It’s been five years since Oregon’s Labor Day fires burned through a California forest offset project. That fire, the Lionshead Fire, destroyed a project called Warm Springs Phase I (ACR260). Well — at least we think the fire destroyed the project. After all this time, neither the project owner nor the California Air Resources Board (CARB) has disclosed the post-fire status of the project. What we’ve gleaned comes only from journalists who looked into the project. However, the rules are clear: the project needed to submit “a completed verified estimate of current carbon stocks within the offset project boundary within 23 months of the discovery of the unintentional reversal.”
Here we are, some 60 months later, still waiting for someone to make that information public.
If this story sounds familiar, that’s because we wrote about it more than two years ago. At the time, CARB and the offset registry ACR informed us that the project had properly reported the reversal, but for a series of technical reasons, the information wasn’t publicly available. By their account, the letter of the law had been fulfilled. However, the spirit of the law — timely disclosure and retirements from the buffer pool — has yet to be satisfied.
All of this matters because California’s forest offset program is in trouble. Since the Lionshead Fire, several other projects have severely burned. And, each time, CARB has needed to dip into the program’s buffer pool — a pool of “good” credits that the regulator uses to replace the credits lost when trees participating in the program burn or are otherwise damaged. This lets CARB satisfy its legal requirement that all offsets represent “permanent” reductions. Without the buffer pool, the program cannot operate.
Over the years, we’ve documented the steady decline of CARB’s buffer pool. Most strikingly, we estimate that almost 40 percent of the buffer pool has been consumed by wildfire. But only 20 percent of the buffer pool is specifically marked for compensating wildfire risk. And that 20 percent was meant to account for wildfire losses for the next century. The fact that wildfire has already consumed twice that amount in roughly a decade is, quite simply, alarming. Yes, the buffer pool still has credits in it. And, yes, the remaining credits can be used to cover any loss — including those from wildfire. But as wildfire eats up more and more of the buffer pool, will there still be enough left over to cover things like losses from drought or when projects go bankrupt?
Which brings us back to the Lionshead fire and reporting delays. Long reporting delays give the impression that the buffer pool is healthier than it is and that the program is functioning as intended. CARB reports that the buffer pool currently contains 28.3 million credits. But that number excludes the Lionshead Fire. If you factor in those losses, the buffer pool is roughly 10 percent smaller. Without transparency about the state of the buffer pool, it’s harder to hold lawmakers and regulators accountable for when California’s much lauded offsets program fails to deliver real climate benefits.