Adding tropical forest offsets will bring many benefits to California

September 19, 2016

Dear Sir/Madam,

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:

  • Helping to fulfill  the directive in AB 32 to  act globally;
  • Contributing to fulfill  the requirement in  AB 32 to  adopt  the most cost effective mechanism to meet the reduction level;
  • Providing assistance to help tropical forest states that have signed Governor Brown’s Under-2-MOU meet their emission reduction pledges;
  • Mitigating global climate change that is generating impacts affecting disadvantaged communities disproportionately, and adversely impacting natural resources upon which all life depends.

Please inform Forest Trends if we can provide any further information related to this matter.


Michael Jenkins
President & CEO
Forest Trends

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