inventory and impacts of climate change on future growth and mortality had not been part of forest management and planning processes, some forestry programs were not fully prepared, even if involved, to weigh in on the carbon commitments being made. Revenues and costs. From the records, it appears that tribes have been receiving carbon prices and contract terms that are comparable to non-tribal owners, although IFMAT did not conduct a thorough analysis of this question. The uses of carbon market revenue varied across participating tribes. It is unclear how much is being reinvested to support forest management, regeneration, or protection of lands and resources. Tribes have reported that revenue from market participation has been used to increase tribal investment accounts, reinvest in tribal infrastructure, increase services to members, invest in improving energy use and efficiency, and providing seed funding for other cultural and natural resource initiatives. Several tribes have dedicated carbon revenue into purchasing forest lands, within their ancestral territory and therefore expand their forest ownership and diversity beyond their trust lands in an overall strategy of self-government. They saw this use as a positive contribution to their tribe’s vision to fortify the resource base and to provide management opportunities and flexibility beyond their trust lands. Tribes have also reported other benefits of market involvement, including incentives for maintaining long-term
The policy states that BIA and the Office of the Solicitor will review carbon agreements to determine if they are subject to Secretarial approval. Agreements that do not restrict use of the land but only require the tribe to manage the land to earn credits do not require recordation. The review will assess whether the agreement requires actions that are inconsistent with the existing agreements that encumber trust lands for seven or more years, or give control to a third party, require Secretarial approval. forest or natural resources management plans. Only Tribal forest carbon management actions must be consistent with the tribe’s management plan(s), regardless of the requirement for approval. Tribes may add allotments to carbon agreements if they are included in a tribe’s approved resource management plan(s). According to this guidance, the tribe will supply the BIA Line Officer with an assessment of effects, including financial, of carbon sequestration management activities outlined in the carbon sequestration agreement and in the current IRMP and/or FMP. If agreement activities conflict with an approved management plan, the tribe must revise and resubmit the plan to address the new management priority. Carbon agreements are not allowed to interfere with the protection of trust assets, for example in the use of fire suppression actions where timber may be burned to reduce fire damage. BIA’s policy maintains the view that carbon sequestration is not a trust asset and therefore largely outside BIA oversight unless there is a clear encumbrance on other land uses. This view allowed
management and retaining forest land use, progress in creating new jobs, and the opportunity to advance tribal self-determination by providing independent sources of revenue. Some tribes raised questions about the costs of verification, monitoring, and additional inventory. Of special concern were the total costs (direct, indirect, and opportunity) of using limited human capacity to assist in verification and inventory processes. Several tribes questioned the level of carbon credit set-asides necessary to insure against project reversals and leakage. Market participation barriers exist for tribes with smaller forest ownership in the current market structure. Some tribes have considered but declined market participation because of high transaction costs, verification demands, long term commitments, incompatibility with tribal goals, and other factors. Several tribes are looking into forming a collaborative to reduce per unit costs and market forest carbon, water, and other environmental credits together. Future of carbon market participation The BIA Division of Forestry and Wildland Fire Management Office of Trust Services published a partial clarification of carbon sequestration policy in the fee- to-trust process (US Department of the Interior BIA 2022). The policy reiterated that carbon is not considered a trust asset because it is neither “harvested” nor “extracted” and therefore not a “forest product.” Unlike trust assets, the value of the forest sequestration comes from its ability to store carbon rather than remove it.
176 Assessment of Indian Forests and Forest Management in the United States
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