Comment Text:
FERN is pleased to provide comments to the CFTC and the interagency working group for its forthcoming study on the oversight of existing and prospective carbon markets. FERN, a not-for-profit organization based in Brussels, Belgium and Moreton-in-Marsh, UK, works to achieve greater environmental and social justice, focusing on forests and forest peoples’ rights in the policies and practices of the European Union. FERN has been monitoring and analyzing the development of the carbon markets for the past 10 years, with a particular emphasis on the EU Emissions Trading Scheme (EUETS) and the trading in carbon offset credits. We have summarized our analysis in a recent publication ‘Trading Carbon. How it works and why it’s controversial’ . FERN's submission - attached - summarises the key lessons we have taken from this analysis.