NAMA Dreaming / Dreaming of NAMAs

Do you sometimes wake up at night, thinking: I wish I knew what a credited NAMA was...? (If you do, you’ve clearly been here far too long - ECO recommends a cup of herbal tea and a walk along the Rhine.) Sadly, you are not alone. The wonderfully fuzzy clouds called NAMAs (Nationally Appropriate Mitigation Actions) are taking shape without anyone really knowing how the three oft-mentioned types of NAMAs should co-exist. By this ECO means: ‘unilateral’ NAMAs, mitigation action implemented solely by developing countries; ‘supported’ NAMAs, mitigation action financially supported by donor countries; and ‘credited’ NAMAs, actions that, like the CDM, result in some form of trade-able carbon credits. Seems distinct enough, but upon further reflection, ECO has some nagging questions about credited NAMAs:

- What role do parties envisage for the new market-based mechanisms in a NAMA framework?

-What role will CDM play? Will new mechanisms be complementary to CDM or will they replace CDM?

– Who will             ensure the         quality and accounting of offsets coming from any new market mechanisms?

Some things we already know: The different NAMAs have to be clearly defined to avoid double counting of the emission reductions and the finance provided. A governance structure is required to ensure sound MRV so that we can truly move towards closing the perilous emissions gap we are facing. It is essential that new mechanisms will not lead to greater offsetting opportunities for developed countries. Clearly, there is a lot to figure out before we will know if NAMAs are going to be a troubling dream that resolves by morning or a nightmare we never wake up from.

By the way, do you ever wonder (sometime in the hazy night) how “Low Carbon Development Plans” relate to NAMAs?!

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CAN Submission - Views on enhancing the cost-effectiveness of, and promoting, mitigation actions - Feb 2011

In this submission the Climate Action Network International looks at a non-exhaustive list of policies and measures which are aimed at directly or indirectly reducing or mitigating greenhouse gas emissions. For each of  the measures a short analysis will be provided together with an assessment of their cost-effectiveness. The types of measures discussed are placed under the categories financial instruments or regulatory approaches, both in a broad sense.

CAN Submission - CCS in the CDM - Feb 2011

In CAN’s view, discussions about the future of the flexible mechanisms including the consideration of new project  activities should be firmly grounded in an analysis of their performance so far. So far, the CDM has failed to meet its dual objectives of supporting cost-effective climate change mitigation and sustainable development in developing countries. Yet, even when accepting some of the well-known shortcomings of project-based CDM mechanisms, CCS is highly likely to fail most of the requirements in this specific offset framework. Therefore despite the abovementioned CMP decision, CAN does not believe including CCS in CDM is an appropriate way forward. Therefore this submission sets out  reasons for  CAN´s  opposition to the inclusion of CCS in CDM and subsequently addresses the different issues referred in paragraph 3 of  the CMP  Decision It should be noted, however, that this submission does not refer to use of various CCS technologies outside the CDM and for general mitigation purposes both in developed and developing nations.

CCS in the CDM: No Way Forward

In Saturday morning’s session on carbon capture and sequestration (CCS), ECO was shocked that the the option for keeping CCS out of the Clean Development Mechanism was absent from the text being forwarded to the CMP for a decision.
CCS has many problems and is some time away from being operational for large power stations.  And yet the door is opening to let it into the CDM by mandating a work programme. Could this be because the best way to accomplish enhanced oil recovery (EOR) is by pumping CO2 into the ground?
The inclusion of CCS is likely to give a perverse incentive to increase emissions and result in fairy tales in CDM project proposals. For example, it might be claimed that ‘by injecting CO2 into the ground, emissions will be reduced and a clean, state of the art technology will be transferred to a developing country.’ But what this actually means is, ‘by injecting CO2, we can squeeze even more oil out of the ground and even though the safety of CCS has not been established, if there are problems it won’t be in our backyard’.
ECO has long had a view that CCS does not belong in the CDM. It should be pointed out that according to the Marrakesh Accords, the inclusion of a new project type requires a showing that it is environmentally safe and sound. CCS is still in the demonstration phase and its safety has not been fully established, especially on long time scales. Furthermore, CCS is likely to be prohibitively expensive. And extra financing through the sale of carbon credits isn’t enough to increase the financial viability of such projects to the level needed.
In many cases, CCS in the CDM could actually be a foil for continuing to pump oil out of the ground. Just like an addicted smoker, we can’t seem to break our dirty habit.

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Keep the CDM Clean

The lack of attention to the environmental integrity of the CDM is a stain on the reputation of international efforts. In December 2009, the CDM Executive Board registered its first coal-fired power project, setting off two reactions: a firestorm of criticism from around the world and a wave of opportunistic applications from other coal projects.
Rather than heed the well-founded alarm of civil society, the EB approved a second 1,100 MW Tirora supercritical coal project under a faulty methodology. With well-documented concerns about the additionality of supercritical coal, and no avenue for addressing the oversight, this sends a sharply negative message about the integrity of the CDM,  
As for the CDM coal rush, it is a wonder to behold.  Some 20-odd coal based projects – including the 4,000 MW Sasan Ultra Mega Power Project (UMPP) capable of earning almost 4 million carbon credits per year while emitting over 20 million tonnes of CO2 – now sit in the CDM pipeline. The attempt to 
rebrand supercritical coal technology as an additional ‘clean’ energy option seems almost Orwellian. In the case of Sasan, the Indian government has mandated the use of supercritical technology in its Ultra Mega Power Project (UMPP) program, clearly undercutting the additionality claim.
Supercritical coal is a non-additional baseline technology for many rapidly industrializing countries and should not qualify for eligibility under the CDM. This is a climate scandal: carbon credits for a non-additional coal power plant deprive the world of much needed emission reductions, contribute little to sustainable development and lock in fossil fuel infrastructure for decades to come. The EB must remove the stain coal is placing on our efforts here in Cancun.

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CAN Position - Offsets - November 2009

CAN Position Statement : The Role of International Offsets in Light of Current Annex I Emissions Reduction Targets and Climate Financing Commitments. November 2009

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