An Open Letter to Fred Krupp

“The Clean Development Mechanism [the offset part of the Kyoto Protocol], which provides about 95% of the offsets used in the European market, is clearly broken and should be quickly phased out.”

My first reaction to reading that parting statement in what was otherwise a very rational and cogent interview was unprintable in a family blog like this.

First of all, let’s get a few things straight. When it comes to protecting the environment and harnessing market forces to that end, Fred Krupp is a god. Maybe I should even capitalize that description. There is nobody who has done remotely as much for that particular cause—including our Nobel Prize winning inventor of the Internet—as Fred Krupp. I have been a regular and long-standing contributor to the Environmental Defense Fund (EDF), even during the unfortunate period when their abbreviated acronym likely confused a fair number of Viagra seekers on Google. The staff there is analytical, innovative and ferociously dedicated to their cause. They’ve gotten their viewpoint into the inner workings of many of the US’s mega corporations, generally at the CEO or Board level. They basically investment-banked the biggest private equity deal of all time—the KKR takeover of TXU – mainly to stop a massive planned expansion of coal-fired power. Calling EDF and Fred the father of environmental markets is not remotely an exaggeration.

While to my regret I don’t know Fred personally, we did actually once spend the better part of an afternoon together, though I doubt he would remember it. It was in the lovely city of Kyoto, Japan, on a Sunday in the middle of the 1997 namesake climate conference, and our Japanese hosts had arranged a series of different tours around that historic city. Coincidentally, I ended up on the same tour as Fred, and for at least one portion of the tour, we ended up chatting as we walked down a small winding street together with a multi-star admiral from the Defense Department who was part of the US delegation. At the time, EcoSecurities was less than a year old, still had a grand total of two employees and to say we (and therefore me) were nobodies would be a gross exaggeration; we had several steps to climb before we would even register at the “nobodies” level. Fred, on the other hand, was already a superstar.

At Kyoto, the CDM was hardly born of unanimous acclaim, and EDF had no small role in getting the negotiating buy-in on market based approaches that helped convince a number of skeptical countries. In 2001 when the US largely disappeared from the international climate world, it’s not an exaggeration to say that EDF also took a hiatus from the dialogue about the operational aspects of the CDM. Fair enough—EDF’s main constituency is the United States and US policy (though they also run an extensive China program). But to be frank, it was very unfortunate to lose their rationality and capability in the process, and I would argue that some of the maddening aspects of the current CDM—from a business perspective—are a direct consequence of losing the US (and by association, EDF) influence on its development in those crucial startup years.

So, when phrases like “should be quickly phased out” get bandied about, my first question (after my blood pressure settles) is: exactly how has the CDM has failed so much that the father of environmental markets believes it to be beyond saving? Let’s take a look at the results. The first CDM project was registered at the end of 2004, just a little more than 4 years ago. Today there are 1,500 projects registered (representing some 1.5 billion tons of emission reductions through 2012) and at least another 2,500 in the pipeline. Billions of dollars have been raised in the capital markets and there are methodologies covering at least 100 different project types. A sector dedicated to financing global environmental improvements has emerged. Projects are distributed across some 68 countries around the world. When you’ve tramped across a landfill in Brazil, a piggery in Mexico, a steelworks in China and a refinery in Ghana, all of which are linked by the single commonality that their management wants to become more climate friendly (and get paid for it), you know that a sea change in global business attitudes has occurred. Maybe Fred and the guys from EDF need to get a bit more mud on their boots and see what what’s actually happening out in the field at the micro-level.

There are many indisputable shortcomings of the CDM. First, far too many first-generation CERs came from HFC-23 reductions, rather than from changeovers to renewable energy and energy efficiency. Second, the process of assessing the “additionality” of certain clean energy assets that were at various stages of development has been deemed questionable by some outside observers. Third, an overwhelming preponderance of CDM capital flows have gone to China. And fourth, the regulatory process that oversees the CDM often seems to have been designed by Kafka, with a helping hand from Dante.

There are answers to all of these critiques, not the least of which is that we’ve barely passed the fourth year of what should be a many decade process of “learning by doing.” The main issue is that you cannot set up a legitimate market system that only lasts a few short years, sunsetting almost as soon as it starts. Of course in these conditions projects that paid the highest immediate returns were identified and executed first. Of course in these conditions clean energy projects that were at some stage along the development pipeline were the most likely to try to engage the CDM financing instrument. And of course China grabbed the lion’s share of projects—half the developing world’s emissions are there, they can be found in large concentrations, and the Chinese government has made a regulatory system that was rational and workable through which to tackle them.

We Americans who basically went offshore about eight years ago to actually buikd the CDM “business” that was vaguely envisioned by the US and EDF are now coming home. We think our experience to date has some relevance and should be heard in the US policy debates. Though it’s been a never ending challenge, I can’t think we didn’t succeed at some important levels. Just for one, that two person company I was half of at Kyoto now has some 300 employees, offices throughout the world and has registered more than 150 projects within the CDM system representing 100 million odd tons of potential reductions by 2012. Anybody who thinks this is so easy is welcome to join our staff on one of several exciting field trips—climbing a 200 foot smokestack to check the calibration on flow meters, negotiating coalmine gas royalty agreements with provincial officials over endless baijiu, or trying to dry clean the stench of pig feces from biogas plants out of your clothes are all popular options. It’s not easy, it’s not always fun, but if you want a market instrument that’s going to work in the developing world, this is where you have to go. Blithe statements about failure are frankly a bit insulting to those of us who actually followed up on the promise and trajectory that was laid out a dozen years ago.

The latest concept that EDF is promoting around global carbon market solutions has been dubbed “ClearPath.” Though sparse in detail, the basic idea involves developing countries taking on voluntary caps that are somewhat greater than their current emissions, so they can sell excess emission rights today and use the proceeds to finance transitional energy technologies to move their emissions downward. EDF estimates that this will raise some $250B to $1.5T over the first decade of operation—a fairly substantial range, to say the least. In principal, it’s an admirable concept, and it is undeniable that covering the broadest possible sweep of countries with hard caps is something to which we should aspire.

However, the idea that it’s going to be easy to come up with the “right” amount of extra emissions allocation for any sizable number of countries is ludicrous. A simple observation of developing country emissions profiles should immediately raise the question of how to construct something even remotely equitable. On a GHG per capita basis, South Africa is at 50% compared to the US, China is at 25%, Mexico is at 20% and India is at about 10%. It is already hard enough to get industrial countries to seriously talk about hard caps – now we need to layer this variable into the equation and create a reasonable supply and demand balance that will be both politically palatable and still incentivize serious reductions ? And this is assuming we can get the necessary monitoring, reporting and verification of GHG emissions data for developing countries in place to ensure that ClearPath could distribute credits accurately and appropriately.

I’m not against the ClearPath – far from it – and if EDF and its negotiator allies can convince a sweep of key developing countries to take this up (while not just flooding the market with a next generation of “Hot Air“), my hat is doffed with genuine admiration. But in my heart, I don’t think that’s realistic. And to be honest, I’d like to know what Plan B is, in case ClearPath is greeted with the skepticism I expect.

As far as I’m concerned, Plan B must involve fixing the CDM so that it can continue mobilizing capital, incentivize emissions entrepreneurs and technologies, and slowly push the global supertanker of emissions slightly away from its current trajectory. There are many ways to fix the CDM to keep it moving, and to make it more environmentally credible, transparent and predictable for capital allocation and project development. Perhaps we can indeed get a small handful of countries to experiment with ClearPath. But as a colleague is fond of saying, climate change will have no silver bullet; rather, will require multiple rounds of silver buckshot.

I guess my problem with a throwaway quote like Fred’s regarding the CDM is that it feeds a (very ironic) attitude encapsulated in the US policy debate about international offsets—the “not made in America” issue. Ironic, because the CDM, emissions trading—and the whole idea of environmental markets in general—sprouted from American soil. In coming back to the global negotiating table, the US can make a real difference by addressing the various shortcomings of the CDM, and by coming up with constructive solutions that actually learn from past experiences. The essentials would be to make the regulatory process simpler and more conservative (by endorsing real technology benchmarks across sectors, avoiding the project by project system of the CDM) and creating a longer time horizon for achieving emissions value, (so that the benefits of emissions savings can correlate with project finance timelines). To be frank, what we have accomplished—given those shortcomings of the Kyoto/Marrakech architecture—is to my mind remarkable.

In 2008, Fred wrote a book called “Earth: The Sequel.” Disappointingly, it was not a sci-fi thriller about moving to another, hipper, planet, but rather about how we fix our relationship with this one through emerging markets for new energy technology. I’d like to think the CDM deserves the same kind of consideration for a sequel, and I don’t think it’s unfair to ask exactly which particular shortcomings of the CDM have convinced Fred that we exclusively need to tread a radically different path. CDM is far from perfect—few have ever claimed otherwise – but it has indeed lit a wildfire of enthusiasm for emissions reductions that we will not rekindle easily if it is summarily doused with a bucket of “been there, done that” cold water. ClearPath is an admirable idea, but fraught with complexities that make the CDM look like a crayon maze on a kid’s meal menu at Denny’s. If we can get five or ten countries with different profiles to sign up and work out the kinks for the next decade, that’s a triumph right there. In the meantime for the other 150+ countries in the world, let’s discuss the strengths and weakness of CDM and international credit systems rationally, with some nuance and with aims of improvement—and not just pander to popular misconceptions.

Marc Stuart is the Co-Founder and Director of New Business Development for EcoSecurities, a global carbon trading firm. The views expressed are his own and do not necessarily represent the view of EcoSecurities.

11 replies
  1. Fred Krupp
    Fred Krupp says:

    Marc,We agree that the Clean Development Mechanism has been a valuable tool for promoting sustainable development, and it has given developing countries important hands-on experience with market-based emissions reductions.But in the 10 years since the Kyoto Protocol was adopted, the science has become grimmer: dangerous climate change is occurring more rapidly than predicted, emissions continue to rise – and the need for a truly global agreement to reverse that trend has become more urgent.Averting the worst impacts of runaway climate change will require the sum total of global emissions to begin decreasing in the near future. That will require absolute emissions reductions (not simply reductions from business as usual) from developing nations, not only from developed ones (though we must lead the way). Because the CDM awards tradable credits for emissions reductions projects in countries whose overall emissions continue to grow, it only marginally slows the pace of emissions growth IN the developing world — there is no guarantee that overall global emissions will come down.That’s why Environmental Defense Fund is developing an alternative path to bring large developing countries into a binding system of emissions caps, while preserving access to the CDM for small developing countries. Our twin goals are to secure sufficient global emissions reductions to protect the climate and enable the poorest countries to benefit from CDM financing.The CLEAR path — short for "Carbon Limits + Early Action = Rewards" — provides incentives for developing countries to join the global carbon market. While we would like to phase out CDM for large developing country emitters, we are certainly not trying to phase out project-level carbon finance. EcoSecurities does fantastic work in securing financing and developing greenhouse gas reduction projects all over the world. We would like to see these projects grow to a multiple of their current volume.CDM provides incentives for countries to stay out of the carbon market and not to take on national emissions reductions targets. CLEAR creates incentives for countries to join the global market with their own reduction targets. The CLEAR path proposal is a work in progress, and I welcome your comments on it. We are continuing to flesh out the details; the most recent version of our proposal, an academic version focused on the financing mechanisms can be found here: http://www.edf.org/documents/9410_clean-investmen

  2. Chandler Van Voorhis
    Chandler Van Voorhis says:

    Fred:If Science is right, scale is everything. However, our rules and layers of bureaucracy are preventing scale. Forestry is a great example. How many forestry projects have made it thru the CDM process — TWO.Further, the market has focused too much on banking and futures and not enough on insurance. That is why C2I has been proposing for several years now that we should create a Federal Carbon Reserve where the mature stands additional carbon flows into a reserve that either insurance companies or registries can access to ensure permanence. While Kyoto's tCER and lCER instruments have had lots of issues for many reasons, the US is looking at requiring permanence to go extremely long (ie CCAR 100 years). Since our company originates forestry carbon in the MS Delta and gets landowners to bind their land for a very long time for afforestation, we have a unique perspective of what it takes to get producer landowners on scale vs. the dabbling of silicon valley absentee landowners.What product or commodity can we name that we sell today and must warrant for 100 years? What transactional settlement period is T+100 years? Why are we asking landowners to go longer than government is willing to regulate the environment and business?The only real reason is that people are looking at matching up atmospheric accounting to the IPCC 100 year GWP. Those same studies have also looked at atmospheric impact over 20 years. Since most of the GHG gases have a more severe impact over the first 20 than the next 80, why not look to the immediate climatic impact.The issue we see with enabling scale is the rules become too cumbersome and landowners opt to grow biomass instead.Think about it.To participate in biomass, I grow trees that absorb carbon. I cut them down and sell the trees to a Utility to use as a replacement to coal. Since carbon was first sequestered, then released, the Utility will be able to claim zero emissions associated with the generation. Here the landowner participates in the carbon market by providing renewable fuel without having to go thru all the hoops of binding land for 100 years. Which by the way, if that landowner is of the average age of 60, we are talking about his great, great grandchildren when the transactional obligation of the settlement is completed. And if we are looking at the regulatory window of Warner Lieberman to 2050 that compliance market will have been over for 62 years.Given the option between biomass and offset market, landowners will opt for biomass and for good reason.What we need is a balanced approach. With the rules largely in place for RFS Standards and a coming federal RPS and with Europe already sourcing wood supply from the US, the market is already moving and organzing the land base into plantation energy crops. This is good. What we need is the same efficiencies and incentives for the offset side of the market.After all the science is more dire and we need a scaled response.

  3. Adam Cherson
    Adam Cherson says:

    Being neither a God nor a nobody-turned-somebody, I enter this discussion with trepidation. I am speaking merely as a human being who wants to organize his life in a way that may reduce suffering. From this perspective, I hope that the main interlocutors here, and anyone else who may run across this discussion, can view my comments as coming from a place of constructive cooperation and not as judgments upon the ideas or past work of anyone in particular. I tend to agree that a fresh start could be a useful concept, as far as the US is concerned anyway, since many people are unable to distinguish the climate change problem from American political history involving such characters as the ‘inventor of the internet’ or the great ‘decider’. What I am sensing from Mr. Stuart is a concern over the mammoth complexity of the CDM (and CLEAR) approaches along with a willingness to expend enormous resources towards working within the Kyoto framework as being the best option available however imperfect. He is therefore upset about the thought that his efforts and those of so many others might face oblivion if we now change direction. To this I would say that our priority should be a climate change strategy that works within the reduced time constraints that are becoming more evident everyday. This is essentially Mr. Krupp’s point and I think it is well taken. Mr. Krupp also adds that CDM provides only reduction in business as usual emissions around the world (that is, a slower rate of emissions growth, but certainly not a cap or reduction). So far so good: Mr. Stuart says the game-plan is devilishly complex and Mr. Krupp says our current protocol is a case of too little, too late. The most logical conclusion I can reach based on these views is this: we need a strategy that is simpler, faster, and big enough, correct? This is why I am somewhat perplexed by the CLEAR proposal. If Mr. Stuart’s summary is correct, this new initiative is an order of complexity higher than the CDM. If Mr. Krupp’s precis is correct, this new initiative “provides incentives for developing countries to [voluntarily] join the global carbon market.” The voluntary global carbon market may be the most efficient mechanism for achieving emission reductions, but will it really be fast enough? And finally, will the CLEAR reductions be big enough to have an impact on climate change? How much will be allowed globally? How will the global quota be distributed among nations? I congratulate both Mr. Stuart and Mr. Krupp for recognizing that there are real problems with our current framework and for trying to do something about them. To assist in this effort, I close by outlining another strategy for their consideration as they move forward. The main reason for the corrosive complexity of the prior schemes is that they are trying to combine climate change avoidance with poverty reduction (i.e., the economic growth of developing nations). I suggest that we decouple these two goals. We should still work hard to reduce poverty in developing nations and we should still work hard to prevent catastrophic climate change for the world, but let’s not tie them together in the same framework. Instead let’s focus entirely on climate change for a moment and, for purposes of this discussion, on carbon dioxide emissions only (the same procedure outlined below to be applied to each of the greenhouse gases and to deforestation as well, whereby a certain amount of deforestation is the equivalent of a certain amount of emitted CO2).The place to start is with a number. What is the amount of carbon dioxide that human beings may safely emit into the atmosphere? By this I mean, what amount of human emitted carbon dioxide will not increase the atmospheric part per million? Based on my review of the scientific literature, this amount is around 8.79 Gt CO2/yr. Harsh, I know, but that is what the science tells us and this number should be the basis for the baseline quota. Now how do we distribute this amount among the nations? Not to enter into a Rawlsian-Singerian debate on fairness, I suggest that the per capita approach is simple and fair enough to be widely acceptable. So using the baseline population levels at the time of the agreement, each human being on Earth is allotted an equal quota of abiotic carbon dioxide emissions. Multiply this number by the population of each nation and you have the national cap. This number does not change, even as population sizes change within each nation. Obviously we can’t expect most nations to achieve their quota limit overnight, so we set up a straight line reduction schedule out to the year 2100 so that by that year, the target amount is reached. (An aside here: although this system treats all nations equally, it will have a much greater impact on the high-emission, industrialized nations since these will have to reduce a much larger amount to reach their cap.) So what happens when a nation fails to meet its own reduction schedule and emits too much? They pay a fine which goes into a fund administered by the Global Environment Facility. This fund is used to finance global carbon mitigation and climate change adaptation projects to be discussed some other time. The formula for determining the amount of the fine is also to be discussed some other time, but rest assured that the amount will be based on a real deterrence value. OK so that’s a framework for a simpler, faster, and large enough climate change strategy. After minimal ground rules such as these are in place, we can safely move on to the further perfection of CDM and carbon trading systems. We should, however, make sure to address the fundamentals before moving to greater complexity.

  4. stefan
    stefan says:

    The need for real, verifiable, and quantifiable GHG reductions will grow for industrial nations and the uncertainty over the value of the carbon offsets need to taper off. One solution is Carbon Default Swaps offered by Carbon Capture Solutions. Carbon default swaps allow a regulated party to hedge the risk of the intial CDM project failing or being proven less effective than planned.

  5. Alan Rushforth
    Alan Rushforth says:

    I cast my vote for a simple honest carbon tax WITH dividend paid back directly to everyone with a social security number. This would be simple. It would create an immediate incentive to cut carbon emmissions for the biggest coal plant conglomerates down to individual consumers. Instead of an average citizen paying say $3,000 per year for energy, what if he/she paid $6,000 per year, and got an annual check for $3,000. He would gladly take the check, and then do his best to cut his fuel use. The energy saving efforts would take place from the biggest energy guzzling companies down to the smallest individual energy users. As the owner of a solar installation business I can say first hand how the clean solar hot water systems my company offers that make reasonable financial sense are often declined because fossil fuel energy is relatively cheap right now. If the cost of fossil fuel were twice as high, clean energy systems like we sell would be deployed much more agressively. Last year I attended a conference on cap and trade. I figured I need to learn how this works for my business. After dedicating 2 days of my time, I went away more confused than I started. Cap and Trade is aimed at big power producers but totally fails to create incentives for individuals and small businessess to cut carbon emmissions. World renowned climate scientist, Dr. James Hansen says Cap and Trade will not cut it and a carbon tax with dividend is what is needed to seriously cut carbon emmissions. I agree and wish we would stop wasting precious time with Cap and Trade paper pushing, and get down business creating real incentives for across the board carbon reductions with an honest carbon tax and dividend.

  6. Liam
    Liam says:

    I work for a company called RESET based in Hong Kong and selling carbon and energy management services into the HK/Chinese market. Our services have to be sold on the basis on short run management of commercial opportunity and risk and the CDM, despite its problems, is an asset. Not as big an asset as we might like – carbon prices are too low to justify structuring most energy efficiency projects for example – but at least as a means of demonstrating that there are new ways to make money from fixing environmental problems.What would be unhelpful, right now, is a message from western markets where all these ideas originated that says oops, 'failure', let's start all over again.Whatever comes next will probably take at least 5 – 7 years get negotiated, turned into regulation and rolled out to the market (ETS was 1998 – 2005, or about 2500 days….and by EU standards that was fast). From environmental standpoint we need to get a lot done in those 7 years. And whilst the CDM may not work in practice for many of RESET's clients, almost all of them have heard about it and are intrigued by the implications it may have for their business.A big part of the climate issue is about changing the mindset of business. Don't we need a narrative that shows how the opportunity evolves, rather than a story that junks the reputations of the first movers?The CDM does have some big problems (and I think Marc puts finger on the main ones) but there is also clearly considerable opportunity for improving the situation within its current framework. Which all makes me wonder whether the 'failure' grandmotif is more about providing a dramatic context for new ideas, rather than an assessment of how effective market regulation should be evolved.Oddly enough, as one of the original carbon cap-and-trade advocates, the CDM is in many ways EDF's baby too, despite their Bush-induced break from the international scene. Careful with that bathwater folks….

  7. Erich J. Knight
    Erich J. Knight says:

    Dear Mr. Krupp,I think I see a totally verifiable and non-reversible CDM in Biochar soils. UNCCD Submission to Climate Change/UNFCCC AWG-LCA 5"Account carbon contained in soils and the importance of biochar (charcoal) in replenishing soil carbon pools, restoring soil fertility and enhancing the sequestration of CO2."http://www.unccd.int/publicinfo/AWGLCA5/menu.phpThis new Congressional Research Service report (by analyst Kelsi Bracmort) is the best short summary I have seen so far – both technical and policy oriented .http://assets.opencrs.com/rpts/R40186_20090203.pdf .Given the current "Crisis" atmosphere concerning energy, soil sustainability, food vs. Biofuels, and Climate Change what other system addresses them all?Biochar viewed as soil Infrastructure; The old saw, "Feed the Soil Not the Plants" becomes "Feed, Cloth and House the Soil, utilities included!". Free Carbon Condominiums, build it and Wee-Beasties will come.As one microbologist said on the Biochar list; "Microbes like to sit down when they eat". By setting this table we expand husbandry to whole new orders of life.This is a Nano technology for the soil that represents the most comprehensive, low cost, and productive approach to long term stewardship and sustainability.Carbon to the Soil, the only ubiquitous and economic place to put it.Cheers,Erich J. Knight

  8. Peter
    Peter says:

    Clearly, it's always good to try and save the baby as the bathwater goes out the window.Marc has a point : CDM has deployed a surprising amount of people and capital into emission reduction projects around the world in only 4 years. This experience and the resultant detailed understanding of some of the real barriers to action and problems to execution seem to me to be very valuable to any "next phase" irrespective of acronym. It would be a huge loss for this to be valued at zero by any successor regime.However, science demands much more radical and abrupt action than the current CDM is able to deliver, and – as Mr Krupp eloquently states – runs the risk of all offset mechanisms: it allows the host country and credit buyer to postpone often harder and more necessary decisions.We are at a juncture when, for the planet, timing is everything. Somehow the policy bridge between what is scientifically demanded and what is politically feasible needs to be built. At such a time, and as a community of people in a minority (ie bridge builders), I think there should be two guiding principles :1) Inclusion – of all relevant experience and resources (ie hands to the pump). Meaning avoidance of policy flip-flop and other inefficiencies that one side or other of the shoreline may newly require.2) Physics first – ie with capital constraints our policies must deliver sizeable, economically efficient and physically achievable global GHG reductions first to buy time (and recycle capital) for the implementation of actions which by their nature will deliver reductions and change later on.In a world with finite degrees of freedom, I guess those with political capital are trying to figure out whether the greatest barriers to future action for our new agenda are behavioural, financial or relate to the management of future expectations. I hope that the present situation whilst reducing room to manoeuvre along one axis maybe creating opportunity along others.

  9. Anonymous
    Anonymous says:

    TIME FOR SOME TRUTHAnything less than a carbon Tax is not only doomed to failure. Please look at what happened in the EU over the years if you do not have the facts .http://www.france24.com/en/20090311-hansen-only-way-keep-planet-cool-hansenhttp://www.newsweek.com/id/36517To elaborate on the Newsweek article above many companies have actually gamed the system to make enormous profits."One reason emissions trading is so politically popular is that it's vulnerable to lobbying. The European Union's Emissions Trading Scheme, which accounted for two thirds of the global carbon trading that went on last year, or $20 billion, is a case in point. On paper, the scheme is a zero-sum game: the European Commission issued a limited amount of carbon credits. These caps are supposed to bring emissions down across the EU to a level 8 percent below those of 1990 by 2012. But most European governments, under pressure from lobbyists, were too generous in handing out targets to specific industries. As a result, many companies weren't forced to make any cuts, or buy any credits. Indeed, in May 2006, when inspectors began checking the books, they found a surplus of carbon credits which, as soon it became public, triggered a market collapse." Which is where it will wind up in the voracious Wall St. corrupt market here.We do not have time for failureWorse than a poor program this proverbial permit to pollute will let the greediest most malevolent players drag out their outdated technologies as long as possible (exactly what has happened to coal power) and use the excuse of "Crap {sic} & Trade" to prolong the battle. Arguments about hedging, they will move to China or other specious excuses are long in the tooth 10 years ago. We are on the down side of the roller coaster that has no tracks at the bottom, blithely with our collective hands in the air, heading for irrevocable global changes and we need to stop the carnage NOW!

  10. Erich J. Knight
    Erich J. Knight says:

    Dr. Das sent this US commerce bill that includes carbon sequestration offsets from agriculture to the Carbon Standards Committee, This Carbon Standards Committee is a diverse group of Big Ag, Carbon Marketeers, Environmentalist, USDA and academics setting protocols, verification and definitions for soil carbon.Contact Gary DeLong if you would like to be on the mail list of reviewersof these Soil Carbon StandardsGary DeLongManaging DirectorNovecta, LLC5505 NW 88th St., #100Johnston IA 5013 1www.novecta.com515-334-7305 office515-225-0781 fax515-240-9586 cell———- Forwarded message ———-From: DAS, PRADIP Subject: The ACESA includes carbon sequestration offset from agricultur ehttp://energycommerce.house.gov/Press_111/20090331/acesa_discussiondraft.pdf

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