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Indigenous People Explore Many Shades Of REDD

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Indigenous People Explore Many Shades Of REDD

Indigenous people have long been the most effective guardians of the rainforest, but confronted with growing global pressures to clear their lands, how will they find the resources needed to protect their forests and thrive? In this series, we will explore the new emerging mechanism known as "Indigenous REDD" and see how it draws on and contrasts with forest-carbon projects that exist to date.

This article was originally published on Ecosystem Marketplace.

15 January 2015 | On a daily basis, logging trucks rumble up an offshoot of Brazil's Highway 364, laden with muddy trunks illegally harvested from the Zoró Indigenous Territory, at the southern edge of the Amazon Rainforest, along the border between the Brazilian states of Rondônia and Mato Grosso.



 Seen from above, indigenous territories in the Arc of Deforestation appear as islands of emerald in seas of gray-green degradation. It's as stark an illustration as you'll find of the vital role that indigenous people play as guardians of the rainforest, but it's a role that takes its toll on the people themselves. The Sete de Setembro territory is in the center, with Igarape Lourdes to the northwest and the Zoro territory to the northeast.[/

Seen from above, indigenous territories in the Arc of Deforestation appear as islands of emerald in seas of gray-green degradation. It's as stark an illustration as you'll find of the vital role that indigenous people play as guardians of the rainforest, but it's a role that takes its toll on the people themselves. The Sete de Setembro territory is in the center, with Igarape Lourdes to the northwest and the Zoro territory to the northeast.


The bounty includes old growth teak and mahogany, the crown jewels of the Amazon rainforest – destined for luxury furniture showrooms across Brazil and around the world. The finished wood from a single mahogany trunk can fetch tens of thousands of dollars, and a few pennies of that will go to members of the Zoró indigenous people who illegally escort loggers to the most productive parts of their forest. It's a practice in which many Zoró say they'd rather not engage, but they see no choice if they're to feed their families.

After leaving the Zoró territory, the trucks pass along the northern edge of the Sete de Setembro, where the Paiter-Surui community once logged just as aggressively as the Zoró do today.

"We had survived for centuries by nurturing the forest, but to survive in the modern market economy, we had to let outsiders come in and chop the mahogany and teak," says Almir Narayamoga Surui, chief of the Paiter-Surui people. "As the trees fell, the birds went silent, the animals and fish retreated, and our people lost their way."

But that changed dramatically over the past five years, as most of his people forswore logging and chose instead to earn money from carbon offsets by maintaining the forest and keeping the loggers at bay. Still, some logging continues here as well.

After leaving Sete de Setembro, the trucks briefly pass through the southern tip of the Igarapé Lourdes territory, home to members of the Gavião and Arara – people who never succumbed to the temptation to chop their trees, and who have a forest that's thicker and richer than that of their neighbors, but a population that's financially poorer.

The trucks then pass out into the dusty terrain beyond the indigenous territories, where cattle graze on depleted land and ranchers wonder why their indigenous neighbors refuse to chop their trees – for even the Zoró, the most aggressive loggers among the local indigenous communities, maintain their forest better than do their non-indigenous neighbors. Ultimately, the greatest threat to indigenous lands – here and around the world – isn't logging, but the illegal conversion of forest to agriculture. Yet that conversion begins with the construction of access roads like the one connecting the three territories.

Last October, about 80 members of the Gavião gathered in their territory, not far from the road traversed by loggers, to weigh their options. Tired of poverty but unwilling to chop their trees, they look with envy on the Paiter-Surui and their ability to earn money by maintaining the forest. Can the same option work for them?

That's a question that the Coordinator of Indigenous Organizations of the Amazon River Basin (Coordinadora de las Organizaciones Indígenas de la Cuenca Amazónica, or "COICA") hopes to answer here. Based in Lima, COICA is a federation of indigenous organizations across Latin America. For the past three years, it's been exploring the creation of a financing mechanism called "Indigenous REDD+" (REDD+ Indígena Amazónico, or "RIA"), which aims to blend financing mechanisms like REDD+ (Reduced Emissions from Deforestation, Degradation and other land uses) with existing indigenous practices.

Igarapé Lourdes is one place it aims to pilot the initiative, and if it works it can change the lives of indigenous people across the Amazon.

The Arc of Deforestation

Sixty years ago, the Zoró, the Paiter-Surui, the Gavião and the Arara were isolated people of the Amazon, but today they're among scores of indigenous communities in the "Arc of Deforestation" – a boomerang-shaped band of destruction that sprawls across the southern and eastern edges of the Amazon Rainforest, representing the frontier of what was, just a century ago, a vast and unspoiled forest.



 The Arc of Deforestation stretches from the port city of Belém at the mouth of the Amazon to Brazil's border with Bolivia.

The Arc of Deforestation stretches from the port city of Belém at the mouth of the Amazon to Brazil's border with Bolivia.


It's a region of vital importance to the global climate, because indigenous territories of the Amazon hold nearly 30 billion tons of carbon, which would become 110 billion tons of carbon dioxide if it made its way into the atmosphere, contributing to climate change. That's a real possibility, because more than half of those trees are in danger of being destroyed, according to research by the Environmental Defense Fund (EDF), the Woods Hole Research Center (WHRC), and COICA.

In a paper entitled "Forest Carbon in Amazonia: The Unrecognized Contributions of Indigenous Territories and Protected Natural Areas", they looked at current threats, like the expansion of access roads, and concluded that roughly one-third of indigenous and protected territories are under "immediate threat" from illegal logging, mining, dams, and agriculture, while an additional fifth are under "near-term" threat.

More than 400 REDD projects around the world are currently protecting a forested area larger than the entire land mass of Malaysia, according to the latest Ecosystem Marketplace State of Forest Carbon Markets Report, and indigenous people across the Amazon have already laid the groundwork for successful REDD projects, although that wasn't their intent.

Indigenous REDD

Beginning in the 1990s, indigenous people across the Amazon began developing "Life Plans" – which are long-term development plans designed to cultivate indigenous economies built on sustainable, traditional practices like the harvesting of Brazil nuts or acai and the creation of handicrafts. All have struggled to get their plans off the ground, but in 2007 the Paiter-Surui achieved liftoff by embracing REDD and becoming, in a sense, modern-day forest rangers.

The Zoró, however, continued to embrace logging – leaving their Life Plan undeveloped – while the Gavião and Arara began implementing their Life Plans in 2004, only to see them stall for lack of funding.

The quality of Life Plans varies, but most describe land-use and governance programs that are, at the very least, compatible with REDD initiatives.

The Paiter-Surui and the Limits of Project-Based REDD

The Paiter-Surui concluded the world's first indigenous-led REDD project in June 2013, becoming the first such project to generate offsets by saving endangered rainforest under the Verified Carbon Standard (VCS). Several months later, they sold 120,000 tonnes of carbon offsets to Natura Cosméticos, a Brazilian cosmetics giant.

But what worked for the Paiter Surui in Mato Grosso might not work for all indigenous territories facing dire threats from deforestation. The Gavião and Arara of Igarapé Lourdes have been much better stewards of their forests than either the Zoro or the Paiter-Surui, and while all four communities – including the Zoró – have preserved their forests better than the non-indigenous settlers have, the people of Igarapé Lourdes have done the best job of all. Yet, ironically, this fact may keep them from fully utilizing REDD finance. The situation is something of a Catch 22: to earn carbon offsets to protect forests and fund the implementation of their Life Plan, the trees of today must face measurable, imminent destruction.

The Paiter Surui REDD project became a reality because they were able to demonstrate this risk of imminent deforestation – and thus reduced carbon storage – under a business-as-usual scenario called a "baseline".




So while a REDD project can help some indigenous peoples improve their stewardship of the land, it may not be applicable to the peoples of Igarapé Lourdes and certainly not the "uncontacted" indigenous peoples inhabiting wild, remote areas of the Brazilian Amazon. It is believed that nearly 70 such indigenous groups continue to live in isolation in the Brazilian Amazon alone, according to a 2007 estimate from Brazil's National Indian Foundation (Funai), higher than past estimates of about 40 groups. What's clear is that conflicts with miners, ranchers, farmers and loggers will increasingly force such groups to confront the world at large, and in particular, incursions for resource extraction.

In the same year of the above estimate, the Brazilian Institute of Environment and Renewable Natural Resources (Instituto Brasileiro do Meio Ambiente e dos Recursos Naturais Renováveis, IBAMA) forced hundreds of illegal settlers from the Uru Eu Wau Wau indigenous territory in Rondônia – where uncontacted groups are believed to reside.

Dealing With a Funding Dilemma

If it's not possible to emulate the Pater-Surui, how do people like the Gavião and Arara resist logging and other short-term resource extraction pressures that are sure to increase in time? And what of the indigenous peoples who remain uncontacted, living in remote areas?

The challenges ahead to protecting the forests of such unexplored indigenous areas are immense: across the Brazilian Amazon today, about 15 percent of indigenous territories have still not been even been defined with boundaries or officially demarcated.

"All across the Amazon, we have indigenous people crying out for help to defend the forest," said COICA head Juan-Carlos Jintiac at recent year-end climate talks in Lima, Peru. "But because they had no deforestation, they had no access to REDD finance."

In light of the importance of indigenous territories to the planet's carbon stocks and the current threats to such a resource, how can these many good stewards of the forest be rewarded for what they are doing? More precisely, how to fund the life plans that are so central to developing an enduring sustainable economy?

Where to Get the Money?

One alternative path forward is for states to seek REDD finance for reducing deforestation across their entire jurisdiction, and then distributing the funding in-state as they see fit. The tiny state of Acre, to the west, of Rondônia, has pioneered this "jurisdictional" approach to REDD and is rewarding indigenous peoples with funds for good forest stewardship. The money comes into the state as REDD finance, but is distributed internally for activities that conserve water and protect endangered species.


 



The premise is this: good forest management and carbon sequestration go hand-in-hand, but payments for one ecosystem service will result in benefits to another – and for indigenous people, there is a chance to resurrect their traditional practices built on sustainable resource extraction, eco-tourism, and handicrafts.

In 2013, the German development bank KfW committed to financing the reduction of 8 million tons of emission reductions from Acre in a four-year, $40-million agreement – the first ever payment for emissions reductions at the jurisdictional level. Such payments are to flow from the state government to indigenous groups and communities based on a variety of activities under Acre's State System of Incentives for Environmental Services (known as "SISA").

Deforestation in the Amazon Rainforest

Beyond REDD, there are other potential sources of funding. One could come from municipal and state levels via the federal ICMS Ecológico (Ecological Tax on Goods and Services / Imposto sobre Circulação de Mercadorias e Serviços Ecológico) program, which allows local governments to access a refunded portion of the value added tax collected in their states, based on the amount of forest cover and water resources in their jurisdiction. To date at least 24 Brazilian states have passed laws or are debating legislation related to creating a green value-added tax.

Other Shades of REDD

Acre is both an innovator and outlier — the jurisdictional REDD solution pioneered there is not a fit for many other states in the Brazilian Amazon, where much larger populations and vastly more diverse deforestation pressures continue to converge. That said, some form of jurisdictional REDD administered from the state level is moving forward across much of the Brazilian Amazon.

At least four other Brazilian states have embarked on statewide REDD programs, and each is unique: Mato Grosso, which destroyed its forests at a devastating rate to make way for soybean production, has slashed its rates 90% and created the country’s most advanced regime for keeping track of REDD payments. Meanwhile deforestation is picking up in states that have historically had little deforestation, like Amapa.

Consider Rondônia itself, home to the Zoro, the Surui, and the indigenous peoples of the Igarapé Lourdes territory, where discussions to create a state-wide jurisdictional REDD system, with state and municipal government support, have already started.

As COICA and the people of Igarapé Lourdes further explore the potential for Indigenous REDD+ (RIA), jurisdictional efforts operating outside carbon markets may prove to be the most viable funding source.

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2014: The Year in Forest Carbon

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2014: The Year in Forest Carbon

How to measure a year? You’ll have to wait for our data collection to conclude in the New Year to find out how many tonnes of forest-based emissions reductions were financed in 2014, but for now we’ll take stock of the year’s major developments, which ranged from the triumphant to the tragic.

Please rank the top forest carbon stories of 2014 and give us your 2015 predictions here.

26 December 2014 | If you had told the Earthlings of 10 years ago that we would soon be watching deforestation occur in almost real-time on our smartphone screens, most would not have believed you. But here we are in 2014 with Global Forest Watch at our fingertips – an exciting tool that also highlights the complex, global nature of the fight to keep forests intact in a climate-changing world.

This past year was also one of new pledges to end deforestation, many of them by unusual suspects and many of them including encouraging financial commitments.

But the murder of four Ashaninka leaders – Edwin Chota Valera, Leoncio Quincima Meléndez, Jorge Rios Perez and Francisco Pinedo – in Peru in September followed by the killing of Shuar leader José Isidro Tendetza Antún in Ecuador weeks before the United Nations climate negotiations in Lima puts a tragic spotlight on the fact that protecting the world’s tropical forests is often life-threatening work. And indigenous peoples are the ones on the front lines.

Big promises

After 400,000 demonstrators took to the streets during the People’s Climate March in New York City in September, governments, multinational corporations, civil society and indigenous peoples issued the New York Declaration on Forests, committing to cut forest loss in half by 2020 and completely end it by 2030. The pledge, if successfully implemented, would reduce global emissions by between 4.5 billion and 8.8 billion tonnes of carbon dioxide each year, and it came with a promise of $1 billion in funding.

Many of the corporate signatories of the New York Declaration are members of the Consumer Goods Forum – companies such as Unilever, Nestlé, and Walmart that source much of the palm oil, soy, and other agricultural commodities that drive a $1.4-trillion annual business… and deforestation. In fact, a report released by Forest Trends this year found that almost three-quarters of deforestation between 2000 and 2012 was caused by commercial agriculture, a significant shift from the timber industry that drove the majority of deforestation in the 20th century.

Facing global pressure, these consumer goods companies made a flurry of “zero deforestation” commitments in 2014, to the point that 60% of the global palm oil trade is now controlled by companies that have committed to eliminating deforestation and human rights violations from their supply chains.

REDD scaling up

Buyer interest in avoided deforestation (REDD) offsets tripled to total 24.7 million tonnes in 2013, according to Ecosystem Marketplace’s State of the Forest Carbon Markets 2014 report. About a third of that volume came from a $40 million agreement between the state of Acre in the Brazilian Amazon and German development bank KfW as part of the REDD+ Early Movers Program.

After spending three years developing its payments for ecosystem services framework, Acre is beginning to see the first payments – about $2.9 million – flow to the local agroforestry association in the region that is managing its REDD activities. The money comes from KfW as payments for emissions reductions, and 70% of it is earmarked specifically for the providers of ecosystem services, including rubber-tappers and indigenous peoples.

Though the remaining two-thirds of REDD offset demand came mainly from companies pursuing corporate social responsibility targets, the government-to-government deal marked the type of “jurisdictional” or state-scale initiative that is likely to become more common in the future. Indeed, during the UN Conference of Parties (COP) in Lima in December, the REDD Early Movers expanded to Colombia and Ecuador, with Norway joining in on the funding side. Colombia and Ecuador each has the opportunity to earn about $65 million if they successfully reduce emissions from deforestation over the next three years.

Though Indonesia surpassed Brazil to earn the infamous spot as the world’s top deforester, the country also achieved some important capacity-building last year, creating the world’s first REDD+ agency and naming Heru Pratseyo as its head in January. Pratseyo is now attempting to save the country’s peat forests – which contain eight times the carbon content of other rainforests – by engineering a massive land-swap, essentially by convincing palm oil producers to move their operations to degraded land.

Show them the money

Rainforest nations say they are poised to do much more – if financing materializes. Governors from 13 states that are members of the Governors’ Climate and Forests Task Force, a group committed to scale up jurisdictional REDD, signed the Rio Branco Declaration in August, committing to cut deforestation 80% in their territories by 2020 if they are compensated for the emissions reductions.

With the Green Climate Fund surpassing the critical $10 billion threshold this month, REDD proponents are jostling to see if they might be able to carve out a space for avoided deforestation. The Fund’s Director indicated that forestry projects are attractive, but given the pressure to get some projects off the ground before the Paris COP negotiations next December, REDD proposals must be simple enough to be fast-tracked.

The World Bank’s Forest Carbon Partnership (FCPF) also had a busy 2014, selecting 11 new countries – Belize, Bhutan, Burkina Faso, Cote d’Ivoire, the Dominican Republic, Fiji, Nigeria, Pakistan, Sudan, Togo and Uruguay – and allocating $191 million in REDD+ readiness grants. FCPF’s Carbon Fund, which will offer payments for achieved emissions reductions, now amounts to $470 million. Eleven countries have submitted ideas for Emissions Reductions Programs, and three – Costa Rica, the Democratic Republic of Congo, and the Republic of Congo – have so far signed letters of intent.

On the private sector side, the Althelia Climate Fund made its first direct investment in 2014, pledging $10 million to the Taita Hills REDD project in Kenya developed by Wildlife Works. In May, The United States Agency for International Development guaranteed Althelia for up to $133.8 million in commercial finance for forest conservation and sustainable land use though a new mechanism that seeks to de-risk these types of investments.

California dreamin’

The Yurok tribe in northern California became the first organization to get compliance forestry offsets –more than 800,000 of them – approved by California’s cap-and-trade program in April. The same month, the state’s Air Resources Board (ARB) decided to shift the risk of invalidated offsets to buyers (rather than sellers) of compliance forestry offsets, putting it in line with other offset protocols.

And, with support from the Walt Disney Company, the community of San Juan Lachao in Oaxaca, Mexico developed the first pilot carbon offset project under the Climate Action Reserve’s Mexico Forest Protocol. The protocol was developed to be adaptable into a national Mexican REDD+ program in the future, with the potential of linking with California.

Chiapas, Mexico and Acre, Brazil signed a memorandum of understanding with California to coordinate around REDD back in 2012 and ARB officials have said they would consider accepting international offsets into the program, although they have not yet set a date for doing so. If California moves forward, it could become the first compliance market for REDD offsets.

The people’s forest

A study released this year by the World Resources Institute and the Rights and Resources Initiative found that rates of deforestation are, on average, 11 times lower in community forests with strong legal recognition, and indigenous people have official rights to about an eighth of the world’s forest area.

Buyers of forest carbon offsets have sent a strong signal that, in addition to verified emissions reductions, they are interested in the community and biodiversity benefits of forest protection – indeed, these “beyond carbon” benefits are sometimes what interests them about offsetting in the first place. Starting in November, the Verified Carbon Standard assumed the day-to-day management of the Climate, Community, and Biodiversity Standards to ease the pathway for the many projects that are already using both carbon and co-benefits certifications.

These verification standards, alongside remote sensing tools like Global Forest Watch, are evidence that we are now living in the Anthropocene – a new geological epoch in which humans have so fundamentally changed Earth’s systems that their management rests in our hands.

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California Regulators Bump Rice Offsets, Forestry Updates To 2015

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California Regulators Bump Rice Offsets, Forestry Updates To 2015

California once again delayed the potential adoption of a new offset protocol for rice cultivation projects, as well as proposed updates to its forest protocol, to 2015 as stakeholders urged regulators to go back to the drawing board on a few particular elements. Meanwhile, regulators took some flak for the market uncertainty created by their recent invalidation of ozone-depleting substances offsets.

23 December 2014 | The California Air Resources Board (ARB) delayed the potential adoption of a new rice cultivation protocol – the first crop-based methodology considered by the ARB – as well as proposed updates to the forestry protocol to 2015 amid controversy about the planned revisions.


The rice cultivation protocol promotes eligible practices that reduce methane emissions from rice cultivation, such as switching from wet seeding to dry seeding and early drainage in preparation for the harvest in California. The ARB projects potential offset supply under the new protocol in the range of 500,000 and 3,000,000 tonnes of greenhouse gas reductions through 2020 – the scheduled end date for California's cap-and-trade program.

Board consideration of the rice cultivation protocol has been delayed several times due to questions raised by stakeholders about the environmental integrity of the offsets, namely the potentially destructive impact on the habitat of bird populations. But the updated protocol incorporated safeguards against negative impacts on migratory birds such as the exclusion of offsets from rice cultivation within the Butte Sink Wildlife Management Area – a critical habitat – and bans a particular project activity even though the practice could generate additional offset supply.

Robert Parkhurst, Director of Agriculture Greenhouse Gas Markets for the Environmental Defense Fund, praised several elements of the proposed protocol, including the ability of farmers to cooperate and aggregate their emissions reductions into a single project and the ability to perform risk-based and randomized verification since verification is typically responsible for 50% of the total project development cost.

"I think the protocol is in really good shape as it is," he said.

The Rice is Still Simmering

In the days leading up to the hearing, several stakeholders urged the ARB not to proceed with the rice cultivation protocol without making substantial revisions. Leslie Durschinger, Founder and Managing Director of project developer Terra Global Capital, encouraged the ARB to include a stronger and clearer consolidation option. While the protocol was moving in the right direction in allowing consolidation of projects and related reports, the system as proposed did not support the level of consolidation necessary to make the rice protocol economically viable for growers to adopt, she said.

In March, the American Carbon Registry listed the first rice project, which aggregates rice growers over a 5,000-acre area in California's Sutter, Colusa and Glenn Counties to reduce the equivalent of 6,700 tonnes of carbon dioxide emissions.

The American Farmland Trust (AFT) identified issues related to the calculation of emission reductions of rice cultivation projects that could reduce the amount of reductions credited to the grower, perhaps unnecessarily, said James Daukas, Vice-President, Programs.

However, the evaluation and the eventual approval of the rice cultivation protocol is critical for future consideration of nutrient management, wetlands and grassland protocols that stakeholders would like the ARB to adopt to expand potential offset supply, Parkhurst said - a sentiment echoed by others.

"The rice protocol has set the stage for a lot of additional protocols from agriculture," he said.

In the Land of the Midnight Sun

Stakeholders speaking at the board hearing expressed widespread support for the inclusion of forestry projects located in Alaska in California's program. Currently, forestry projects providing offsets to California's program are required to be based in the lower 48 US states.

The ARB did not allow Alaska-based projects when considering early- action methodologies and programs in 2011 because of the absence of data from the Forest Inventory and Analysis Program of the U.S. Forest Service. Now having access to such data, the ARB staff has proposed allowing Alaska-based forestry projects into the program. But more revisions must occur before the proposal becomes official such as revising the approach for establishing baselines for improved forest management projects on public lands.

Removing the ban on Alaska-based offset projects from the cap-and-trade program would give the native populations in the state an alternative to timber harvest and reward sustainable forest management, said Sheri Buretta, Chairman of the Board Chugach Alaska Corporation.

"Alaska forest carbon offset projects could generate millions of offsets while achieving social, environmental and economic benefits to our Alaska native populations," she said. "The data was not available when the program first started and now it is."

A Chilling Effect

Foresters and forest carbon project developers, however, objected to several proposed technical updates to the forestry protocol, including planned changes to standards for even-aged management of forest stocks.

The proposal would have a "chilling effect" on the participation of even-aged-managed forests because it would create a substantially larger and longer-term buffer that is inconsistent with the requirements of the California Forest Practice Act, argued Gary Rynearson, a professional Forester with Green Diamond Resource Company, which owns and manages forest lands in Washington and California.

"These excessive buffers go far beyond prescriptions recommended," said Roger Williams, President of Blue Source, which has registered 44% of the forest carbon offsets issued by the ARB to date. "Our proposed solution is to maintain the existing protocol language. The existing language was carefully developed over a 5-year period by a diverse group of expert stakeholders and should not be abandoned."

Buyers' Liability Still a Thorny Issue

The buyers' liability provisions were a major topic of conversation following the ARB's decision to invoke the invalidation provisions featured in the state's cap-and-trade program for the first time in November. The ARB invalidated 88,955 offsets for ozone-depleting substances, but limited the invalidation to one particular carbon offset project by developer EOS Climate generated at the Clean Harbors facility in Arkansas.

Thursday's hearing marked the first time when stakeholders were able to voice their concerns about the final invalidation directly to board officials in a public hearing and they were not shy about raising their objections. A consistent theme revolved around the fact that the ARB invalidated the offsets for an alleged violation unrelated to the actual generation of the offsets, which represented real, quantified and verified emissions reductions by the ARB's own admission, and the need for the ARB to provide specific guidance about the circumstances that would trigger a violation.

Adam Smith, ‎Program Manager of Climate and Air Policy at Southern California Edison, said the lack of clarity in the invalidation rules creates problems for developers, registries and entities regulated under the cap-and-trade program.

The International Emissions Trading Association (IETA) recommended modifications to clarify that only activities in the offset project area could potentially trigger invalidation and that only a confirmed formal violation notice should trigger an invalidation investigation.

"It remains unclear what exactly constitutes a violation," said Josh Strauss, Director of Forest Carbon Projects for project developer Blue Source, speaking on behalf of IETA. "IETA believes it is extremely important to ensure that violations unrelated to actual offset project activities are not grounds for invalidation."

IETA also suggested a modification that specifies that only offsets generated during the period of an actual violation could be subject to invalidation rather than all offsets generated during the entire reporting period.

ARB board members appeared receptive on the need to offer guidance on the type of violations that would rise to the level of offset invalidation even as they acknowledged the difficulty in providing such guidance.

"I think that's going to be a thorny issue, but it's something that needs to be worked on," said ARB board member Judy Mitchell.

"It's not an easy job and it's a slippery slope, but what's going to be in front of Mr. (ARB Executive Officer Richard) Corey is a whole slew of possible invalidations," said ARB board member Sandra Berg.

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