Oppose Carbon Offset Scams Like the Growing Climate Solutions Act
April 14, 2021
Dear Members of Congress:
We, the undersigned organizations, encourage you to oppose the Growing Climate Solutions Act of 2021. While agriculture and land management can play key roles in addressing the warming climate, this legislation would allow greenhouse gas emissions to continue unchecked and would undermine efforts to build a healthy, sustainable, and resilient food system.
The Growing Climate Solutions Act would require the U.S. Department of Agriculture (USDA) to help agricultural entities generate carbon credits by certifying third-party verifiers and creating a “one stop shop” to educate and enroll farmers in third-party carbon markets. Power plants, refineries, and other polluters could purchase these carbon credits to offset their emissions, or even increase them, instead of actually reducing and eliminating them. Third-party verifiers have inherent conflicts of interest that would create a system ripe for fraud.
This legislation aims to build a framework for broad-scale development of carbon markets and to pave the way for a national cap-and-trade program. We oppose these carbon schemes for the reasons discussed below. Instead, Congress should invest in existing conservation programs to help transition farmers to more ecologically regenerative and resilient agricultural practices and systems — ones that do not facilitate more carbon offsets or carbon banks or rely on expensive and harmful chemical inputs, many of which are fossil fuel derivatives. Congress must also enact policies that require polluters to reduce and eliminate pollution at the source by stopping the expansion of oil and gas production and infrastructure, while investing resources to ensure environmental justice and a just transition to healthier, more sustainable communities.
These carbon offset schemes allow utilities, fossil fuel companies and other polluters to continue releasing greenhouse gases, instead of actually reducing and eliminating their emissions. This is because fossil fuel based carbon extracted from where it has been sequestered underground for millions of years, safely trapped in the slow carbon cycle cannot be offset by temporary actions in the short carbon cycle.
Carbon offsets allow fossil fuel polluters to continue polluting the climate, while undermining sustainable farming. In addition, differences between carbon reservoirs, lack of leverage for farmers, and potential for disproportionate benefits all demonstrate that carbon banks are not good for agriculture:
Due to issues of flawed concepts of earth’s pollution absorbing capacity, impermanence, additionality, corruption, and market forces, carbon offset programs can increase emissions — of not just greenhouse gases, but also harmful co-pollutants like hazardous air pollutants, PM 2.5, and ozone precursors. This can be particularly acute in environmental justice communities when major sources of pollution rely on offsets instead of direct emissions reductions. Below are a few examples of such failures:
without the program in place. Similarly, a USDA study looking at conservation tillage practices found that only about 50% were additional.7
USDA has the necessary tools to build soil health, protect water quality, and avoid greenhouse gas emissions while boosting farm income:
Instead of continuing the legacy of pollution through carbon markets, we encourage policies that eliminate pollution at the source and support local food economies, better living wages for farmers and farmworkers, and pathways for sustainable practices of food and energy production.
Congress needs to transition away from factory farming and large agricultural interests by increasing funding for conservation programs, and supporting farms in adopting regenerative practices that enhance soil health, protect biodiversity, and help make our food system more resilient to the climate crisis — all without the use of counter-productive carbon pricing systems including offsets and banks. Black, Indigenous, Tribal, family farmers and ranchers need structural reforms that ensure fair markets and prices, and infrastructure that supports transitions to and sustainable continuance of regenerative farming. Ecologically regenerative farming should be incentivized in addition to, and not instead of, carbon reductions in the energy and transportation sectors. We urge you to oppose the Growing Climate Solutions Act of 2021 and support policies that will halt greenhouse gas emissions and empower rapid transition to a more just, healthy and sustainable future for all.
Businesses for a Livable Climate Call to Action Colorado CatholicNetwork.US
Family Farm Defenders Food & Water Watch Friends of the Earth
Indigenous Environmental Network Institute for Agriculture and Trade Policy Loretto Earth Network
Organic Consumers Association Progressive Democrats of America Public Justice
Rapid Shift Network
350 Butte County
350 New Hampshire 350Brooklyn
A Stone’s Throw Bed & Breakfast
A+ B2B Copy (Green tech specialization) ABC Earth Care Team
Agroecology Research-Action Collective All Our Energy
Alternatives for Community & Environment (ACE)
Animal Legal Defense Fund Animals Are Sentient Beings, Inc.
Ashtabula, Geauga, Lake Counties Farmers Union (Ohio)
Athens County’s Future Action Network, acfan.org
Benedictine Sisters of Erie Beyond Pesticides Beyond Plastics
Big Reuse Brighter Green
Bronx Climate Justice North Buffalo River Watershed Alliance Campaign for Renewable Energy Center for Food Safety
Central Jersey Environmental Defenders Chemung County Mother’s Out Front Church Women United in New York State CleanAirNow
Climate Hawks Vote
Coalition Against Pilgrim Pipeline – NJ Coalition for Outreach, Policy, and Education
Coalition to Protect New York Colorbrightongreen
CWA Local 1081 divinAmerica, llc
Don’t Gas the Meadowlands Coalition Earth Ethics, Inc.
Eastern Cherokee Organization ECO Ecoaction Committee of the Green Party of the U.S.
Endangered Species Coalition Environmental Justice Taskforce of the WNY Peace Center
Environmental Stewardship Committee of the New York Society for Ethical Culture Environmentalists Against War
Erie Benedictines for Peace
Factory Farming Awareness Coalition Fossil Free Tompkins
Fox Valley Citizens for Peace & Justice Franciscan Action Network FreshWater Accountability Project Future Coalition
Gas Free Seneca
GBC Sustainability Team Global Justice Ecology Project Green Delaware
Green Party of Nassau County
Green Party US EcoAction Committee Green State Solutions
Greenpeace USA GreenRoots
Harford County Climate Action Hilton Head for Peace
Hoosier Environmental Council Howard County Climate Action iEat Green, LLC
Indivisible Nation BK Indivisible Ulster
Inner-City Neighborhood Art House Institute for Policy Studies Climate Policy Program
John Muir Project of Earth Island Institute Johns Hopkins Center for a Livable Future Kickapoo Peace Circle
Labor Network for Sustainability Livelihoods Knowledge Exchange Network Long Island Progressive Coalition
Morningside Gardens Green Committee for Environmental Sustainability
Mothers Out Front
Mothers Out Front – Long Island Team Mothers Out Front, Croton Hudson, NY Movement Rights
Nassau Hiking & Outdoor Club National Black Environmental Justice Network
National Family Farm Coalition NC Council of Churches
New Jersey Tenants Organization New York Communities for Change
New York Lawyers for the Public Interest NOFA-NH
North American Climate, Conservation and Environment (NACCE)
Northeast Organic Farming Association – Interstate Council
Northeast Organic Farming Association of Vermont
Northern Plains Resource Council Nuclear Age Peace Foundation
Nuclear Information and Resource Service NY Climate Advocacy Project
NYCD16 Indivisible Occupy Bergen County
Ocean Conservation Research
Orange Residents Against Pilgrim Pipelines Organic & Regenerative Investment Cooperative
People Demanding Action
People for a Healthy Environment People Over Pipelines
Peoples Climate Movement-NY Pesticide Action Network North America (PANNA)
Physicians for Social Responsibility Physicians for Social Responsibility FL Plymouth Friends for Clean Water Princeton Student Climate Initiative Protecting Our Waters
Physicians for Social Responsibility AZ – Director
Putnam Progressives Rachel Carson Council Ramapough Lunaape Nation Reach Out America
Regional Farm and Food Project Residents Allied for the Future of Tioga (RAFT)
River Guardian Foundation Rural Vermont
SCNY Office of Peace, Justice and Integrity of Creation
Seneca Lake Guardian Show Up LI
Sisters of Charity Federation
Sisters of St. Dominic of Blauvelt, New York Slow Food North Shore
Slow Food USA
Socially Responsible Agriculture Project SOMA Action
Stop the Algonquin Pipeline Expansion Sustainable Tompkins, Inc.
Tampa Heights Acupuncture The Banner
The Climate Mobilization North Jersey The Corner House
The Wei LLC
Thomas Berry Forum for Ecological Dialogue
Three Parks Independent Democrats Thrive_At_Life: Working Solutions Toxic Free North Carolina
Toxics Information Project (TIP) United Native Americans
Wall of Women Water Climate Trust
WESPAC Foundation, Inc. www.Eco-Poetry.org
1 U.S. Global Change Research Program. “Second State of the Carbon Cycle Report.” 2018 at 47 to 48.
2 U.S. Global Change Research Program. “Second State of the Carbon Cycle Report.” 2018 at 47 to 48.
3 Solomon, Susan. Et At. Irreversible climate change due to carbon dioxide emissions. Proceedings of that National Academy of Sciences. Feb 10, 2009. At 1704-1709.
4 U.S. Global Change Research Program. “Second State of the Carbon Cycle Report.” 2018 at 249 to 252.
5 Institute for Agriculture and Trade Policy (IATP). “Why carbon markets won’t work for agriculture.” January 2020
6 Kollmuss, Anja. Stockholm Environment Institute. “Has Joint Implementation reduced GHG emissions? Lessons
learned for the design of carbon market mechanisms.” August 2015 at 5.
7 Claassen, Rodger. U. S. Department of Agriculture (USDA). “Additionality in U.S. Agricultural Conservation and Regulatory Offset Programs.” July 2014 at 16.
8 Haya, Barbara. Goldman School Goldman School of Public Policy Working Paper. “The California Air Resources Board’s US Forest offset protocol underestimates leakage.” May 2019 at 1.
9 Food & Water Watch (FWW). “The Lose Lose Reality of RGGI.” April 9, 2018 at 1.
10 FWW. “Cap and Trade Hurts Environmental Justice.” December 2019 at 2.
11 FWW. “Biogas From Factory Farm Waste Has No Place in a Clean Energy Future.” July 2019 at 3.
12 Cushing, Lara, Dan Blaustein-Rejto, Madeline Wander, Manuel Pastor, James Sadd, Allen Zhu, and Rachel Morello-Frosch. “Carbon Trading, Co-Pollutants, and Environmental Equity: Evidence from California’s Cap-and-Trade Program (2011–2015).” PLOS Medicine, 2018, 1–21; Cushing, Lara J., Madeline Wander, Rachel Morello-Frosch, Manuel Pastor, Allen Zhu, and James Sadd. “A Preliminary Environmental Equity Assessment Of California’s Cap-and-Trade Program,” 2016. http://dornsife.usc.edu/PERE/enviro-equity-CA-cap-trade.
13Schneider, Lambert. Nature Climate Change. “Perverse effects of carbon markets on HFC-23 and SF6
abatement projects in Russia.” August 2015 at 1061–1063.
14 Congressional Research Service. “Environmental Quality Incentives Program (EQIP): Status and Issues.” R40197. May 9, 2011 at Table 3 on page 8.