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