Last week, the Sierra Clubs California lobbying arm issued a letter (.pdf) urging Governor Jerry Brown to re-evaluate Californias cap-and-trade program to reduce greenhouse gas emission, particularly the programs rules regarding use of offsets.
A quick refresher on whats been going on here in the Golden State. In 2006, then-Governor Schwarzenegger signed into law Californias Global Warming Solutions Act, known commonly as AB 32, which directed the California Air Resources Board (ARB) to develop regulations that would reduce greenhouse gas emissions to 1990 levels by 2020. The ARB was given wide latitude to decide what regulatory mechanisms to use, though the law did set down policy boundaries such as maximizing environmental and economic benefits while minimizing cost.
A whole host of regulations have been adopted pursuant to AB32 over the past several years, including most recently the cap-and-trade system set to get underway January 1, 2012. As adopted, the system allows emitters to use a combination of onsite emission reductions and offsite emission reductions to meet their reduction burden. The offsite emission reductions – the offsets – are limited in quantity, in geography, and in the types of emission sources which may be reduced.
This is a groundbreaking moment for climate change action. Here we are, poised to committing greenhouse gas emitters to substantive emission reductions, and now that the challenges from the emitters have been dealt with, the ever-fractious environmental community is starting to throw rocks. The latest, voiced by Sierra Club California Director Bill Magavern, argues:
>Excessive reliance on offsets could open up loopholes that undermine the very purposes of
Californias AB 32 cap on emissions. Curbing global warming will require a fundamental
transformation of our energy economy, a task that cannot be outsourced to other countries.
Requiring Californias largest polluters to reduce their own emissions will spur technological
advances that can be exported to the rest of the world, bringing green jobs to the Golden State.
The letter continues to argue that ARBs approach contains a number of offset-related problems, including disproportionate impacts to low-income communities, weak forestry offset protocols, and a general skepticism of offsets from an enforcement standpoint.
Im disappointed. I expected better from my fellow environmentalists over at the Sierra Club. In particular, they disappointed me with:
1. Use of exaggerated claims.
Excessive reliance on offsets could open up loopholes that undermine the very purposes of Californias AB 32 cap on emissions.
As a matter of policy, the ARB has decreed that the majority of required emission reductions must occur onsite, at the regulated facilities. The cap-and-trade regulation translates this emission reduction requirement to an emission limit: a covered entity may use no more than 8% offsets to satisfy its emissions obligation. (See pg. 5 of the ARB regulation (.pdf) or if you need a visual, see the chart on pg. 10 of this presentation (.pdf).) I hardly think 8% constitutes excessive reliance.
2. A la carte style of selecting supporting (but not really relevant) points.
As experienced environmental prosecutors for the state have noted, ‘the cap-and-trade market poses significant enforcement challenges,’ and ‘offsets pose multiple additional enforcement problems, including jurisdiction, verification, and certainty.'”
Right, but the point of the article cited (.pdf) isnt to take offsets out of the picture. It does point out that the newly developing offset market will require new enforcement mechanisms. Thats not rocket science or anything we didnt already know; indeed, the article states this point as an obvious fact without any data or rationale to defend its stance. The point of the article is that local enforcement mechanisms need to be integrated into the larger enforcement process. Which is great. Im sure theyre right. What I dont see in the article is a case against offsets as unenforceable or as poor regulatory tools, as the Sierra Clubs letter implies. Did they not expect anyone to read it?
3. Complete lack of alternatives, proposals, suggestions, or anything else constructive.
Curbing global warming will require a fundamental transformation of our energy economy.
This is absolutely true. Its also going to be a pretty expensive task. Offsets are included in this cap-and-trade system to reduce the cost of achieving the required emission reductions. When youre dealing in greenhouse gases, reducing the cost means keeping the rise in energy/fuel prices to a moderate level. We arent going to get off of carbon by talking about ideals; we need a path to get us there which will solve for both environmental and economic conditions.
The ARBs regulations arent perfect. I agree with Sierra Club California there. But when I see yet more data such as last weeks National Science Council report (.pdf), Americas Climate Choices stressing the urgency of greenhouse gas emission reductions, I come out firmly in the lets get this thing started camp. Please. No more rocks.