LULUCF Reference Levels: Technical Review Good, Policy Deeply Flawed

5 December 2011

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.