First, full disclosure. As you may know, I’m a boardmember of the Climate Action Reserve.

Second, I take seriously your concerns about process and the need to have environmental advocates represented in CAR’s working groups. But, it is not a simple matter to find environmental advocates willing and able to commit the time and effort to help develop CAR protocols, particularly on a highly technical issue like ODS destruction.

I don’t know if Thomas Grammig, whose comment precedes mine, meets your criteria of having an environmental advocacy background, but he is a strong advocate that was actively involved in the working group process and I very much appreciate and value his involvement.

More generally, I agree with you that CAR needs to have the active participation of environmental advocates with substantive technical and/or policy expertise in relevant fields in order to be effective. I would like to encourage anyone who meets these criteria to participate. And, if someone has suggestions on how to improve CAR’s process and expand working group participation, please let me know.

As for the partial overlap of the comment period with COP 15, I’ll simply note that in the current climate policy world conflicts are inevitable. If anyone has trouble meeting a comment deadline, please contact Reserve staff and let them know you will be filing late comments.

Finally, the suggestion that a COP15 side event would have been a promising venue doesn’t square with the COP15 chaos I remember so fondly. If the public meeting had been scheduled at a side event we might have had a great discussion amongst those few who were tenacious and fortunate enough to get into the Bella Center after waiting in line outside in the cold for eight hours.

Third (a substantive issue, at last), you argue that freezing a project’s baseline based on regulations in place at the time will create a constituency opposed to future regulatory actions. I would argue that quite the opposite is true. If an offset provider’s credit is linked to future regulations — as you recommend — then the offset providers will oppose future regulations. In contrast, with a fixed baseline existing projects will be indifferent to future regulations and won’t add to the already significant opposition to future regulations.

Also, while a variable baseline reduces the possibility of over crediting, it also increases risks to project proponents and would likely reduce participation. The argument that we should be willing to forego near term reductions from offset projects for the possibility of greater reductions through future regulations doesn’t strike me as a slam-dunk. I appreciate your optimism that future international action under the Montreal Protocol is likely to make a significant impact on emissions of legacy stocks over the coming decade, but I am not entirely convinced it is warranted.

Peter Miller, Senior Scientist
Natural Resources Defense Council
San Francisco, CA