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7/28/2019 Bad Trade: International Forest Offsets and Californias Carbon Market
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)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
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HUK*HSPMVYUPHZ*HYIVU4HYRL[
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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.
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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
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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-
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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
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(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.
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(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.
33 Gilberson and Reyes. 2009 a 59.
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.
43 Gilberson and Reyes. 2009 a 60.
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.
52 Gilberson and Reyes. 2009 a 60.
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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