Environmental Effects of the Forest Project Protocol Version 3.0 in Question

AB 32 requires that the State of California encourage the voluntary reduction of greenhouse gases (GHGs). In October 2007, the California Air Resources Board (CARB) adopted forest project protocols as an accounting methodology for use in CARB’s Climate Change Program and as a step toward using the sequestration of carbon in forest resources (trees and timber) as part of a future cap and trade program.

After adoption of the 2007 protocol, CARB “instructed staff to initiate a process to develop additional approaches and reduce barriers for participation by public lands, by private commercial forests, and by private non-timber forests such as oak woodlands.”

On September 24, 2009, CARB adopted Version 3.0 of the Forest Project Protocol, requiring that “[p]rojects using this protocol are required to maintain or increase live tree biomass on site and greenhouse gas reductions are only credited for increases in carbon stocks above the baseline (business as usual) level.” According to CARB, “[t]he update includes numerous improvements, including expanding applicability for other landowner types, especially public lands and private commercial forests, more accurate conservative methods for calculating baselines and additionality, and improved methods to address leakage and permanence risks.”

Environmental review was not performed as part of CARB’s adoption of the Forest Project Protocol Version 3.0 and on November 9, 2009, the Center for Biological Diversity (CBD) sent a letter to CARB asserting that “[t]he Board violated the California Environmental Quality Act (CEQA) by failing to consider whether it is reasonably foreseeable that its adoption of the Protocol will result in changes to the physical environment.” Further, CBD stated:

“Indeed, the Board apparently failed even to consider whether CEQA applied to its action. Yet the Board’s adoption of the Protocol will encourage and facilitate “underlying activities,” including forest clearcutting and greenhouse gas offset trading, that will undoubtedly have environmental effects.”

With regard to the impact of CBD’s challenge to CARB’s adoption of the Protocol and the Protocol itself, stay tuned.

View online at: http://carbonconscious.us/newsletter/jan10.html#top