CDM black market

“I give you CCS in CDM if you give me forests in exhaustion in CDM” is one of the popular negotiation techniques that ECO observed over the past few days. Is this really how the UNFCCC seals its deals? ECO is seriously concerned that the “negotiators” forget that they don’t barter apples for pears. Possibly they don’t even know which goods they are handling.

Currently, any plantation established on land that was forested after 1 January 1990 is excluded from the CDM. However, based on a request by CMP4, the CDM Executive Board adopted a definition for land with “forests in exhaustion” as CDM afforestation and reforestation project activities to be possibly approved by CMP5. According to this new definition, CDM could support industrial tree plantations in areas that were “forests” either as of 31 December 1989 and/or at the start of the CDM project activity, provided that they will be converted to non-forested land through final harvesting within five years.

When looking at the impact of this definition let’s clarify first things first: Forests in exhaustion are actually not forests. The forest definition under the UNFCCC includes existing monoculture tree plantations. In practice, this applies to the millions of hectares of peatlands that have been drained for oil palm and pulp wood. The loss of these carbon rich soils causes ongoing emissions of up to 90 tonnes CO2 per ha/yr, /200 million Mt CO2 per year. Support for these emissive plantations is support for deforestation. The new definition would just benefit large existing forest plantations in Indonesia, Malaysia and Brazil while LDCs would lose as they hardly have plantations. It would moreover open doors to forest management under the CDM which severely contradicts the agreement reached in Marrakech. Any amendment of the current definition of “forests” should rather exclude plantations and must under all conditions avoid extending it to the management of existing tree plantations.

Besides, this definition is highly problematic as it builds on a hypothetical assumption that plantations (alias forests) will be converted to non-forested land in five years. How do you prove that the land would have actually been finally harvested in five years if CDM supports the plantation to continue beyond that period? It rather seems like throwing money to a commercial activity that might continue anyway. This rings a bell. Eco reminds that the CDM is already suffering from one characteristic which is based on hypothetical assumption. The current project-by-project additionality testing is inherently subjective and impossible to do accurately and is leading to millions of non-additional CERs that are eagerly used by AI countries to offset their emission reduction obligations. Any countries out there that might think to seal a deal for CCS in CDM by accepting this misleading new project activity must think twice. ECO does not believe that CCS in CDM can pay for the huge negative impact that this new definition would bring along. Negotiators, please handle with care!