Bad Trade: International Forest Offsets and California’s Carbon Market

7/28/2019 Bad Trade: International Forest Offsets and Californias Carbon Market

1/7

)RRG:DWHU:DWFK36WUHHW1:6XLWH:DVKLQJWRQ'&ZZZIRRGDQGZDWHUZDWFKRUJ

IU5V]LTILY*HSPMVYUPHZ(PY9LZV\YJLZ)VHYKH\J[PVULKVMM[OLYZ[YV\UKVMJHYIVUWLYTP[ZMVYP[Z]VS\U[HY`JHWHUK[YHKLTHYRL[^OPJOVMJPHSS`^LU[SP]LVUJanuary 1, 2013. This initiative came out of California Assembly Bill 32, the Global

Warming Solutions Act, which sets a goal of lowering greenhouse gas emissions to

1990 levels by 2020 (a reduction of about 30 percent).1

Under his regulaion, polluers can mee heir emissions

reducions hrough hree opions: reducing emissions, rad-

ing emissions allowances or using ofse credis or emissions

reducions ouside o he cap.2 Caliornia is he irs saeo have a cap-and-rade marke or greenhouse gases in he

Unied Saes.3 Many policymakers are looking o he saes

marke as a es or a naional model.4

Cap-and-rade markes, however, are no he soluion o emis-

sions reducions ha hey preend o be. They do no produce

real reducions in greenhouse gas emissions and pose serious

problems or common resource managemen. The privaiza-

ion and inancializaion o naure is synonymous wih hese

markes, and he numerous opporuniies or corrupion

urher weaken heir legiimacy as real soluions or reducing

emissions. In paricular, he use o ofses poses signiican

problems in Caliornias new marke.

%DFNJURXQGRQ2VHWVDQG5(''An ofse is a radable credi represening reducions in green-

house gas emissions ouside o he eniies covered by he

cap-and-rade marke.5 Through ofses, a polluer can pay o

preven emissions ouside o he cap, in lieu o reducing emis-

sions a he source.6 So ar, Caliornias cap-and-rade marke

has approved our caegories o domesic ofses, and each

0U[LYUH[PVUHS-VYLZ[6MMZL[Z

HUK*HSPMVYUPHZ*HYIVU4HYRL[


2/72

polluer will be allowed o mee 8 percen o is emissions

reducions wih ofses.7

For example, a polluer in Caliornia could pay or a secion o

ores o no be cu down in Oregon. This would coun oward

he polluers required reducions even hough emissions are

no reduced in Caliornia bu are in heory prevened in Or-

egon. Because rees sore carbon bu also release greenhouse

gases ino he amosphere i hey are cu down, hen no cu-

ing down rees is considered an ofse.

In addiion o he domesic ofses already approved, Calior-

nia is considering he uure inclusion o inernaional ores

ofses. These would come rom programs like he Reducion

o Emissions rom Deoresaion and Degradaion (REDD+),

which has he added purpose o conserving and enhancing

ores carbon socks and susainably managing oress (he +

in REDD+).8

REDD+ programs are carried ou in developing counries wih

signiican ores cover, like Brazil, Indonesia and many oh-

ers.9 Through inancial incenives, landowners are paid o nocu down oress and insead proec hem. Wha Caliornia

would do is sell credis or preserved oresland rom REDD+

programs. This would be one o he irs cap-and-rade

programs o allow inernaional ores ofses rom REDD+

iniiaives.10

The use o ofses is problemaic, as is REDD+, and i Calior-

nia goes hrough wih acceping hese ofses in is cap-and-

rade marke, he impacs could be serious. REDD+ ofses

lead o he inancializaion and privaizaion o naure. In

addiion, oress usurped ino REDD+ programs become of-

limis o he indigenous communiies ha have lived here or

decades and have susainably managed he oress wihou

inancial incenives.

Moreover, signiican concern has been voiced abou ores

ofses. Some criics quesion he wisdom o enrusing he

worlds las ropical oress o he insabiliy o proi-led

global commodiy and rading markes ha have proven o

be highly unsable and unpredicable and hisorically sufer

rom drasic boom and slump cycles.11 Ohers argue ha of-

ses do no reduce emissions, bu raher move he reducions

elsewhere, usually o counries in he global Souh where i is

less expensive o make he reducions.12 Polluion coninues a

he source while i is assumed ha reducions are made a he

ofse locaion, which may or may no be he case.13

Generaing ofses rom REDD+ programs exposes vial ores

resources o inancial markes ha have no regard or he

inrinsic value o biodiversiy, conservaion, susainable man-

agemen and he necessiy or common resources o remain

under public conrol. Unorunaely, here is a real chance haREDD+ ofses could make i ino he Caliornia marke, as

recen analyses show ha exising domesic ofses will no

mee demand, whereas he inclusion o REDD+ ofses could

mee his demand and even exceed i.14

2VHWV$/LDELOLW\To qualiy as an ofse, one credi mus equal one meric on o

greenhouse gas emissions.15 Ofses are essenially a loop-

hole in real emissions reducions, because hey do no reduce

emissions a he source, and are hereore a serious liabiliy.


3/73

As he U.S. Governmen Accounabiliy Ofice (GAO) repors,

In heory, ofses allow regulaed eniies o emi more while

mainaining he emissions levels se by a cap and rade pro-

gram or oher program o limi emissions.16

Ofses mus mee a series o requiremens in order o be

valid requiremens ha are oen hard o mee and veriy.

These include proving ha an ofse is real, addiional, per-

manen, quaniiable, veriiable and enorceable.17 These are

deined as:

Real:There mus be evidence ha he ofse is boh appro-

priae and accurae;

Permanen:The ofse mus be irreversible;

Addiional:Emissions reducions mus exceed (be in addi-

ion o) hose required by law, and mus exceed reducions

ha would oherwise occur in a business-as-usual scenario;

Qaniiable:I mus be possible o accuraely measure and

calculae he emissions reducions produced by an ofse,and o be able o replicae he indings;

Veriiable:The emissions reducions rom an ofse mus be

moniored and documened; and

Enorceable:There mus be srucures o accounabiliy

in place and a body ha oversees and enorces hese

requiremens.18

Meeing hese requiremens is challenging, especially wih

regard o REDD+ ores ofses. Firs, guaraneeing perma-

nence is very dificul.19 Trees can easily be cu down, dam-

aged by ire or desroyed hrough oher naural disasers.20 A

Congressional Research Service repor suggess ha ofses

could come wih assurances ha i somehing compromised

he ofse i would be resored.21 However, his conradics he

poin o requiring permanence and presens anoher loophole

in ofse compliance.

Second, esablishing a baseline o greenhouse gas emissions

is very dificul, ye i is a vial componen.22 Baselines are

needed o compare prediced reducions o wha would have

happened wihou he ofse program. Wihou his com-

parison, deermining emissions reducions or he amoun o

carbon sequesered is nearly impossible.23

Baselines are also needed o esablish addiionaliy, he re-

quiremen ha reducions be in addiion o wha would havehappened i no acion were aken. This requires deermining

wha he emissions levels would have been wihou an ofse

program.24 Wihou a properly calculaed baseline, i is di-

icul o deermine addiionaliy, and non-addiional ofses

have already been awarded under exising programs, meaning

ha real reducions may no maerialize.25

Third, here is a signiican risk or leakage o occur. This

happens when emissions conrols cause polluion o shi

elsewhere, leading o reduced emissions in he locaion under

regulaion and increased emissions in unregulaed areas.26 The

polluion hereore leaks rom one area o anoher. For ex-

ample, i a counry agrees o proec is oress, logging com-

panies could move o unproeced land and carry ou logginghere. I his happens, he oal level o prevened deoresa-

ion and emissions would be unchanged, because he leakage

elsewhere cancels ou he reducions in he regulaed area.27

A ourh complicaion o ofses is ha hey cause disorions

in price signals and incenives o reduce emissions wihin he

polluion marke. I he marke is o work as supporers sugges

i will, hen marke signals mus be able o drive prices in order

o drive reducions in polluion ha is now le o he marke,

insead o regulaion. I oo much emphasis is placed on he use

o ofses o achieve reducions, he proper price signals are no

sen o polluers o reduce emissions a he source and subse-

quenly o inves in he necessary echnology o do so.28

This complicaion can be atribued o he disorionary naure

o ofses, which serve primarily o make compliance wih

reducion requiremens less expensive, raher han inceniviz-

ing polluers o reduce emissions a he source.29 Again, ofses

represen a loophole ha undermines real emissions reduc-

ions, urher perpeuaing he problems caused by green-

house gas emissions.

Finally, measuring emissions reducions is anoher challenge,

and ores projecs are he mos conroversial ype o ofse


4/74

because so many issues exis in ensuring heir inegriy.30 The

only way o atemp a good measuremen is direc monioring

hrough various ools.31 However, direc monioring is no always

atainable or economical, and does no accoun or he impacs

o leakage.32 This conradics he promoed purpose o ofses o

keep compliance coss low or emissions reducion markes.

While ofse credis migh be cheaper per credi han rading

emissions allowances, he process o esablishing ha ofses

are valid and legiimae is highly cos prohibiive. I he only

way or ofses o work is hrough exensive monioring and

evaluaion sysems ha require subsanial unds o operae,

hen ofses do no ofer a cos-efecive marke opion or re-

ducions. Insead, he law should be enorced and require ha

polluers direcly reduce heir emissions.

7KH'DQJHUVRI5(''The iniial REDD concep is based on he premise ha deor-

esaion and degradaion occur because no economic value is

placed on oress excep as lumber or poenial agriculural

land. By providing inancial incenives o proec oress, i

is hough ha his will solve problems o deoresaion and

degradaion.33 However, many indigenous communiies worry

ha moneizing oress hrough REDD+ iniiaives will lead o

land grabs by large corporaions or he governmen, a problem

ha has already occurred in rial projecs.34

Rainoress are home o millions o indigenous peoples and

ores communiies ha subsis on he resources o he or-

es.35 These communiies have successully managed and con-

served oress or cenuries, wihou degrading or deoresing

hem, because hey depend on he oress or heir livelihood

and long-erm wellbeing.36 Ye REDD+ programs raise many

concerns abou indigenous righs, land enure, ores gover-nance and corrupion.37

Indigenous peoples are oen orced of heir land and prohib-

ied rom heir long-esablished use o he oress when he

governmen or oher groups become involved in ores man-

agemen.38 The oress become privaized and are no longer in

he hands o he communiies ha have long resided here.

Concerns have also been raised ha REDD+, which rewards

polluers, gives only marginal beneis o he indigenous com-

muniies ha have susainably managed oress.39

Unorunaely, in many counries wih vas holdings o ropi-

cal ores, he governmens oen do no recognize indigenous

righs or ancesral oreslands.40 Fores communiies have

lived on oreslands or decades wihou legal ile o i, and

many cases exis where governmens will declare his uniled

land propery o he sae.41 As a resul, indigenous communi-

ies are kicked of heir land.42

A primary concern is ha he proecion o ores carbon

reserves will be placed above he proecion and righs o or-


5/75

es peoples.43 REDD+ programs sand o generae signiican

income or governmens, incenivizing leaders o ignore land

dispues in oresed areas and o suppor REDD+ iniiaives

over indigenous righs.44 This shis governmen accounabiliy

away rom he ciizens o he inancial beneis o REDD+ i

pus prois over people.

Looking speciically a ofses rom REDD+ iniiaives, many

problems and limiaions persis. Developing counries oen

do no have access o he resources necessary o implemen,

monior and enorce he rules.45 Problems o permanence and

esablishing a baseline are also ormidable challenges.46 In ad-

diion, because each counry has diferen legal rameworks,

issues arise wih veriicaion.47 The measuremen echniques

are complex and cos prohibiive, documenaion o emissions

or avoided emissions can be inadequae and i is dificul o

esablish wheher projec developers have legal ownership o

he land in use.48

Ample opporuniies or corrupion exis as well, since here

are no incenives o correcly repor inormaion or inspec

ofse auheniciy i he baseline is oversaed, more ofses

can be produced.49 There is also a risk ha ofse buyers will

enorce heir own crieria or ores governance ha could

jeopardize he livelihoods o indigenous peoples and ores

communiies.50

Finally, REDD+ by isel and as an ofse poses serious risks

or he privaizaion and inancializaion o naure. Ataching

inancial incenives, like ofses, o REDD+ programs could

cause owners o oresed land, primarily governmens, cor-

poraions and conservaion organizaions, o cu up racs o

ores ino proeced, privaized areas.51 The Unied Naions

REDD+ program (UN-REDD+) has even admited ha sev-

eral poenial ailings exis. These include he likelihood o

depriving indigenous and ores communiies o heir lands,

marginalizing hese communiies, undoing signiican prog-

ress in susainable ores managemen pracices and, mosimporanly, ha REDD+ programs could lock-up oress by

decoupling conservaion rom developmen.52

&DOLIRUQLDDQG5(''2VHWVSince Caliornia aces a poenial shorage o ofses or is

cap-and-rade marke, adminisraors have discussed us-

ing REDD+ ofses o keep compliance coss low.53 I REDD+

ofses become eligible in Caliornias marke, hey sand o

generae up o $2.2 billion.54 Caliornias marke would be one

o he irs o use hese, despie he ac ha oher markes

have rejeced using REDD+ ofses.55

This has happened in he case o he UN Clean Developmen

Mechanism (CDM).56 CDM is an ofses iniiaive ha issues

ceriied emission reducion credis (CERs) in developing

counries ha can be bough by indusrialized counries o

mee heir reducion arges. REDD+ credis are no ac-

ceped because o problems wih measuremen, reporing and

veriicaion (MRV), as well as wih accouning, addiionaliy,

leakage and permanence.57

In anicipaion o he possible inclusion o REDD+ ofses in

Caliornia, he Governors Climae and Foress Task Force


6/76

(GCF) was se up in 2008 and esablished Memoranda o

Undersanding (MOUs) wih Brazil and Indonesia.58 The

MOUs represen iniial agreemens o work wih Caliornia in

developing REDD+ ofses or use in he saes cap-and-rade

marke. Since hen, urher counries have become members

o he GCF, including Mexico, Nigeria, Peru and Spain, and

addiional saes in Brazil.59

Glaring problems emerge, however, when considering ofses

rom he counries oulined. For an ofse o be valid i mus

prove addiional, and he Caliornia Air Resources Board (ARB)

saes ha or an ofse o be addiional, emissions reducions

mus exceed hose required by law and exceed reducions ha

would oherwise occur in a business-as-usual scenario.60 Brazil

has a decades-old ores law ha serves o preven deoresa-

ion and conserve is ores reserves.61 Mos o he saes in

Brazil ha are members o he Task Force are in he Amazon,

and landowners in ha region are required by he Fores Code

o conserve 80 percen o oress on heir land. 62

Mexico and Indonesia boh have ores laws on he books as

well, which require ores proecion and conservaion.63 This

raises serious quesions abou how REDD+ ofses rom hese

counries will prove addiional. I canno be said ha he

reducions in deoresaion and degradaion, and he added

conservaion o oress resuling rom hese laws, would no

have happened wihou REDD+ ofse programs.

Furhermore, he poenial harm caused o indigenous com-

muniies by REDD+ ofses conradics he iniial inenions

o Caliornia when draing he regulaion or is cap-and-

rade marke. Under a secion called Requiremens or no ne

harm, he ARB saed, The sandardized mehodology mus

ensure ha he ofse projec ype does no cause or conrib-

ue o adverse efecs on human healh or he environmen.64

Unorunaely, his no longer seems o be a prioriy or Calior-

nia in he developmen o he marke. In Ocober 2012, indig-

enous leaders raveled o Caliornia and proesed he poen-

ial use o REDD+ ofses in he saes cap-and-rade marke.65

Many cied ha hey already ace persecuion, hreas and

unjus reamen a home or proesing he iniiaive.66 The

ARB will decide on he use o REDD+ ofses in 2013.67

Overall, he use o REDD+ ofses in Caliornias cap-and-rade

marke poses signiican problems and, i adoped, would lead

o he large-scale inancializaion and privaizaion o naure.

Foreslands would be of-limis o public use and add o he

alarming rend o moneizing naure or inancial gain.

5HFRPPHQGDWLRQVSupporers o alernaive mehods o manage oress poin o

a non-marke approach, called he Join Miigaion and Adap-

aion Mechanism (JMA), included under he Unied Naions

Framework Convenion on Climae Change.68 This approach

incorporaes public suppor and mehods or susainable

ores managemen, and srenghens governance.69 I also in-

cludes saeguards or he righs o indigenous peoples, parici-

paion o relevan sakeholders and ensuring ha JMA is no a

mehod or convering oress, bu or proecing hem.70

Bolivia has developed a proposal or JMA ha emphasizes he

use o local knowledge on ores managemen, addressing he

roo causes o deoresaion and reinorcing ha oress are no

commodiies.71 The primary goal o JMA is no carbon emis-

sions reducions, bu raher o proec he many uncions and

beneis o oress hrough he applicaion o beter land use

pracices and prevenion o biodiversiy loss, deoresaion and

degradaion.72 Foress do no need REDD+ programs o seques-

er carbon or preven emissions; hey already do his on heir

own when iniiaives ocus on ores inegriy over prois.

Given he serious implicaions or indigenous peoples and he

public managemen o ores resources, Caliornia should noallow REDD+ ofses in is greenhouse gas cap-and-rade mar-

ke. While he use o ofses migh make compliance more cos

efecive, he process o accuraely veriy hem is highly cos

prohibiive, so hey are no a easible marke opion overall.

Based on he myriad problems o ofses, and speciically o

REDD+ ofses, polluers should be required o direcly reduce

heir emissions wihou depending on loopholes o do so.

REDD+ ofses do no lead o real, addiional or permanen

emissions reducions, and hey mus no be allowed ino Cali-

ornias cap and rade marke.


7/7

(QGQRWHV1 Barringer, Feliciy. A Grand Experimen o Rein In Climae Change. The New York

Times. Ocober 13, 2012; Caliornia Assembly Bill 32, Subchaper 10 Climae Change,

Aricle 5, 95800-96023, Tile 17, Caliornia Code o Regulaions. December 21, 2011.

2 Fores Carbon Markes and Communiies, U.S. Agency or Inernaional Developmen

(USAID). Caliornia Climae Legislaion: Cap and Trade and Inernaional Fores

Carbon Ofses: Brieing paper or Ocober 30 Webcas The Caliornia Carbon

Marke and he Role o Inernaional Foress: A Primer on Risks and Opporuniies or

Insiuional Invesors. Ocober 30, 2012 a 2.

3 Eshelman, Rober S. Carbon ofse group parners wih Clinon Foundaion on Ma-

lawi ani-povery iniiaive. ClimaeWire. Ocober 17, 2012.

4 Barringer, 2012.

5 Air Resources Board (ARB), Caliornia Environmenal Proecion Agency. Background

and Descripion: Caliornias Cap and Trade Regulaion. A 2.

6 Gilberson, Tamra and Oscar Reyes. Dag Hammarskjld Foundaion. Carbon Trading:

How i works and why i ails. Criical Currens, no. 7. November 2009 a 11.

7 ARB, Proposed Regulaion o Implemen he Caliornia Cap and Trade Program. Par 1,

Vol. 1. Ocober 28, 2010 a III-5; Fores Carbon Markes and Communiies, USAID. 2012 a 2.

8 ARB. 2010 a III-26; Unied Naions Framework Convenion on Climae Change

(UNFCCC). Repor o he Conerence o he Paries on is sixeenh session, held in

Cancun rom 29 November o 10 December 2010. Decision 1/ CP.16. 15 March 2011.

Paragraph 70 a 12.

9 ARB. Overview: Preliminary Dra Regulaion or a Caliornia Cap and Trade Pro-

gram. November 24, 2009 a 80; UN-REDD Programme. UN-REDD Programme Par-

ner Counries. Available a htp: //www.un-redd.org/Parner_Counries/abid/102663/

Deaul.aspx. Accessed January 10, 2013.

10 Cosslet, Chris. Caliornia Leading he Way Towards REDD+ Carbon Markes. UN-

REDD Programme. UN-REDD Programme Newsleter, Iss. 16. February 2011; Teixeira,

Marcelo. Brazil akes legal acion agains ores carbon deal in Amazon. Thomson

Reuers: Poin Carbon. December 14, 2012.

11 Grifihs, Tom. Fores Peoples Programme. Seeing REDD? Foress, climae change miiga-

ion and he righs o indigenous peoples and local communiies. December 1, 2008 a 22.

12 Gilberson and Reyes. 2009 a 11.

13 Ibid. a 11.

14 Fores Carbon Markes and Communiies, USAID. 2012 a 2 o 3.

15 ARB. Background and Descripion: Caliornias Cap and Trade Regulaion. A 2.

16 U.S. Governmen Accounabiliy Ofice (GAO). Climae Change Issues: Opions or

Addressing Challenges o Carbon Ofse Qaliy. (GAO-11-345). February 2011 a 8.

17 ARB. 2010 a III-4.

18 Caliornia code 95802, secion a, 3. 2011. In Subchaper 10 Climae Change, Aricle 5,

Secions 95800 o 96023, Tile 17, Caliornia Code o Regulaions; Taylor, Mac. Sae o

Caliornia Legislaive Analyss Ofice. Evaluaing he Policy Trade-Ofs in ARBs Capand Trade Program. February 9, 2012 a 19.

19 Taylor. 2012 a 19 o 20.

20 Ibid. a 19 o 20.

21 Ramseur, Jonahan L. Congressional Research Service. Volunary Carbon Ofses:

Overview and Assessmen. (RL34241). November 7, 2007 a 4.

22 GAO. Climae Change: Observaions on he Poenial Role o Carbon Ofses in

Climae Change Legislaion. (GAO-09-456T). March 2009 a 17.

23 GAO. 2011 a 9.

24 Ibid. a Execuive Summary.

25 Ibid. a 8.

26 Gore, Ross W. and Jonahan L. Ramseur. Congressional Research Service. Fores

Carbon Markes: Poenial and Drawbacks. (RL34560). July 3, 2008 a 17.

27 Ibid. a 17.

28 GAO. 2009 a 9.

29 Fores Carbon Markes and Communiies, USAID. 2012 a 2.

30 Ramseur. 2007 a 5.

31 GAO. 2011 a 11.32 Ibid. a 11.


34 Ibid. a 59.

35 Ekl, Gran. Swedish Sociey or Naure Conservaion. New hope or he oress?

REDD, biodiversiy and povery reducion. (89542). 2011 a iii.

36 Ibid. a 2.

37 Ibid. a iv and 2.

38 Ibid. a 2.

39 Grifihs. 2008 a 19.

40 Ibid. a 21.

41 Sheikh, Pervaze A. and Ross W. Gore. Congressional Research Service. Inernaional

Foresry Issues in Climae Change Bills: Comparison o Provisions o S.1733 and

H.R.2454. (R40990). December 22, 2009 a 12.

42 Grifihs. 2008 a 21.


44 Grifihs. 2008 a 21.

45 Sheikh and Gore. 2009 a 15.

46 Ibid. a 7 o 8.

47 GAO. 2011 a 15.

48 Ibid. a 15.

49 Ramseur. 2007 a 3; GAO. 2011 a Execuive Summary.

50 Grifihs. 2008 a 27.

51 Ibid. a 21.


53 Fores Carbon Markes and Communiies, USAID. 2012 a 2 o 3.

54 Ibid. a 1.

55 Cosslet, 2011; Teixeira, 2012.

56 Murray, Brian. REDD as a Compliance Opion. In Edior, Workshop on secor-based

ofse crediing and a subnaional (REDD) program. Sacrameno, CA: Nicholas Insiue

or Environmenal Policy Soluions. July 30, 2010 a 9.

57 Ibid. a 9.

58 Governors Climae and Foress Task Force (GCF). Abou GCF. Available a

htp://www.gcaskorce.org/abou. Accessed December 2012; GCF. GCF Task Force

2011 Brochure. A 1.

59 GCF. Abou GCF.; GCF. GCF Task Force Brochure.

60 Caliornia code 95802, secion a, 3. 2011. In Subchaper 10 Climae Change, Aricle 5,

Secions 95800 o 96023, Tile 17, Caliornia Code o Regulaions.

61 Secker, Tifany. Brazilians begin o swap ores credis o push Amazon oresaion.

ClimaeWire. December 18, 2012.

62 Ibid.; GCF. Abou GCF.; GCF. Documens: MOUs Esablishing GCF. Available a

htp://www.gcaskorce.org/docs. Accessed January 2013.

63 The REDD Desk. General Law or Susainable Fores Developmen. Available a

htp://www.heredddesk.org/law/general_law_or_susainable_ores_developmen.

Accessed January 2013; The Law o he Republic o Indonesia, Number 41, Year 1999.

Aricles 40 and 46.

64 ARB. 2009 a 65.

65 Friends o he Earh. [Press release]. Indigenous leaders rejecing Caliornia REDD

hold governor responsible or heir saey. Ocober 24, 2012.

66 Ibid.

67 Ibid.

68 UNFCCC. Repor o he Conerence o he Paries on is seveneenh session, held

in Durban rom 28 November o 11 December, 2011. Decision 2/CP.17. 15 March

2012. Paragraph 67 a 15; UNFCCC. Repor o he Conerence o he Paries on is

sixeenh session, held in Cancun. 2011. Appendix I, paragraph 2 a 26.

69 UNFCCC. Repor o he Conerence o he Paries on is seveneenh session, held in

Durban. 2012. Paragraph 67 a 15; UNFCCC. Repor o he Conerence o he Par-

ies on is sixeenh session, held in Cancun. 2011. Appendix I, paragraph 2 a 26.

70 UNFCCC. Repor o he Conerence o he Paries on is seveneenh session, held in

Durban. 2012. Paragraph 67 a 15; UNFCCC. Repor o he Conerence o he Par-

ies on is sixeenh session, held in Cancun. 2011. Appendix I, paragraph 2 a 26.

71 The Plurinaional Sae o Bolivia. Proposal or he Developmen o he Join Miiga-

ion and Adapaion Mechanism or he Inegral and Susainable Managemen o

Foress. Presened o he UNFCCC. Augus 2012 a 10 o 11.

72 Ibid. a 9 and 14.

Copyright March 2013 by Food & Water Watch. All rights reserved. This issue brief can be viewed or downloaded at www.foodandwaterwatch.org.

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Documents

Bad Trade: International Forest Offsets and California’s Carbon Market