Comment Log Display

As a professor and geographer (PhD, UC Berkeley) specializing in
international environmental policy and sustainable development, I
have done research and written peer-reviewed publications on trade
in environmental services, REDD+, and the results of proto-REDD+
programs and payments for environmental services (PES) projects in
Latin America. I have taken part in numerous conference sessions
and read dozens of research reports, peer-reviewed case studies,
and review articles about carbon sequestration services in the
tropics and about the designs and results of proto-REDD+ programs.
I have read the ROW recommendations and the ARB White Paper and
have observed presentations at the October and April public
workshops on the proposed AB32 sectoral offset policy. 

It seems that the ARB is largely unaware of the extensive,
peer-reviewed academic literature on the implementation and actual
results of PES and REDD-type programs in Latin America and other
regions. I am also struck by the ROW/ARBÕs limited and selective
interpretation of the dynamics of land-use change and the drivers
of deforestation in Amazonia. 

The academic literature, as well as in depth studies by the Center
for International Forestry Research and other agencies, point to
serious problems that are not addressed or are not addressed
adequately in the White Paper and ARB presentations. Many of the
problems that trouble one-off PES and proto-REDD+ projects are
likely to plague jurisdictional REDD+ systems as well. For example,
one well-documented problem is that of inequity: the tendency of
market-oriented REDD+ and PES implementation to favor larger-scale
landholders at the expense of smallholders, a pattern that is very
widespread in PES and proto-REDD+ programs and that has been
detected in PES projects in Acre. 

One of the more dubious suggestions put forward by the ARB is that
leakage of forest-destroying activities, both within and beyond the
targeted REDD+ jurisdiction, can be prevented or at least can be
measured and accounted for. The ARB further proposes that any such
leakage can be managed by means of discounting and reserving a
small share of credits within a partner jurisdiction. However, even
if we assume that most such leakage within a jurisdiction can be
detected Ð an assumption that is not justified, in my view Ð it is
impossible in principle to measure, much less prevent,
deforestation leakage beyond that jurisdiction because the area
beyond the jurisdiction is unbounded. It is also impossible in
principle to determine whether avoided deforestation within and
beyond the jurisdiction is permanent or not, since the future
cannot be predicted. 

The jurisdictional approach per se most certainly does not
eliminate the high risks of impermanence and of leakage into
Amazonas state, Bolivia, and Peru. Even within a jurisdiction such
as Acre, the revenues from CA offset credit sales cannot compete
with the opportunity values of many non-forest land-use options if
land values continue to rise. Rising agricultural land values and
commodity prices are a very possible outcome of growing global land
and food scarcity and could easily swamp regulatory efforts, such
as the proposed sectoral offsets plan for AB32, that depend on
markets in greenhouse-gas offsets.  

In such a context, the responses to the permanence and leakage
problems offered in the ARB white paper are entirely inadequate. A
buffer pool of credits would effectively reduce total revenues from
credit sales and could quickly become insufficient in the event of
land-use changes related to commodity-price increases in soy, beef,
timber, wood pulp, palm oil, biofuels, etc. The ARB-proposed risk
insurance could also become insufficient in the context of natural
events, economic trends, and political factors, as has happened in
the case of the OPIC-insured Oddar Meanchey REDD+ project in
Cambodia that the ARB white paper cites as a precedent for this
approach.

Deforestation also might well accelerate as a result of changes in
government in Brazil. Just yesterday the interim president
appointed as Minister of Agriculture a Òsoy tycoonÓ and notorious
deforester of the Amazon [New York Times May 10, 2016]. Brazil may
soon see some combination of changes in state policies for land
use, soy and other agricultural subsidies, increased export
incentives in the context of the current economic recession, or
changes in enforcement practices. 

The ARB also suggests that leakage can be monitored and minimized
by encouraging agricultural intensification and by assessing the
results in terms of the production of animal products and crops.
The ARB reasoning here is partial and faulty, since data showing
increased productivity of beef, fodder, or other commodities in the
targeted area would not prove that leakage is not also occurring,
especially leakage beyond the jurisdiction. 

But this is more than a matter of poor logic or hypothetical
scenarios. There is evidence, corroborated by several recent
studies, that when agricultural land use in the tropics is
intensified in the context of tightened regulation of deforestation
and agronomic practices, the result is not Òland sparingÓ for
conservation but rather the expansion of the land area where the
targeted crops are grown or animals raised, including expansion
based on forest clearing in jurisdictions neighboring the regulated
areas. This trend has been documented in the Brazilian Amazonian
and cerrado zones and in neighboring states Profits from
intensified farming and ranching have been reinvested in ranching
and large-scale soy production has been shifted to less effectively
regulated regions.

UCLA professor Susanna Hecht, one of the worldÕs foremost experts
on deforestation in tropical South America, and Gustavo de l. T.
Oliveira, who studies land-use change and agriculture in Brazil,
summarize some of these findings in an important article published
this year.* They write:
ÒCommon to all analyses is the evidence that intensification of
profitable land uses tends to enhance its spread rather than to
confine it spatially, regardless of the mix of drivers (Hecht 2005;
Morton et al. 2008; Rudel et al. 2009; DeFries, Rudel, and Hansen
2010).Ó [p 267]. 
They continue, 
ÒÉthere is evidence that the tight environmental regulations,
cadastral requirements, better monitoring and enforcement in the
Amazonian fringe have triggered ÔleakageÕ into other woodland
systems elsewhere in Brazil, Bolivia, Paraguay and Argentina,
operational dynamics that are obvious to cross-continent farm
management companies and migration choices of small- and
medium-scale soy farmers (Hecht 2005; Pfaff and Walker 2010;
Richards 2011). [p 270]

In this light, the ARB propositions that intensification of
production should be promoted, and that production increases in
ranching and related production will indicate lack of deforestation
leakage, is badly misguided. It is also odd that intensification
techniques such as N-fixing cover crops and paddock rotation, which
have been recognized and studied since at least the 18th century,
are portrayed as innovations that ranchers will quickly adopt. More
worrisome, and ironic, is that this approach would provide backing
from California, in the name of conservation, for intensification
of ranching and the meat/fodder/feedgrain complex, which is by far
the most efficient way of producing food calories wherever it is
practiced.

Finally, the US and Canada together comprise the worldÕs largest
source greenhouse-gas emissions both absolutely and per capita. It
seems arbitrary and somewhat opportunistic to argue that California
has a special responsibility to try to shape forest policy in Acre
(or anywhere else), while we continue to enable continued emissions
from our own state and make emissions even easier by adding more
offset options in the name of Òreducing compliance costsÓ.
Californians who feel that there is a particular reason to support
conservation in tropical Latin America can do so through many other
organizations. The state of Acre has other means of limiting
deforestation should it choose to employ them. Both Brazil and the
US have made commitments under the Paris climate agreement to make
significant reductions in their climate-warming emissions. The
appropriate place for California to show leadership in meeting this
commitment is right here in our own state.

Kathleen McAfee
Professor of International Relations
San Francisco State University
kmcafee@sfsu.edu

* Gustavo Oliveira & Susanna Hecht (2016) Sacred groves, sacrifice
zones and soy production: globalization, intensification and
neo-nature in South America, The Journal of Peasant Studies, 43:2,
251-285, DOI: 10.1080/03066150.2016.1146705.