greenhouse Gas Emissions and Market-Based Compliance Mechanisms Regulation.
Forest Trends supports the ARB staff recommendation to revise the cap and trade program to achieve the new mandated GHG reduction levels of 40% below 1990 levels by 2030, the new level of reductions that is now required by state law and was signed last week by the Governor.
We strongly support the staff recommendation to maintain the existing role for offsets, strongly support the staff recommendation to continue discussing the role for sector based credits, including especially, those from tropical forests, and to adopt regulations that would these types of offsets in the 3rd compliance period.
We urge you to act quickly to complete this addition to the program, and we want to point out that ARB has explored this issue extensively and has built a strong record supporting this action. The ARB staff has recommended this action many times, adding tropical forest offsets is specifically referenced and contemplated in the existing AB 32 regulations, and adding tropical forest offsets will bring many benefits to California, including:
Please inform Forest Trends if we can provide any further information related to this matter.
President & CEO