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.

Agricultural and forest offsets are an ineffective policy for addressing the climate crisis

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.

• The majority of the earth’s carbon is stored in geological formations in the form of fossil Carbon locked in these “slow-exchange” reservoirs take tens of thousands to millions of years to cycle back into the atmosphere — unless interrupted by volcanic eruptions or fossil fuel extraction and combustion.¹
• “Fast-exchange” reservoirs like soil and biomass have limited storage capacity and may re-release carbon in a matter of decades — or sooner from land conversion, unmitigated erosion due to flood episodes, or ²
• The fast carbon cycle (oceans, soil, forests) cannot absorb and sequester fossil fuel carbon pollution, as proposed through soil offsets, on the timescale of fossil fuels either prior to or after extraction.³ The Earth is not an endless sponge to absorb fossil fuel If it was, we would not have climate change.
• Methods for measuring soil carbon sequestration remain underdeveloped, inconsistent, and influenced by specific climates and geographies.⁴ There is simply no way to accurately estimate carbon sequestration because the fast carbon cycle does not function this way. Establishing a price for offsets consistent with integrity principles, including “permanent” and “quantifiable,” perpetuates a myth that agriculture can sequester fossil carbon quickly and

Carbon offset programs are incompatible with sustainable agriculture and may drive further consolidation of farms and agribusinesses

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:

• Market-based carbon credit programs give additional leverage to already powerful corporations, including agribusinesses, that have long squeezed farm income and drained rural economies.⁵ Companies may continue to capture the majority of profits and valuable on-farm data at the expense of
• Carbon credit programs will likely be most feasible for larger operations, potentially leaving out smaller farms, farmers of color — including Black and Indigenous farmers and Tribal Nations — who are already underserved by USDA programs and Commodity Credit Corporation
• Benefits of carbon payments would not extend to organic and other operations that have already invested in regenerative and/or agroecological

Carbon credit programs are ineffective at reducing emissions and pollute environmental justice communities

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:

• A Stockholm Environment Institute report found that around 75% of offsets issued under the Kyoto Protocol were non-additional,⁶ meaning they would have occurred even

without the program in place. Similarly, a USDA study looking at conservation tillage practices found that only about 50% were additional.⁷

• A California Air Resources Board’s US Forest analysis found 82% of the credits reviewed “likely do not represent true emissions reductions” due to lenient accounting rules for leakage, resulting in an additional 80 million tons of CO2 emissions from over- crediting.⁸ The states in the Regional Greenhouse Gas Initiative, a multistate carbon offset program, increased gas generation by 11.2% during the first seven years of the offset program instead of accomplishing reductions, while renewables only increased by 1% over the same time period.⁹
• A Food & Water Watch analysis found that states with carbon credit programs saw emissions of CO2 and PM 2.5 increase in environmental justice communities, while emissions went down in more affluent communities.¹⁰ For example, when carbon offsets subsidize manure digesters at factory farms, they incentivize the creation of methane — a far more powerful greenhouse gas than CO2 — along with other harmful pollutants including ozone-forming volatile organic compounds, nitrates, ammonia, hydrogen sulfide, and harmful air pollutants emitted when the factory farm gas is combusted, all of which disproportionately impact environmental justice communities.¹¹
• Researchers analyzing California’s cap-and-trade program found that 52% of facilities increased emissions of greenhouse gases and co-pollutants, while cap-and-trade sources were disproportionately located in communities of ¹²
• Carbon markets are open to fraud. A study in Nature identifies hundreds of millions of dollars in profits made by Ukrainian and Russian companies selling fraudulent credits into the EU Emissions Trading ¹³

Building Back Better in agriculture means building healthier food systems and rural communities

USDA has the necessary tools to build soil health, protect water quality, and avoid greenhouse gas emissions while boosting farm income:

• The Environmental Quality Incentives Program (EQIP) pays farmers for practices that can build soil health and make farmland more resilient to a changing Yet up to 85% of farmers vying for EQIP funding are turned away in a given year.¹⁴
• USDA can close loopholes that enable unsustainable factory farms to capture conservation funding for use in other false solutions, such as building manure lagoons and creating factory farm gas
• The Conservation Stewardship Program (CSP) is an example that pays farmers to increase conservation in farming
• Rather than funding ad-hoc practices, incentives can activate a comprehensive strategy promoting widespread shifts to organic, regenerative, and agroecological farming Simply encouraging farmers to practice no-till agriculture, dependent upon fossil-fuel derived herbicides like glyphosate, for example, will not meaningfully reduce emissions or build healthy, resilient soil.

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.

Sincerely,

Original Signatories:

Biofuelwatch

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

Additional Signatories

198 methods                                                              

350 Butte County

350 New Hampshire 350Brooklyn

350NJ-Rockland 350NYC

350NYC

50by40

A Stone’s Throw Bed & Breakfast

A+ B2B Copy (Green tech specialization) ABC Earth Care Team

ActionAid USA

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.

Earthworks

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

GAIA

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

L&R Manufacturing

Labor Network for Sustainability Livelihoods Knowledge Exchange Network Long Island Progressive Coalition

MADRE

Milwaukee Riverkeeper

Morningside Gardens Green Committee for Environmental Sustainability

Mothers Out Front

Mothers Out Front – Long Island Team Mothers Out Front, Croton Hudson, NY Movement Rights

MoveOn.org Hoboken

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

Zero Hour

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

at 2.

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.