Number 2022-01
WHEREAS, building upon 170+ policy resolutions approved since 1984, the National Wildlife Federation recognizes the need to mitigate the causes of climate change and to safeguard biodiversity, wildlife habitat, landscapes, and human livelihoods; and
WHEREAS, the Paris Agreement calls for limiting global warming to well below 2⁰C and preferably to 1.5⁰C compared to pre-industrial levels, and the Convention on Biological Diversity calls upon nations to develop national strategies for the conservation and sustainable use of biological diversity, with the UN Secretary-General characterizing the urgency to respond to climate change and deforestation as a “code red for humanity;” and
WHEREAS, achieving net zero greenhouse gas (GHG) emissions by 2050 to meet Paris Agreement goals will not be possible with emission reductions alone; and
WHEREAS, projects that use nature to avoid, reduce, remove store carbon, referred to as “natural climate solutions” (NCS), are generally more mature, less expensive, and have more environmental and socioeconomic co-benefits than technology-based carbon sequestration solutions, have significant potential for reducing peak global warming, and can and increase the scope, scale and pace of climate change mitigation; yet the readiness for upscaling nothwithstanding, NCS design and implementation must be readily adaptable to changing requirements for climate change mitigation as the US progresses toward achievement of net-zero carbon goals; and
WHEREAS, at the same time, NCS projects narrowly focused on emissions sequestration, reduction, or avoidance may inadvertently conflict with goals related to preserving biodiversity and increasing the adaptive capacity and resilience of ecosystems; and
WHEREAS, funding for climate change mitigation and adaptation falls far short of what experts at the IPCC estimate is necessary to avoid catastrophic social and environmental impacts; and that this shortfall is even greater in the land sector, despite the fact that well-planned NCS could provide other ecosystem services to support human thriving and community resilience, such as water quality regulation, urban heat island mitigation, and disaster risk reduction; and
WHEREAS, carbon markets represent a market-based instrument to encourage climate action, in both natural and developed terrestrial, wetland and aquatic systems by unlocking private capital; and the “carbon credits” or “offsets” generated from such removal and storage are currently being certified in registries allowing the credits to be legally sold and traded; and
WHEREAS, current NCS projects can suffer from shortfalls in monitoring, reporting, and verification; from lack of accounting for leakage, additionality, and permanence; and from issues of scale that may unintentionally increase risks to biodiversity and ecosystem services, disincentivize emission reductions, and increase carbon dioxide (CO2) emissions; and
WHEREAS, NCS often involve changes to forest management, including management and restoration of natural forest systems, reforestation, afforestation (planting of trees on landscapes currently lacking tree cover) and planting on monocultures; yet “reforestation” projects that involve planting of monocultures and afforestation of historically treeless landscapes can have harmful effects on native biodiversity; and definitions of “reforestation” currently used by the U.S. Department of Agriculture (USDA), UN Food and Agriculture Organization (UNFAO), and the UN Intergovernmental Panel on Climate Change (IPCC) can contribute to biodiversity loss; and
WHEREAS, carbon markets and other market-based incentives may present additional considerations for environmental justice and social equity; and
WHEREAS, there is an underutilized opportunity to support U.S. federal, state, territorial, and tribal governments, and private landowners and producers in forest management and restoration, sustainable agricultural practices, and other management activities that promote carbon storage and sequestration; and
WHEREAS, pursuant to Executive Order 13990 (Jan 2021), and reflecting the best available science and the recommendations of the National Academies of Sciences, Engineering, and Medicine (National Academies), a U.S. Federal interim estimated ”social cost of carbon” was set at $51/ton (CO2e); and raising the price of carbon is a major incentive if not requirement for increasing deployment of NCS; and
WHEREAS, federal, state, territorial, tribal, and local incentives could also support NCS deployment; and in particular, a federal tax credit for carbon capture, utilization, and sequestration (IRC Sec. 45Q) currently provides a financial incentive for technology-based CO2 capture and sequestration, an opportunity exists to replicate this successful model to spur analogous innovation and funding for NCS; and
WHEREAS, NCS include some regenerative agricultural practices, such as prairie strips, buffers, cover crops, rotational grazing, and conservation tillage that sequester carbon in the soil and reduce GHG emissions, while providing co-benefits, including improved wildlife habitat, water quality, resilience and reduced flood risk; and by purchasing carbon credits, companies effectively pay farmers and landowners to implement agricultural conservation practices or land uses changes that result in climate, biodiversity, and public benefit; and
WHEREAS, companies are increasingly investing in nascent ‘Ecosystem Services Markets’ (ESMs) by helping to finance conservation practices and purchasing the resulting credits for ecosystem services such as carbon sequestration, biodiversity, and reduced GHG emissions, nutrient loading, and reducing flood risk; and carbon sequestration credits are currently the most popular form of ESM credits for companies seeking to become ‘carbon neutral’ or even ‘carbon negative’; and
WHEREAS, ESMs and the registries that validate resulting ecosystem service credits, currently lack standardization, creating wide variability in the quality of credits, and in many instances causing ESMs to lack credibility and trust of landowners, farmers, and investors; and
WHEREAS, several ESMs and registries exclude early adopters of conservation practices; and
WHEREAS, most ESMs only pay for CO2e credits which account for carbon sequestration and nitrous oxide emissions reductions, but do not pay for other ecosystem services such as methane emissions reductions, biodiversity, water quality, and flood risk reduction; and
NOW, THEREFORE, BE IT RESOLVED that the National Wildlife Federation (NWF), at its Annual Meeting assembled June 7-11, 2022, supports efforts to stimulate deployment of ecologically appropriate natural climate solutions (NCS), which safeguard or enhance biodiversity and natural ecosystem services and functions; and
BE IT FURTHER RESOLVED that NWF calls for NCS projects to emphasize ecologically appropriate and climate-informed restoration and reforestation, including natural regeneration, thus supporting biodiversity conservation and recovery, forest health, wildlife, other ecosystem services, and sustainable livelihoods; and
BE IT FURTHER RESOLVED that NWF calls upon federal and state governments and private companies, while simultaneously avoiding and reducing GHG emissions to the fullest extent and as rapidly as feasible, to invest or trade only in high-integrity certified carbon credits with high potential for biodiversity recovery and protection and social co-benefits; and
BE IT FURTHER RESOLVED that NWF calls upon carbon credit registries to standardize measurement, monitoring, reporting and verification of NCS projects, accounting for transparency, double-counting, extrapolating carbon removal measurements, additionality, duration, permanence, jurisdictional scale, net sequestration, and biodiversity loss/gain; and to distinguish natural forests, prairies, and wetlands from areas managed for production and harvest of timber and other products; and
BE IT FURTHER RESOLVED that NWF calls for establishment of a national carbon price tied to the currently established U.S. Federal interim “social cost of carbon,” and rising to a level by 2030 which, based on best available science and the recommendations of the National Academies, optimizes the carbon capture and storage potential of NCS projects; and
BE IT FURTHER RESOLVED that NWF calls on Congress to enact federal tax credits akin to the 45Q program that would spur innovation and deployment of capital into NCS projects that sequester additional carbon through conservation and restoration of America’s grasslands, forests, wetlands, waters, and agricultural lands; and
BE IT FURTHER RESOLVED that Congress should direct executive agencies to establish standards for ESMs, carbon registries, and ESM credits, and establish a voluntary greenhouse gas technical assistance provider and third-party verifier certification program, providing certainty and clarity to those who wish to participate in these markets; and
BE IT FURTHER RESOLVED that NWF calls upon policymakers to thoroughly consider the social impacts of NCS projects, including by championing locally led projects, reducing barriers to small landowners, and ensuring the free, prior and informed consent of Indigenous peoples and local communities; and
BE IT FINALLY RESOLVED that the NWF calls upon the USDA, UNFAO, IPCC and other policymakers to redefine “reforestation” to include natural regeneration, and managed intervention to assist and accelerate regeneration as needed to conserve and reestablish native or landscape-appropriate functionally diverse natural forests.