forest.,	D 

rn

^ 

r 

`c^- C ^^ -, -^ C	

- m^ w	^ 

;-,	..	J

^ 

C L I MATE 

A C T 1 O N 

RESERVE 

^ 

s

PACIFIC FOREST TRUST 

PT

DAIL ItEADING FIi.E 

^ NewForests 

columbia 

FOREST PRODIJCTS° 

THE 

CONSERVATION FUND

NATIONAL WOODLAND 

UNYpW`NFR OWNERS ASSOCIATION 

FiniteCarbon 

^ Co r

y

nsevation 

Forestr , LLC 

NEW ENGLAND FORESTRY FoUNDATION 

c,,..,..,a.,^ r,...,^, ^.., r..^.., i;.•.^.•..,^^..... 

lk;i BlueSource" 

Gina McCarthy 

Administrator 

Environmental Protection Agency 

1200 Pennsylvania Avenue, N.W. 

Washington, DC 20460 

May 27^ 2014 

Dear Administrator McCarthy:

As forest landowners, scientists, businesses and NGOs, we write to express our 

support for the inclusion of compliance-grade forest emissions reductions 

projects equal to those used by the California Air Resources Board (CARB) in the 

EPA's upcoming rulemaking regarding greenhouse gas (GHG) emissions from 

power plants. Such forest emissions reductions will provide both flexibility and 

clear, enduring atmospheric benefits. 

Further, such offsets would help reduce a major source of CO, pollution 

nationally by incentivizing the avoided conversion of private forests. The US has 
lost over 1 million acres of forestland azunually to conversion over the last 20 

years. This is equivalent to the emission of over 2.6 billion tons of CO,e, not 

counting the foregone sequestration benefits those forests would have provided 

had they not been lost. 

While there are a variety of voluntary forest carbon offset credits available, given 

the regulatory nature of the deliberation before you we urge you to utilize forest 

carbon offset standards that are at least as strong as California's. CARB's forest 

emissions reduction protocols were developed for a working forest setting where 

ongoing harvest occurs, providing for the growing demand for sustainable wood 

products. Forest landowners from the large (such as the Forestland Group) to 

the small (such as individual landowners like Keith Argow) and in between 

(such as the Yurok Tribe in northern California) are using these protocols, 

demonstrating their practicality in a variety of settings. 

Further, working with the CARB standard means that EPA will not need to 

"reinvent the wheel" and answer difficult questions that surround offset projects 

that have been resolved to a regulatory compliance standard. Doing so also 

ensures the continued success of the regulatory carbon market, keeping things 

clear for both buyers and sellers of emissions reductions. 

Backgroacr2d oti Califorrnia's offset progi-avi 

California's Global Warming Solutions Act (AB32) sets the parameters for using 

forest carbon offsets in California's compliance market. The implementation of 

AB32 and the cap and trade mechanism have been remarkably successful over 

the last two years. Since the beginning of GHG allowance auctions in late 2012, 

over $1.6 billion in allowance credits have traded hands. Forest carbon offsets 

have played a key role in this marketplace, with over three million tons of COze 

credited to forest carbon offset projects now being used to help the state meet its 

GHG emission targets. 

The climate, policymakers, businesses and residents can all be assured that when 

a forest offset credit is sold in California's compliance market it is as effective as 

eliminating a ton of GHGs at the smokestack. This guarantee can only be made 

in the context of rigorous legal standards for offset projects. 

Tlie fiiture of forest offsefs iu Califorizia's corriplianee »Tarket 

EPA's rulemaking will doubtless have effects on California's pioneering efforts. 

Importantly, if the EPA were to allow states to use offsets that were of a weaker 

standard than California's, it would cause considerable confusion in the 

marketplace as well as place pressure on California to ratchet down its existing 

offset standards. 

Indeed, a weaker offset standard could threaten the utility of offsets in 

compliance markets in general. Significant criticism of offsets would likely flow 

if only a few individual projects were found to be ineffective in providing actual
emission reductions. This is a risk that California's strong offset standards help 

to avoid. 

Conchision 

Forest carbon offset projects have enormous potential to capture and store GHG 

emissions from existing power plants in a cost-effective manner with significant 

environmental co-benefits. Realizing the potential of forest offsets requires the 

implementation of rigorous standards already developed for the most successful 

compliance carbon market. We recommend that EPA include forest carbon 

offsets as a tool for states to use when crafting their implementation plans, and 

that EPA ensure that any forest offsets used by states comply with standards as 

strong or stronger than those used by California. Dr. Jerry Franklin, noted 

member of the American Academy of Arts and Sciences has trenchantly noted 

that doing less would in fact be airet lrnrm to the atmosphere. 

Thank you for your attention to this letter. 

Sincerely yours, 

Laurie Wayburn Dr. Jerry Franklin 

President and co-CEO Professor of Ecosystem Analysis 

Pacific Forest Trust University of Washington 

Evan Smith Tim Schallich 

Vice President, Conservation Ventures Columbia Forest Products 

The Conservation Fund 

Alexander Evans, PhD. 

Interim Executive Director 

The Forest Guild 

Keith A. Argow PhD., CF 

President 

National Woodland Owners 

Association (NWOA) 

Kent Gilges 

President 

Conservation Forestry 

Sean Carney 

President 

Finite Carbon 

Roger Williams 

President 

Blue Source

Dr. Mark Harmon 

Professor and Richardson Chair of 

Forest Science 

Oregon State University 

Timothy Robards 

Manager, Investments & Operations 

New Forests, Inc. 

Robert Perschel 

Executive Director 

New England Forestry Foundation 

Gary Gero 

President 

Climate Action Reserve
3 z^ 

tU `^ ^ 7 4 

W (:) M ^ N 

3 w O ^ I 0 d' N V 

Lu 

Im	^ 

> O ^ LLJ 

^ 0 

0 < a 

N 

t'^^

^ ^ ^ ^ LL W

^ (7 

-4i►N0 o o '2

^ U 

^ ^ V 

w<. ^; ^

^. 

^^ 

V) 

^ ^- 

^ Ln LL] ^ 

0 

Ll.. 

V_ 

LL 

V Q ^

"qw ,iL 

it 

^ 

H 

c N O 

O > ^ v^i 

G Tu o w 

— —oo c 3 

cn

3

^d N 

C`-

2

z 

(

	^^ 7Z o 

c^	^► ^ J ,9 c '

-2 

Z ^

C) 

^`

¢ 3

,^. 

i^#