Tag: Forests-Sinks

LULUCF for Ministers

Ministers, your attention is about to be rewarded.  This article aims to preserve your sanity.

In the past, ministers have run out of closed rooms when asked to make decisions on LULUCF. When a minister once was asked how the LULUCF rules were progressing in Marrakesh he replied, “I have no idea. It is like fighting in a fog and the civil servants have all of the weapons”.

The basics of LULUCF are not hard, just weird, and they work in opposition to the rest of the UNFCCC process. For example, it is generally assumed that developed countries should be cutting their emissions, or at least trying to. This is not the case in the Alice in Wonderland world of LULUCF; quite the opposite in fact.

To begin with, the ‘rules’ are currently optional, so if a country thinks that a LULUCF activity such as forest management will result in an emission, then it can choose not to account for it. If it thinks that the activity will result in a removal, then it will account for it and take the credit.

Are you with us so far? Can you imagine the fuss if developed countries arbitrarily decided not to account for industrial emissions? This is what is commonly known as legalised cheating.

So we offer a remedy.  Ministers should ensure that developed countries have to account for all LULUCF emissions and removals, not just the ones that suit them. This is called mandatory accounting and it really should be a core principle, or at the very least apply to forest management and wetlands.

It gets worse. The new rules on forest management are likely to allow countries to account for emissions however they choose, giving a whole new meaning to the word ‘rule’.

The most popular option (Option 1) is for the reference level (baseline) to be a projection, which assumes that emissions will increase, thereby ensuring that no emissions have to be accounted for.

Imagine this ‘rule’ being applied to electricity generation. A country could build as many new coal-fired power stations as it liked, and as long as the country first announced that it would do so, they would not have to account for any of the emissions. Bearing this in mind, ministers should reject Option 1 and go for either Option 2 (proposed by the Africa Group) or Option 3 (by Tuvalu) instead. These are not ideal but they are a lot better than Option 1; almost anything would be.

Now for another mind-bender.  To fully understand Harvested Wood Products (HWP) requires a twists in logic that we hope that ministers will not countenance, so here’s very simple advice. Just go for Option 3.

Last but not least, there is a proposal called FLU, which is as nasty as it sounds. This is an attempt to rewrite the Kyoto Protocol’s article 3.3. Reject “flexible land use” out of hand.

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African COP, African Perspectives

To commemorate the opening of the High Level Segment of the “African COP” in Durban, ECO invited African NGOs to submit thematic articles on the often
urgent challenges of climate change and the compelling opportunities for
response.  Like the continent itself, the essays here are diverse, but unite on
common ground: the readiness, given necessary and required support, to devise African solutions on the ground to the climate challenge.

Overview

Apart from ensuring plenty of air-time for adaptation and vulnerability in Africa, what can South Africa and the COP Presidency do to honor the expectations attached to being host for the ‘African COP? Could the outcome end up so poor, so far from the principles and objectives of the Convention, that South Africa would prefer to denounce rather than
defend the process?

Token reference to a 1.5° C stabilisation level is meaningless to Africa as long as we remain so far from targets that are consistent with having half a chance of remaining below 2°. At this point deciding a time-bound process for robust review of ambition and action would be more useful.

Developed countries that are historically responsible for the climate crisis must step up and pay their dues. An appropriate Shared
Vision will be a mirage if not accompanied by the means to ensure that global emissions will peak about mid-decade.

Operationalising Cancun won’t be sufficient to mobilise finance for adaptation, beyond the trickle seeping into the Adaptation Fund. With the focus now on a new fund – design, governance etc., there is too little happening to actually raise the finance.

A straightforward matter such as requesting the IMO to proceed to design a levy, to put a price on carbon consistent with its own principles and that of ‘common but differentiated responsibilities and respective capabilities’ with a rebate system has, we hear, been made unmanageable by constraints behind a discussion of a broader framework.

Mobilising public finance is a clear imperative. There is no rationale or need to impede development of a finance-raising levy on bunker fuels by restricting discussions to sectoral approaches to mitigation. Financial transactions taxes are in the wings if not yet on stage, and Africa has a right to a portion of such resources and a myriad of opportunities to use it for green growth.

This is not, as some North Americans like to suggest, an issue of ‘guilt money’, it is an opportunity for sustainable development to the benefit of all humanity, and it is in our collective interest to enable ‘leap-frogging’ – an efficient transition to best available technology globally. Responsibility is not guilt. The Green Climate Fund is global because the benefits will be global, particularly if developing countries are allowed to access and use the funds in alignment with pressing development imperatives – should sufficient funds be forthcoming.

The right to sustainable development is not asserted to shame or assign guilt to those in economies that have grown rapidly through use of fossil fuels – it simply seeks to restore some balance, and efficient direction of resources to put all of humanity on a sustainable footing. The powerful should not be so fearful of yielding leverage over others that the entire system is so profoundly compromised that it cannot support the majority of people alive. 

And by the way: How old will you be in 2050? It seems that very few negotiators have contemplated the world even one generation from now. Do NGOs really need to repeat that about the opportunities to put in place what is required.  And is there any point when some of the needed text has already been written, but subsequently removed?

Much of the discussion in the first week has been about what we might hope to see in place at some time in the future, perhaps post-2020. After this, defending a deadline for an agreement in four years time is held out as a positive outcome!

Will there ever be a ‘make-or-break’ moment for the UNFCCC, or the processes for implementing it? Certainly it doesn’t look very good for  Qatar serving as a big step up if Durban does not produce what we need.

So here’s an idea. What if scenarios of potential COP 17 outcomes were named for trees? Perhaps a positive outcome would be a Baobab; certainly an Acacia would have to feature as nationally appropriate and offering welcome shade and resilience. What would a poor outcome be? A Welwichia – native to Namibia, far from decorative, but still providing a habitat? The vision of a long-dead and weathered log is on the horizon, but what would the alien invasive tree look like?

In South Africa, the Working for Water Programme roots out alien invasive trees.  But there isn’t a ready process for a COP Presidency to disown or defeat an unacceptable outcome, though there is precedent.

African NGOs hope to hear and see a lot more this week about what will be happening before 2015, including from the beginning of 2012. If the initial high-level sessions in Durban do not offer decisions for this timeframe, giving clear direction not just on additional institutions, but on moving money and continuing the Kyoto Protocol, African Parties should consider putting their host on notice that the outcome may face rejection.

 

North Africa

In the aftermath of the ‘Arab spring’ across the region, North Africa is spiraling upward with change in the follow-on to Tunisia, Egypt, and Libya’s revolutions. Civil society is finally rising up and vocalizing a myriad of concerns they have over issues ranging from democratization, human rights, labor and the environment. With the empowerment of the people, North African governments are cautiously listening to their demands. Yet with the rising impacts of climate change on this hot arid region, concerns will only escalate.

According to a recent World Meteorological Organisation (WMO) report, there will be a 20% decrease in water flow in the Nile River to Egypt. This is occurring in a country that is already severely affected by water scarcity and is currently below the water poverty line. The report also projects that these impacts will hit countries at a much faster rate than originally predicted, with sea levels rising almost 1 m instead of 0.5 m by 2050.  This means the delta in Egypt – the food basket of Egypt’s agricultural lands – will be inundated by up to 75%. These impacts will devastate the region and magnify the food and water security crisis for millions.

Earlier this year, the people of North Africa took to the streets to protest against increasing food prices, lack of jobs and insufficient resources.  Those challenges are already being increased by climate change. The governments of North Africa have a golden opportunity to act domestically with the creation of green jobs that will meet the needs of their people, economy, and the climate. Governments also have an important role in the global climate negotiations to push developed countries to increase their ambition targets as well as their financing capacity and deliver to address urgent concerns of the looming impacts of climate change on their people. 

 

East Africa

For poor farmers and pastoralists in East Africa, the climate has already changed and the impacts are severe, having claimed lives and livelihoods of people who contributed little to the situation. It is also certain that it will cost far more if concerted action is not taken soon.

In East Africa, climate change has amplified a chain of disasters: floods, extreme droughts, seasonal shifts and crop failure, animal diseases, water and fodder shortage, and social collapse. The current drought – the worst in decades, following the failure of both the main and short rain seasons – has reportedly affected 12 million and the real number may be far more. It has brought to famine in Somalia, claiming lives primarily of women and children, and rendering others refugees in Ethiopia. The survival of pastoralists is threatened by the death of thousands of livestock on which they are heavily dependent.

Droughts and famine in East Africa have been increasingly frequent over the last three decades. The region is and has been the leading humanitarian aid recipient. Changing this situation requires meaningful actions that will bend the global emissions curve into decline.

Over the years foreign aid has helped those who are affected by drought conditions, but such support has not extended to delivering the change desired by the people. The only thing that keeps changing is the climate and the degree of its impacts, making millions of farmers and pastoralists in the region suffer absolute poverty. Here is an appeal to the developed world which has been providing humanitarian support: real help requires implementing climate change response actions immediately. Help the people to adapt and take actions that will stabilize the climate, and the people of East Africa will find their own way out of poverty.

 

West Africa

For most African countries, increasing vulnerability to the impacts of climate change is a present danger, particularly for the rural poor, the great majority of whom are farmers. With increasing land degradation, desertification and soil erosion hitting hard at the local level and poor women and men totally reliant on natural resources for their survival, the need for adaptation support could not be more urgent.

The results of multilateral climate negotiations therefore have a huge impact on African lives. Smallholder, predominantly family-operated farms produce about 80 % of most African economies’ total agricultural output.

In Ghana for example, half of the labour force, or 4.2 million people, are directly engaged in agriculture, which is heavily dependent on rainfall. Food production fluctuates from year to year with variations in rains during and between growing seasons. In Ghana, the total area under formal irrigation is around 11,000 hectares whereas the potential area – including inland valleys – that could be developed for irrigation is estimated at 500,000 hectares.

The urgent need for a comprehensive adaptation framework, supported by adequate and predictable finance, cannot be overstated. Progress in this area has remained elusive for successive COPs. Instead, their mandate is applied in pursuit of narrow near-term interests of parties caught up in a web of diplomacy.

In Nagbere, a community in the Upper East region of Ghana, vegetable production – the only source of livelihoods for over 600 inhabitants – has collapsed due to long periods of drought. “We are not able to use very well the few heavy rains we get at certain periods during the year”, reported a local farmer in the community.

Creating resilient and sustainable societies requires substantial intervention to develop adaptive capacity of vulnerable communities and to maintain a healthy agriculture for improved food security. Timely provision of adaptation funds is critical to eradicating poverty and the achievement of the Millennium Development Goals.

Timely adaptation measures will enable communities to take charge of their future and increase resilience. Unfortunately, in Durban we see appalling obstinacy by some of the major polluters rather than progressing the ultimate objective of the Convention.

African women, led by the late Wangari Maathai, took the simple first step step of digging a hole and placing in it a seedling. By so doing, they demonstrated commitment to adapting to their changing climate. If they could do that, why then the delay in releasing the green funds for climate change adaptation?

 

South Africa

The agreement of a further two-year phase of the Nairobi Work Programme, including specific focus areas on ecosystem-based approaches and on water, is a welcome development. This highlights the need for full consideration of the tensions between water and energy security, within the context of water scarcity in southern Africa and a heavy dependence on coal through South Africa’s dominance in the subregion and position as anchor of the Southern African Power Pool.

The Olifant’s River in SA’s Mpumalanga Province provides a classic example of the lack of ecosystem-based integrated planning.  The water of the Olifants is too polluted – almost entirely by coal mining to be used for cooling downstream coal-fired power plants. Water catchment management, with an ecosystem-wide approach, is not only a national but a regional imperative, yet the Southern African Development Community (SADC) lacks capacity to involve stakeholders in such regional planning.

Recent promotion of desalination raises additional concerns regarding overall resource efficiency and the potential for diminishing returns on investment, given the energy inputs required to ensure water supply, with current energy supply being from thirsty fossil-based processes. The concept of Energy Return On Energy Invested (EROEI), which is diminishing for fossil resources, but improving for renewable energy technologies, will also need to be applied to water supply. Adapting to
increasing water scarcity requires that supply should also be subject to resource efficiency standards, to optimise value derived from ecosystem services.

In this specific example we see how one output of the climate negotiations, the Nairobi Work Programme, is providing the context for making a positive contribution to sustainable natural resource management down on the ground.

 

Africa for Integrity

At this African COP, it is gratifying to see the Africa Group tabling a number of constructive proposals aiming to bring environmental integrity back to the Kyoto
Protocol.

On the issue of hot air, the Africa Group is proposing that the carry-over of surplus AAUs from the first to the second commitment period be limited to 1% of each party’s assigned amount for the first commitment period, and that parties be allowed to sell the carried-over amount, with 50% of the revenue to be transferred to the Adaptation Fund.

In the LULUCF negotiations, the group has put forward a proposal that would act to lower the free credits countries get from managing their forests. While it doesn’t fully solve the issue of unaccounted emissions in LULUCF, this compromise proposal is a step in the right direction.

These proposals may not be perfect, but they put forward compromises that take us towards environmental integrity needed at the core of global climate efforts.

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10 Points of Action

Ministers – thank goodness you are here. Your delegations may have been burning some midnight oil in the last few days – but they have left the hard decisions for you! Here’s what your agenda for the next 4 days looks like:

1.  Don’t just “Mind the Gap” – do something! Ministers, at Durban you must show that you live on the same planet as the rest of us and acknowledge that the current mitigation pathway puts us on track for over 4° C warming. You must explicitly acknowledge the 6 to 11 Gigatonne gap, agree to a 2012 work plan to close the gap by increasing developed country targets to at least 40% by 2020, and provide guidelines and timeframes for NAMAs to be registered and supported where required. The ambition work plan must include clear markers through 2012, including submissions, technical papers and a dedicated intersessional meeting, to ensure we don’t have another year of wishy washy workshops with outcomes.

2. Commit for the long term. Negotiators have made no progress at all in setting a peak year and a long term global goal for emissions. Ministers now should explicitly agree that each country contribute their fair share to the globally needed mitigation effort, leading to a peak by 2015 and a reduction of global emissions of at least 80% below 1990 by 2050.

3. Stop spinning wheels in the Review. Ministers need to ensure that the Review will be effective, and limiting the scope will help it get off the ground as an effective instrument. We must focus on the important things: reviewing the long-term goal and the overall progress towards achieving it. Leave the biannual reports under MRV to cover the inputs like the means of implementation.

4. High Time for legally binding. A 5 year long second commitment period of the Kyoto Protocol is an absolute necessity as it contains important architectural elements which are crucial to ensure that mitigation commitments are legally binding and have environmental integrity. Nobody believes that a temperature rise of 4° C might be OK. So now is the moment to act decisively. An LCA mandate to agree a comprehensive legally binding instrument can build on the KP. Parties need to go beyond their long stated positions and immediately kick off negotiations toward a comprehensive, fair, ambitious and binding agreement to be agreed no later than 2015.

6. KP is essential – but it must have integrity. When added together, loopholes in the KP could wipe out Annex I ambition for the second commitment period.

In LULUCF, hidden and unaccounted emissions could significantly undermine Annex I targets, and cause us to doubt your commitment. Ministers must therefore ensure emissions from forests and land use are accurately accounted and reject the options on the table with the lowest environmental integrity.

All of the parties to this relationship know that the hot air / carried over AAUs is a bad joke that threatens to sour our relationship.  To keep it pure we need you to retire your surplus AAUs, or at least reduce them to 1%. Flexible mechanisms need clear rules and governance structures to avoid double counting of both emissions and finance, strengthen additionality testing and ensuring the standardization frenzy does not leave us with a highway for free-riders. Let’s start by keeping CCS and nuclear out of the CDM and let’s exclude coal power projects. Last but not least, we do indeed need stakeholder involvement in the CDM. Don’t back down, we are counting on you!

PS: CDM’s little brother JI has been up to a bunch of no-good stuff: hot air gussied up in new clothes (ERUs) is still hot air.

7. Fill the Fund. Operationalising the GCF in Durban is essential but not nearly enough – an empty fund is no good to anyone. We need initial capitalization of the GCF from developed country Parties in Durban. Reaching $100 billion per year by 2020 will require a commitment to scaled up finance from 2013 onward and clear progress on innovative approaches to generate finance. In Durban, parties should move forward on the establishment of mechanisms in the shipping and aviation sectors in a way that reduces emissions, generates finance, and ensures no burdens and costs on developing countries. Countries must also agree to a detailed one year work programme under the UNFCCC to consider a full range of innovative sources of public finance and report back to COP 18 with a proposal for action.

8. Gear Up and Deliver Technology. Technology is heading in the right direction, but speed is needed! Don’t be held back by other laggards. The Tech Mechanism could be operational by the end of COP 18.

9. Feel the Love for Transparency and Stakeholders. Your negotiators excised stakeholders’ right to participate from the IAR text and subject to heavy bracketing in ICA. But we know, Ministers, that you recognize the worth of engaging stakeholders to create a better process – rather than having us only campaign from the outside. Current text also falls short on common accounting rules for Annex I countries and clarification of pledges for all countries. Surely we’ve learned from the financial crisis! Robust reporting, such as Biennial Reviews and Biennial Update Report guidelines, including tables for reporting actions, and a common reporting format for finance must be agreed in Durban, so countries can complete their biennial reports in time for the first review. And where would this relationship between us and the planet, be without compliance for our commitments!

10.  An ambitious adaptation package at the African COP. Good agreements on Loss and Damage and the Nairobi Work Programme have already been reached. Wrapping up the package will require agreement on a strong Adaptation Committee including active civil society observers and direct reporting to the COP (as well to the SBs when COP does not meet). Furthermore, guidelines for National Adaptation Plans for Least Developed Countries must be adopted, plus modalities on how other developing countries can take these up. The prioritisation for LDCs must of course not be undermined.

A strong role for local, affected communities and civil society in national planning processes, building on the principles agreed in the Cancun Adaptation Framework, is essential. Finally, Parties must ensure that the Adaptation Fund does not dry up because of decreasing CER prices and lack of new pledges to the Fund from developed countries.

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“It always seems impossible, until it is done!"

Manjeet Dhakal
Clean Energy Nepal
Program Director
Nepal

Photos: Civil Society meeting (top), UNFCCC Executive Secretary, Christiana Figueres, showing off the CAN COP17 lanyard (bottom).

Civil society lanyards proudly touting this quote by Nelson Mandela was a good choice by CAN and the perfect fit for Durban.  Its timeliness resonates with many a delegate at the climate negotiations here at COP17.  Indeed the promise of optimism and hope it gives must surely permeate the negotiations and secure for our planet what Mandela proved is possible despite the trials and tribulations on the path to achievement.  Even though we despair at the slow pace of the negotiations, we will continue to persevere in the spirit of this silent reminder until the seemingly impossible is accomplished.
 
This week, more than 25,000 delegates from over 190 countries are gathered here in the beautiful city of Durban, South Africa to progress talks on finalizing the climate deal and to take us closer to a fair, ambitious, and binding global deal. With the letdown of COP15 in Copenhagen, no one expected Cancun to score a redeeming package to ensure continuity in the process. But we know that Cancun was just the next step of a process, which needs to be finalized by this meeting.  Against this backdrop, Durban will be dominated by three major issues: the Kyoto commitments, financial matters, and the legal mandate for ongoing discussions. More than ever, we need a lot of optimism to move ahead and to make good progress.  

Now, it is the time to take a bold step on the second commitment period of the Kyoto Protocol that was adopted in 1997 with the aim of stabilizing green house gas emission in the atmosphere and holding developed countries accountable with binding targets. The first commitment period (2009 – 2012) ends this year, therefore, a decision must come out of this meeting. Major parties to the KP, including Japan, Russia, and Canada, have already signaled that they will not take on a second commitment because China and the United States—the world’s top two polluters that are not included in it. The European Union (EU) is prepared to sign up for a second round, but it insists that major developing countries, whose emissions are surging as their economies grow, must embrace and follow through on real commitments. Least developed Countries (LDCs), which includes Nepal, are strongly arguing for the KP to be strengthened and to raise the commitments of developed countries.  

The Durban COP will also be judged on whether the wealthy nations of the world will make good on their financial commitments to developing countries adaptation to climate change.  It was decided in Cancun to set up an umbrella Green Climate Fund (GCF) with thematic windows to address the varying needs of countries to deal with climate change. A Transitional Committee (TC) that was established to design the fund has come up with its report, but the situation does not seem to favor the hard work of the committee.

Since Bali (Indonesia, 2007), the climate discourse has shaped the two track approaches, which are the KP track and the Bali mandate track.  The Bali Road-map provides the building blocks of Adaptation, Mitigation, Finance, and Technology Development ,which are briefly covered in the Cancun Agreements.  But there are many other leftover issues mandated to be finalized by the Durban COP.  Some have linkages to the issues being discussed in the KP. There is a stronger voice all around to continue the KP even though it seems quite difficult to continue with two parallel processes forever.  The EU’s preference is to negotiate “a single global and comprehensive legally binding instrument,” including all emitters; although it would accept an “interim” solution whereby major emerging countries would accept a “road map” and timetable for treaty commitments.

Durban will also be judged by the decisions on Adaptation Framework and Technology mechanism i.e. Climate Technology Center (CTC) and diverse views on National Adaptation plan (NAP).
Let me finish with another quote from Nelson Mandela that I hope will encourage us all to be optimistic while moving forward.  He said,  “There were many dark moments when faith in humanity was sorely tested, but we should not and could not give up to despair.”  On the wisdom of these words, we must secure a mandate for working towards a strong legally binding agreement and for the continuation of the Kyoto Protocol – the only international agreement to cut emissions – if we are to avoid an unfolding disaster.
 

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Media Advisory – Webcast Notice: civil society expectations for a successful outcome of UN climate talks in Durban.

UNFCCC CLIMATE TALKS IN DURBAN:

CIVIL SOCIETY EXECUTIVES SET EXPECTATIONS FOR SECOND WEEK OF NEGOTIATIONS

[Durban, South Africa] Climate Action Network – International will host an exclusive media briefing, webcast live, to outline civil society expectations for a successful outcome of UN climate talks in Durban.

A panel of civil society executives will discuss the overall status of the negotiations and outline possible scenarios for a Durban outcome, highlighting how much is at stake at these talks and what Ministers arriving in Durban need to do in the second week in order to secure a successful conference.

The briefing takes place at the UNFCCC conference venue, on Monday, December 5, at 12:30 local time (10:30 GMT), Kosi Palm (ICC MR 21 ABCG), NGO Press Conference Room.

It will be webcast live at: http://bit.ly/CANwebcasts

Civil society leaders on the panel will include: Kumi Naidoo, Executive Director, Greenpeace International; Jim Leape, Director General, WWF International; Celine Charveriat, Director of Advocacy & Campaigns, Oxfam International; Sharan Burrow, General Secretary, International Trade Unions

What: Briefing on the UNFCCC climate negotiations in Durban

Where: Kosi Palm (ICC MR 21 ABCG) NGO Press Conference Room, UNFCCC conference venue, Durban

Webcast Live via www.unfccc.int, or at: http://bit.ly/CANwebcasts

When: 12:30 local time (10:30 GMT), Monday, December 5, 2011

Who: Kumi Naidoo – Executive Director, Greenpeace International
Jim Leape – Director General, WWF International
Celine Charveriat – Director of Advocacy & Campaigns, Oxfam International
Sharan Burrow – General Secretary, International Trade Unions

Climate Action Network (CAN) is a global network of over 700 NGOs working to promote government and individual action to limit human-induced climate change to ecologically sustainable levels. For more information go to: www.climatenetwork.org

For more information please contact:

David Turnbull, CAN International, +27 (0) 78 889 6827 (local mob)

Every day at 18:00 local time CAN gives the Fossil of the Day to the Parties that obstruct the negotiations the most. You can watch the Fossil ceremony at the CAN booth in the DEC building and get the press releases every day at: http://www.climatenetwork.org/fossil-of-the-day

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LULUCF Reference Levels: Technical Review Good, Policy Deeply Flawed

ECO recognises that significant time and effort have gone into improving the transparency and technical robustness of Annex I Parties’ proposed reference levels for forest management.

However, although the review process achieved those objectives, this is in no way sufficient to ensure the environmental integrity of the reference level approach to forest management accounting. Put bluntly, the policy premise of the reference level approach is deeply, irrevocably flawed.

Although the review process was able to identify and correct technical issues and inconsistencies in individual country reference levels, it was never intended to assess the broader policy implications of the reference level approach. These implications include the following:

Environmental integrity. The reference level approach would allow Annex I Parties to increase net emissions of greenhouse gases relative to current levels over the next commitment period without penalty. Over time, this approach could seriously undermine global climate change mitigation and result in a loss of forest carbon stocks in developed country forests.

Economy-wide mitigation. The forest management reference levels for some Annex I Parties have been set in a way that allows them to hide increases in emissions from managing their forests and therefore allows them to avoid undertaking mitigation actions in other sectors.

Comparability. One supposed strength of the reference level approach is that it is flexible enough to allow all Annex I Parties to adopt mandatory forest management accounting.

However, reference levels overshoot the flexibility actually needed several times over. The result is a framework in which a tonne of mitigation in one country is not necessarily equivalent to a tonne of mitigation in another country.

The review was designed to assess the technical robustness and transparency of Parties’ reference levels, and it did its job. It is now plainly and utterly apparent just how bad the effects of the reference level approach could be.

ECO therefore implores Parties to take a step back, consider the broader implications of the reference level approach and reject it in favour of one of the more robust options on the table as we head into the critical second week of negotiations here in Durban.

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