| Comment Number: | 533431-00003 |
| Received: | 1/10/2008 11:30:34 AM |
| Organization: | |
| Commenter: | Amanda Cundiff |
| State: | DC |
| Agency: | Federal Trade Commission |
| Rule: | Guides for the Use of Environmental Marketing Claims |
| No Attachments |
Comments:
Thank you for investigating this issue. I believe there should be regulations that bar carbon credits from reforestation projects on public lands. These projects, such as those Carbonfund.org was funding one year ago on four national forests or current projects completed under an MOU between The Conservation Fund and Fish and Wildlife Service, are fundamentally different than reforestation and avoided deforestation carbon credit projects on private land. First, when carbon credit retailers fund projects on public land, it means that green consumers are stepping in to make up for lower appropriations from Congress for reforestation of federal lands. I'm not a lawyer, but I've heard it is illegal for government agencies to accept money from other sources than congressional appropriations, except when specifically allowed (as in, e.g., National Park entrance fees.). Second, these lands are, generally speaking, not in danger of development, so we can assume trees would regrow there eventually without the help of carbonfund.org or others. Third, carbon stored through reforestation projects on public lands is not insured against catastrophic wildfire or other destruction. And I haven't seen any retailers provide a guarantee that the same location will be replanted when the original tree dies in 100 years. Thus, while marketed right next to each other ("pick your project"), these forestry credits are very different than credits derived from renewable energy projects or energy efficiency projects in terms of their longevity / permanence. After investigating these problems, we asked Carbonfund.org to remove projects on National Forest land from their portfolio of projects, and they did. However, I am still concerned that other federal land management agencies are falling in the same trap, especially after learning yesterday--at your workshop--about The Conservation Fund's MOU to fund reforestation on F&W refuges. I would be more than happy to come discuss this with you at any time. Thank you for the excellent workshop yesterday. Amanda Cundiff