Tag: LULUCF

Taking Stock of the Gigatonne Gap

ECO is deeply concerned that the planet is on a fast track to dangerous climate change. The lack of ambition and plain inaction by the world's richest countries has created a negative spiral that needs to be broken. So-called 'political realism' and current lifestyles will use up the global carbon budget by the early 2020s. Not unlike the financial crisis, an emergency bail-out package is needed to prevent a climate collapse.

There is a widely-acknowledged ‘gigatonne gap’ from the mitigation pledges made at Copenhagen to a global carbon budget and realistic pathway that will be consistent with avoiding dangerous warming of 2º C or more, not to mention 1.5º C, above pre-industrial levels.

On the current path, science tells us we are facing a world that is at least 3º to 4º C warmer. What does that mean?  The answers are shocking. This could spell the extinction of countries, ecosystems and species. People will perish. It is already starting to happen. Parties need to urgently take ownership of this gap and acknowledge the responsibility they share in closing it.

ECO has highlighted before that the complexity of the climate problem has instilled fear and mistrust – particularly between industrialized and developing countries. Without fairness and respect we will never have trust. The reality of historic responsibility, the difference in per capita emissions, the primary importance of development for countries whose populations struggle with the crisis of poverty – these are very real. The dynamic of fear and division is obscuring the urgency of the disaster we face.

The fundamental reason why the world is heading for a climate disaster is the feeble ambition on reduction targets and finance coming from all industrialized countries. In particular, the excessive emissions from the US now and to 2020 and beyond are stretching the world’s carbon budget beyond the breaking point.

Whatever else we could say about Copenhagen, it certainly underlined the need for a Fair, Ambitious and Binding agreement which combines the environmental security of a robust emissions cap with a much-needed energy and economic transformation spurred by policies, measures and innovation. Given the size of the gap, we urgently need creative thinking and courageous action.

Further work by SBSTA can support the analysis of available solutions and taking the necessary decisions. ECO proposes that Parties agree, here in Bonn, to hold a workshop under SBSTA Article 9 (‘Scientific, technical and socio-economic aspects of mitigation of climate change’) in the first inter-sessional before Cancún, to come to a common understanding of the scale of the gap, and for steps that could and must be taken to address it.

Developed countries have not adequately reduced their emissions since agreeing the Convention in 1992. The aggregate target of -5% agreed in Kyoto may have been a political success, but it was far from consistent with the scientific realities even at that time. And in the event, many Annex I countries haven't achieved those modest targets, and some have barely even tried. They need to do more.

And still, ECO also notes that fingerpointing is not a survival strategy. We will only stay afloat with a concerted effort from all, according to their abilities.

Climate realism requires action, not new accounting tricks.  So another problem is the loopholes that were built into the Kyoto architecture . . . LULUCF rules that hide increased forestry emissions, prodigious offsetting with little additionality (and not even targeted towards sustainable low carbon development), and AAU banking that has become an increasing concern as the end of the first commitment period approaches. The Secretariat’s technical paper recalculated the levels of effort pledged and sheds a clear light on the assumptions behind the targets. While these issues are part of the KP negotiations, they must also be put in a consolidated context.

Finally, ECO suggests that the workshop explore the potential of new sources, sectors and approaches to reduce radiative forcing in the atmosphere and generate funds to support action. Such innovative approaches could include, inter alia:

* International aviation and shipping, a large and rapidly growing source of emissions (business-as-usual would result in 2.2 Gt CO2 by 2020), and one that can be a significant source of climate finance.

* Designing REDD, market mechanisms, NAMAs, etc., to avoid double-counting of both developed country mitigation and financial support obligations, all relevant to the MRV agenda item.

* Reducing emissions of black carbon.

* Inclusion of new F-gases in the climate regime, as technically feasible.

* Taking industrial GHGs (N2O, HFCs and NF3) out of the CDM. Their abatement costs can be better met through a fund. The CDM can be better targeted at transformational measures.

A comprehensive and realistic approach to closing the gigatonne gap is needed now. The inclusion of new sources and sectors should not replace efforts in existing sectors, but be additional so as to bridge the gigatonne gap and peak global emissions by 2015.

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Deja vu? Or a renewed focus...

And now we’re all here again, what is it that needs to be accomplished?

Clearly, on the KP track lamentably little progress has bee made over the past four years. ECO suggests that the following issues must be agreed this year, as a priority:

  • LULUCF accounting rules – Annex I countries must stop trying to hide emissions from forest management and commit to reduce them instead.
  • CDM/JI/emissions trading modalities – These must be revamped to avoid double counting of mitigation and financial support obligations, and to keep inappropriate sectors, such as nuclear and CCS, out of the CDM.
  • New sources and sectors and other accounting rules around them (the “other issues”) should include new gases to the extent that is technically possible, and use the new IPCC AR4 global warming potential (GWP) measures over the 100 year timescale.
  • The commitment period length, base year and the other modalities that will define the calculation of the quantified emission reduction obligation (QERO) and assigned amount from country pledges (here's a free hint! correct answers for the first two are: 5 years, 1990).

When the KP was first negotiated, Parties agreed targets first, and the following years turned into excruciating negotiation exercises that ended up agreeing a series of loopholes. ECO has long maintained that the rules should be negotiated first, so that the science-indicated reduction target of at least 40% on 1990 levels by 2020 can be fairly shared between the Annex B Parties.

For this reason, negotiating time in Bonn and for the intersessionals should be concentrated on clearing these issues, so that the targets and then the discussion on QEROs can be resolved rationally and equitably, based on a clear and common understanding of the underlying scope and rules of accounting. In the short term, then, negotiating time should be concentrated on resolving the issues listed above.

In the LCA track, a balanced agreement is needed by Cancún, with each of the Bali Action Plan building blocks being addressed. In Copenhagen, the LCA negotiating texts on adaptation, technology and REDD+ were well advanced, and agreement should be possible on these issues this year. Additionally, finance, MRV and low carbon development plans should be among the agreements reached this year.

Adaptation

Most Parties seem to agree that progress can be made in Bonn on the design of an adaptation framework for implementation. However, developed countries should stop resisting a firm institutional link that ensures the provision of regular, reliable and truly additional grant-based finance needed to make this framework a real implementation action tool.

Bonn II could also achieve greater clarity on the enhancement, establishment, composition and role of regional centres and initiatives as well as the proposed establishment of an adaptation committee. Another issue that must advance is how to address unavoidable loss and damage from climate change impacts when adaptation is not longer a viable option, e.g., when water resources disappear due to shrinking glaciers and livelihoods become untenable. Progress in Bonn would be achieved if Parties clearly recognise the need for an international mechanism to address loss and damage, and identify key substantive issues to be addressed in subsequent sessions.

Technology

Technology negotiations have progressed enough that areas of clear convergence can be identified, especially regarding the establishment of a technology mechanism. More clarity is required to ensure that it operates within UNFCCC authority and principles. Other areas to be further clarified are the role of regional innovation centres, as well as criteria for MRV for technology support and actions that may take place outside the UNFCCC mechanism. Negotiators should be willing to show more flexibility regarding intellectual property issues, acknowledging the valid concerns of all parties, while focusing on a solution that will preserve incentives for innovation and ensure and expand production of, and access to, climate technologies for mitigation and adaptation.

REDD+

While ECO understands and agrees that reliable and adequate long-term funding is essential, goals for REDD and the conservation and enhancement of carbon stocks remain essential. There should also be a finance goal for support, either a specific range – a number of studies have indicated that halving emissions by 2020 would cost $15-35 billion in 2020 – or simply an agreement to finance achievement of the carbon-related goals. It is crucial to move on this now given the speed of REDD negotiations and the launch of the REDD+ partnership for fast-start financing last week.

Successful mitigation outcomes from REDD+ activities by developing countries,  supported by developed countries, depends on using improved methodological guidance for estimating emissions by sources and removals by sinks. SBSTA needs to progress this issue.

Climate integrity is not the only concern for REDD+ activities; safeguards not only need to be agreed, but the LCA text needs to operationalize them.

Finance

Climate finance can be a valuable opportunity to build some momentum in a process that needs a shot in the arm. Here in Bonn, parties should set ambitious goals for finance outcomes in Cancún, whether or not a comprehensive deal is agreed by then. To be more precise, by Cancún parties can finalize decisions covering finance MRV, governance and institution, and make substantial progress on operationalizing sources of finance to mobilize funding at the scale needed.

But it must be decided here in Bonn to achieve this by Cancún, and that means a negotiating text must be developed that will result in this outcome. ECO gives fair warning: for any parties thinking of blocking progress on finance because they didn’t get what they want in other areas, it's time to open eyes to the bright light of negotiating reality.

MRV

ECO recognizes the crucial role of gathering, in a consistent and comparable way, accurate information relating to emission reduction activities undertaken by Parties, as well as the support provided. Indeed, this is central to the integrity of the climate regime. Thus, it is vital to continue discussions on the nature of MRV, in particular its scope and architecture, that is tailored to Parties’ differentiated obligations.  In so doing, Parties should agree a process at this meeting to elaborate the main issues associated with MRV. Additionally, Parties should give the Chair a mandate to develop text on MRV for this and future negotiations. Parties should also consider how to provide capacity building and support to construct and maintain domestic reporting and verification systems in non-Annex I countries.

Zero- and Low-Carbon Action Plans

As part of the essential process to build trust among Parties through transparency of action, ECO would like to highlight the need to agree by Cancún that both developed and developing countries (with optional participation by LDCs and SIDS) will produce national plans showing how developed countries can get their emissions to near-zero by 2050, and how developing countries can reduce their emissions -- with support from developed countries as defined and agreed previously, including the Convention and the Bali Action Plan -- in line with the required overall global carbon budget.

Time for action is so short, there is no time to lose, and actions are needed now in line with the scientific imperative. There is much that can progress at the multilateral level this year. In Bonn, Parties must build upon progress in the LCA and KP tracks to date and define the expectations for a balanced and ambitious outcome in Cancún.

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Developed countries should produce Zero Carbon Action Plans (ZCAPs) to map out the institutions and policies needed for them to achieve their targets under a five-year commitment period, with the longer-term aim of near-total decarbonization by 2050.  ZCAPs would also serve to document how each country proposes to achieve their support obligations to developing countries.  Both parts of the ZCAP would be subject to MRV procedures to help ensure the environmental integrity of the deal and also to give all countries increased confidence that others will not free-ride.  The long-term component allows countries to begin to develop a long-term vision for their economies and to plan for related socioeconomic transition. The reporting, review and compliance components of the ZCAP proposal are therefore essential to the integrity of the overall deal and giving confidence that targets will be met.

Developing countries, over the short to medium run and depending on capacity, will produce visionary low-carbon action plans (LCAPs) that provide a road map and outline a trajectory for their pathway to a low-carbon and climate-resilient economy, clearly linking development and climate goals to achieve sustainable development.  These plans should be developed through a bottom-up, country-driven process and should build upon national plans for adaptation and mitigation, recognizing the linkages already in place in many countries between these issues.  They should provide an integrated framework where a country's NAMAs can form a coherent package.  These NAMAs would then form essential building blocks of a LCAP, and together their cumulative impact should result in the long-term objective of a low-carbon economy as well as stay within atmospheric limitations.  Mitigation efforts together with adaptation all contribute towards the overall LCAP.

ZCAPs and LCAPs link to a number of existing agenda items.  They are in the LCA text and are also relevant in the MRV discussions (MRV mitigation on non-Annex I, Annex I, the “firewall” between them, and MRV finance).  Because ECO sees them as being related to national communications, but forward- rather than backward-looking, SBI agenda items 3 and 4 (national communications for developed and developing countries) are also relevant.

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LULUCF: good rules before targets?

ECO has always called for “rules before targets” when it comes to land use, land use change and forestry (LULUCF). We certainly don't want to repeat the mistakes of Kyoto, when LULUCF rules were negotiated specifically to allow countries to meet their emissions reduction targets, rather than to aid in climate change mitigation or adaptation.  In that light, it makes sense for the Chair of the AWG-KP to call for rules to be finalized.

While ECO applauds the push to finalize text here in Bonn, agreeing the current LULUCF proposal would be even worse than the status quo. The proposal currently tabled would frame rules that actually allow countries to increase emissions and not account for them. This will seriously undermine targets for Annex I countries before they are even finalised. We assume this isn’t what the Chair of the Kyoto Protocol really wants to see.  In fact, it contrasts rather dramatically with the approach being proposed for REDD, which starts from the assumption of emissions reductions from non-Annex I countries.

Forest management accounting rules on the table from Copenhagen allow countries to hide or ignore substantial increased emissions from forest management in their baselines. Around 400 MT annually could be released without being accounted for, equivalent to 5% of the total 1990 emissions of all Annex I parties, and a significant fraction of their proposed reductions post-2012.

Instead, what we need is a strong and unambiguous commitment to deliver emissions reductions and increases in removals in this sector, in the form of a goal in the LULUCF framework. We also need to see protection for existing forest carbon stocks. We urge all parties to consider the consequences of enshrining hidden emissions increases into a climate deal and to instead move rapidly to reduce emissions from land use, land use change and forestry.

ECO has always called for “rules before targets” when it comes to land use, land use change and forestry (LULUCF). We certainly don't want to repeat the mistakes of Kyoto, when LULUCF rules were negotiated specifically to allow countries to meet their emissions reduction targets, rather than to aid in climate change mitigation or adaptation.  In that light, it makes sense for the Chair of the AWG-KP to call for rules to be finalized.

While ECO applauds the push to finalize text here in Bonn, agreeing the current LULUCF proposal would be even worse than the status quo. The proposal currently tabled would frame rules that actually allow countries to increase emissions and not account for them. This will seriously undermine targets for Annex I countries before they are even finalised. We assume this isn’t what the Chair of the Kyoto Protocol really wants to see.  In fact, it contrasts rather dramatically with the approach being proposed for REDD, which starts from the assumption of emissions reductions from non-Annex I countries.

Forest management accounting rules on the table from Copenhagen allow countries to hide or ignore substantial increased emissions from forest management in their baselines. Around 400 MT annually could be released without being accounted for, equivalent to 5% of the total 1990 emissions of all Annex I parties, and a significant fraction of their proposed reductions post-2012.

Instead, what we need is a strong and unambiguous commitment to deliver emissions reductions and increases in removals in this sector, in the form of a goal in the LULUCF framework. We also need to see protection for existing forest carbon stocks. We urge all parties to consider the consequences of enshrining hidden emissions increases into a climate deal and to instead move rapidly to reduce emissions from land use, land use change and forestry.

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Final Innings For a 2 Degree World !

Dear Delegates, It is April 2010 and we are back . . . with a whimper? The bottom line: Copenhagen wasn’t the stuff of dreams after all. It certainly didn’t deliver up our dream of a climate threshold well below 2 degree C (let alone 1.5 degree C) for the planet! Meanwhile, the science is ever more loudly telling us to kick-start a “race to the top” for more ambitious mitigation targets. Parties are busy finding distractions and reasons not to deliver the needed outcomes under the AWG-LCA and AWG-KP tracks. And none of this, sadly, is very different than what we observed in the long runup to Copenhagen. So here we are. All too many developed country parties continue playing to weaken the ability to deliver a fair, ambitious and binding outcome, based on narrow national interests. To take it beyond these generalities, ECO has a few suggestions where improvement is especially needed. First off, the existing LULUCF rules under the Kyoto Protocol, riddled with far too many loopholes, are leading to perverse outcomes as long predicted. And yet the revised rules drafted and partly negotiated at Copenhagen go even further in the wrong direction. Parties must abandon attempts to stretch the LULUCF rules even more, hiding future emission increases from the sector and undermining the integrity of a climate deal. A revised LULUCF framework must be free of loopholes, use historic baselines and not future projections, and set an explicit goal to actually reduce emissions and increase removals from forestry and land management. Surely this is not unreasonable for a climate deal ? Likewise, even after two full years of negotiations, the Shared Vision text coming out of Copenhagen is far from wholesome. One thing the text has is too many brackets. They surround a number of major elements including the long term global goal, developed country emissions, peak year, and review process. The current Shared Vision text also skips over the next commitment period, the legal nature of the outcome, and a compliance clause among other aspects. Instead, the Shared Vision needs to guide the negotiations toward the final outcome rather than be wrapped up at the end of the process. Next up, a focus of the negotiations that must not be lost. While all nations – especially top-emitting countries – should strive to put forward emissions reduction proposals that fully address the prospect of dangerous climate change, the pledges to date are far from what is needed. Instead of putting us on track to achieve the Copenhagen Accord commitment to keep increases below 2 Degree C, the pledges in hand instead lead toward nearly a 4 degree increase, according to a recent analysis by the Sustainability Institute. Not only that, merely pleading ‘political realities’ will not stem the rising Gigatonne Gap, as demonstrated by the current science. Catching up after 2020 really isn’t an option, is it, if we are serious about containing global warming. Now let’s turn to an issue that has been gaining prominence recently but needs more prioritisation. Everyone now agrees that adaptation is a major challenge . . . so let’s treat it that way. In the work plan for the rest of this year, Parties should focus on producing an adaptation text containing a concrete agreement on both fast-start and long-term finance, as well as a robust mechanism for delivery. The Adaptation Fund is proving to be an excellent mechanism with governance and outcomes founded on the principle of equity. Here is a working prototype for a well-managed, equitable and effective climate fund under the auspices of the UNFCCC. That brings up a broader point. There are troublesome winds blowing on the sources and scale of finance so that developed countries meet their obligations under the Convention. The Secretary-General has employed his good offices in convening the high-level Advisory Group on Climate Finance (AGF). But remember -- ultimately, Parties have the responsibility to produce a decision in Cancún. For fast track financing, developed countries should make good on longstanding commitments and provide expanded financial resources to the mechanisms that already exist under the authority of the COP – the Adaptation Fund, Least Developed Countries Fund and Special Climate Change Fund. Nearing the end of our highlights tour, let’s turn to REDD. Requests for further work on methodological issues in the draft LCA text should be agreed and forwarded to SBSTA at this meeting, so it can fully engage on this agenda in June. Meanwhile, the LCA REDD group should also continue its work at the June session full speed, focusing first on issues that can be resolved without reference to the broader process -- for example, the operationalization of safeguards, and an objective for REDD.Furthermore, time should be set aside in the LCA work plan to consider outstanding REDD issues that cut across to other aspects of mitigation such as MRV and NAMAs. Based on the submissions by parties post-Copenhagen, it is clear that developing country parties will not compromise on their core ask for a second commitment period of the Kyoto Protocol. The outcome of negotiations under the LCA track, regardless of form, must provide for and significantly advance the full implementation of financial obligations of developed countries under the Convention. And the legal form and nature of the LCA track outcome must be in full respect of equity principles, including “common but differentiated responsibilities”. We have reached the last innings on many fronts: inter-generational equity, intra-generational obligations, and the possibility of achieving the overarching goals of poverty alleviation and climate-neutral sustainable development. Yours sincerely, 6.8 billion people... and counting...on Planet Earth…

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CAN Intervention - KP Opening Intervention - 1 Jun 2010

Thank you Mr Chair, Distinguished delegates, Clearly, progress is needed on the KP track here in Bonn.

CAN would like to remind delegates that when the KP was first negotiated, Parties agreed targets first, and the following years were spent agreeing the loopholes to accommodate them - loopholes that have contributed to the gigatonnes gap between accounting for emissions and what the atmosphere actually sees.

It is CAN’s long-standing opinion that the underlying rules should be negotiated first, so that the needed reduction target of at-least -40% can be allocated between the Annex B Parties, based on a clear and common understanding of the underlying scope and accounting rules.

Negotiating time in Bonn and for the subsequent intersessionals should therefore be focused on reaching agreement on a number of issues, including:

  • Accounting rules that actually reduce net LULUCF emissions;
  • Modalities for the flexible mechanisms – to avoid double counting of developed country mitigation and financial support obligations, and keep out inappropriate sectors, such as nuclear and CCS
  • The AAU banking loophole
  • The scope of new sources and sectors and other accounting rules – the “other issues”
  • Commitment period length and base year

These issues need to be agreed, but not agreed at any cost. CAN has strong concerns about some of the proposals currently being discussed, especially for LULUCF.

In the LULUCF negotiations, Annex I Parties are proposing to make their forests part of the climate change problem, rather than part of the solution. They are proposing to increase their annual net emissions from forest management by approximately 400 Mt CO2e without even accounting for it. This type of proposal has absolutely no place in a global climate agreement.

At this session, Annex I Parties must stop the accounting games. Annex I Parties must commit to absolute reductions in net anthropogenic emissions from LULUCF and they must protect their forests and other natural ecosystems as reservoirs of greenhouse gases. Parties could then quickly agree to LULUCF rules that transparently meet these two principles.

Like so much in this process, time is not required to fix LULUCF, only political will and ambition.

Close the logging loophole now

Most developed countries came to Copenhagen asking the world to ignore planned increases in greenhouse gas emissions from logging and erase them from the books. It was a proposal that never deserved to see the light of day at a climate conference. Now it has to be put to rest.

The Climate Action Network has developed and proposed to negotiators a reasonable, technically sound and objective way to close the logging loophole: Account for all changes in forest management emissions compared to the average level of emissions between 1990-2007. It is so simple and so obvious that it’s boring.

It is imperative this loophole is closed if we are to have an agreement with environmental integrity. Closing this loophole will also strengthen overall targets by nearly 4%.

Will developed countries make this most basic commitment to environmental integrity or will they insist on keeping increased forestry emissions out of accounting even though they are in the atmosphere.

Austria, Australia, Canada, Finland, Japan, New Zealand and Sweden – ECO is looking right at you.

Brazil emerges as leader

In the fifth edition of the Germanwatch-CAN Europe Climate Change Performance Index (CCPI), Brazil climbed to fourth place, as Sweden slid down its LULUCF projected baseline and landed in fifth. As the top three places were left vacant, Brazil earned the top rank among 57 countries surveyed for the CCPI.

At the other end of the scale, Saudi Arabia and Canada finished last and second last respectively at 58 and 59. Saudi Arabia’s negative rating was for blocking a fair, ambitious and binding treaty to protect the most vulnerable developing countries. Canada earned second last place for its weak domestic climate policy, huge per capita emissions and lack of any kind of constructive engagement in the UN climate talks.

The USA also fared poorly – it was ranked 53 – as President Obama and the Congress have yet to make good on the mandate of renewal (and renewables) which swept him to office.

The Germanwatch CCPI is an independent report, ranking the 57 largest emitters on their efforts to protect the climate. This year, like last year, witnessed blank spaces for the first three ranks. This was because no country was on a path to keep warming as far below 2°C as possible. For details, visit germanwatch.org

AI loopholes

Those of us who don’t like playing Russian roulette with the planet are looking for aggregate developed country targets greater than -40% from 1990 levels by 2020. In that light, the nominal pledges from developed countries, adding up to a humble 13-19%, look quite bad. But if one includes loopholes that could still make their way into the final deal, they look still worse. You may think you can fool the public with creative accounting, but you definitely can’t fool the atmosphere.

Sadly, ECO concludes that when loopholes are used to the fullest extent, aggregate developed country pledges allow their emissions to increase from 1990 levels by 2020. Even partial use of these loopholes results in a terrible outcome for the planet.

  • Full banking and use of ‘hot air’ (surplus AAUs) from the first and second commitment periods may add up to an extra 6% of the Annex I aggregate emissions to the atmosphere, according to several studies.
  • Creative free-for-all LULUCF accounting may add another 5% to the atmosphere, in line with several studies.
  • Emissions from aviation and shipping are currently just a footnote to Annex I national totals, but they are certainly seen by the atmosphere. These emissions are best tackled through a global cap, but if this is not achieved they will continue to rise, requiring deeper cuts elsewhere to keep the climate safe. If we don’t get a global agreement, the expected overall increase in bunker emissions until 2020 would add a further 6% to developed country emissions in 2020.

With these loopholes, the atmosphere sees 17% more in 2020 than the nominal pledges suggest, leaving an aggregate of -2% to +4% over 1990. But there’s more. Developed countries plan to meet a significant portion of their reductions through offsets, between 1.1 and 1.5 Gt, according to ECO’s estimates – equivalent to 6-8% of 1990 emissions. So domestic developed country emissions may even exceed 10% above 1990 levels in 2020. If, as under the CDM, non-additional projects make up a substantial part of the offsets (ECO has seen studies quoting a range from 40% to 79%), this further undermines the effectiveness of the targets.

If these loopholes are not closed, the gap between what’s needed for a stable climate and current developed country pledges widens into a mighty chasm.

ECO is pleasantly surprised, though, to learn that the EU has beaten us to it and has been shining a light on Annex I loopholes in Kyoto Protocol discussions yesterday. Whatever next, a move to a 40% cut?

REDD haunted by LULUCF?

A spooky story for the last day of negotiations: Once upon a time, ECO recalls, a list of LULUCF principles was determined and included the following: "That the implementation of land use, land-use change and forestry activities contributes to the conservation of biodiversity and sustainable use of natural resources."

Yet today, under the rules for forests in developed countries, conversion of natural forests to plantations is not accounted.  Indeed, native forests and plantations are not even distinguished, making it impossible to directly track this important indicator of the impacts of LULUCF on biodiversity. The LULUCF principles have become wispy spirits haunting the forests of the North.

Today, forest conversion has become a bone of contention in the REDD discussions. ECO is glad to see that the safeguard against conversion of natural forests is back in the REDD text, although it is bracketed and vague. Inclusion of an improved version of this provision in the final Copenhagen agreement will be an important step towards banishing LULUCF spectres from REDD.

In addition, however, principles alone cannot ensure that REDD lives up to its promises. How will Parties ensure that conversion of natural forests to plantations does not occur under REDD as long as the definition of “forest” encompasses everything from tropical jungle to oil palm plantations?

Conversion of forests to plantations not only has dire consequences for biodiversity, it also increases emissoins.  And so ECO asks, what about the 'E' in REDD?  If you look closely, the definitional gap that exists in LULUCF as an important lesson for REDD.  Natural forests and plantations must be defined separately and emissions from conversion must be accounted for, just as degradation of forests must be defined and accounted for.

Relying on carbon accounting alone to prevent conversion is not enough, warn the ghosts of LULUCF, who whisper that accounting for degradation never became mandatory.  In the real world of tropical forests, proxies may be used to estimate carbon stocks, and if forest cover is one of them, then distinguishing plantations from forests becomes crucial. In addition, defining natural forests and plantations will help clarify what REDD is all about, and ensure confidence in its effectiveness to protect the climate.

ECO knows Parties are hesitant to enter a process of developing definitions akin to a recurring ghost story of the Marrakesh Accords. However, negotiators must use several potions to banish the phantoms of LULUCF loopholes. One of them is carbon accounting strong enough to ensure that emissions caused by conversion are seen by all and not just the atmosphere. Another is definitions. Employing the forest categories suggested by the Ad Hoc Technical Expert Group (AHTEG) of the Convention on

Biological Diversity would help protect REDD from the grinning spectre of unaccounted-for emissions lurking in the newly converted forests of Annex I.

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