Tag: loopholes

LULUCF: the Second Agenda

You’ve heard about all the trouble with the logging loophole in LULUCF. But there’s another important agenda on emissions from non-forest lands under the Kyoto Protocol.
Several ideas such as mandatory accounting for cropland management and grazing land management, and the introduction of a new activity category of wetland management, have languished with very little discussion. Yet Parties seem to think they are on the downhill run wrapping up LULUCF.
Emission from biofuels (processing crops and burning them as transport fuels) also risks being mostly ignored at a time when they are expected to grow rapidly as an alternative to fossil fuels.
There are issues with data availability and accuracy in accounting for these activities. But that is no excuse for deferring action in the second commitment period. One thing that can be done is to use a hotspots approach, concentrate MRV efforts on identifying the lands with the most significant sources of emissions, and estimate these activities in the most accurate and practicable way whilst commencing on a SBSTA program to introduce more comprehensive accounting.
The new rules could well make a huge amount of forest management emissions vanish through a loophole, but even worse, also fail to capture significant emissions arising from the other land use activities.
There is still time to construct a complete agenda for LULUCF rules with integrity for the next commitment period, but there is not a moment more to lose.
 

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LULUCF on the Leading Edge of Failure

The LULUCF negotiations are heading towards the worst possible outcome for forests and are dragging down climate mitigation as a whole.  With each passing day it looks more and more likely a deal will be cut that allows developed countries to increase their annual emissions into the foreseeable future without any real accountability.  Do the national leaders who committed to ‘deep cuts’ in Copenhagen really know what is happening here in Tianjin?  Shouldn’t somebody tell them?

Yesterday Parties had a chance to consider an alternate path.  In an open session, Tuvalu proposed that countries should take responsibility if their emissions increase relative to the first commitment period.  It’s one way to create some basic accountability for changes in forest management. 

But this proposal was roundly rejected by some Annex I Parties with the excuse that it would be too politically difficult to account for these emissions in a fair manner.  The cursory treatment of Tuvalu’s proposal lasted less than an hour, leaving the distinct impression that developed countries would be happy never to discuss it again. 

The quick dismissal of viable accounting options is a travesty in light of the nearly two years wasted on developing a ‘reference levels’ approach that would allow developed countries to increase exploitation of their forests and artificially enhance their weak national targets.

And it gets even worse.  A large proportion of emissions from bioenergy, supposedly a low carbon energy source, will disappear entirely – unaccounted for while trees are harvested under weak forest management rules and counted as zero carbon in power stations.

ECO has learned not to expect much at all from the LULUCF negotiations.  But the citizens of a world increasingly threatened by climate change should reject this blatant abdication of accountability and responsibility, and demand that developed countries live up to their commitments to reduce emissions and protect and enhance forest carbon sinks.

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LULUCF: The Countdown Commences

 

With Cancun looming, a push is coming to get much of LULUCF finalised here in Tianjin.  ECO cannot stress enough: it is more important than ever to get strong rules for forest management accounting. Proposals in the form of projected baselines for forest management that allow countries to increase anthropogenic emissions into the future without accounting them need to be rejected.

Avid readers will recall that ECO has been calling for emissions from forest management to be measured compared to what happened in the past -- just like all other sectors – and not to uncertain futures determined by Parties. In the current text, the proposal put forward by Tuvalu is the only one that attempts to incorporate this principle, and time must be found on the agenda in Tianjin to discuss this. A methodological review, while helpful in ensuring transparency, will not bring hidden emissions back into the accounts.

Meanwhile, with so much focus on this now familiar issue, we must not lose sight of the other ways in which Parties are attempting to use accounting for their lands and forests to fiddle the system. While negotiators have been knocking heads on rules that may determine whether forest management accounting becomes mandatory (and so it must), what of the fate of the other land use activities? It remains an open question as to whether Parties will still be allowed to elect for cropland or grazing land management, or revegetation.

Additionally, crucial environmental safeguards should be maintained in accounting for natural disturbances so that when the storms come or wildfires rage, these aren’t put forward as yet another excuse for not
accounting for man-made emissions.

We are often told that LULUCF accounting with environmental integrity, while technically achievable, is not politically realistic. Dealing with dangerous climate change will be a much greater political problem than good LULUCF rules could ever be. 

And locking in loopholes in the climate accounting is the last thing that should be on negotiators’ minds.

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LULUCF: on the verge of a bad deal

Will the LULUCF roller coaster end in a train wreck? Last week was LULUCF week here in Bonn. It all started with a KP Chair intent on finalizing the LULUCF rules, despite the existence of enormous loopholes.  In particular, the approach to forest management accounting favoured by Annex I Parties would allow developed countries to increase their annual emissions without accounting for it. In Saturday’s contact group, the G77 and China presented a two-part proposal to try to limit the damage of this approach: a review process to allow independent scrutiny of how each developed country calculates its reference level, and the proposal for a cap on credits from forest management. The Group’s proposal includes an expert review that would have the power to make adjustments if the assumptions and methods of a country’s reference level were found to be flawed, if the projection contradicts historical data collected for the first commitment period, or if there are accounting inconsistencies that result in hidden emissions (e.g., not accounting for emissions from bioenergy use). The Group is clearly trying its best to close the loophole, but this effort is severely limited by a group of Annex I Parties who are uninterested in rigorous accountability and actual emission reductions.  Rather than Parties agreeing to an honest accounting framework, the G77 and China are being forced onto the back foot to develop partial fixes to limit the damage. Further evidence of this was provided in the follow-up proposal from Russia that it should have no cap on credits and no obligation to account for increased net emissions until the forest sink is wiped out. These talks are in dire need of some leadership from developed countries. ECO maintains that accounting must be based on comparisons to the long-term historical average before the start of the first commitment period (i.e., 1990-2007), and that the goal of LULUCF must be to reduce net anthropogenic emissions, not let them increase. And lest we forget our natural forest ecosystems, they must be protected! Unless Annex 1 Parties adopt fair reference levels based on historical average emissions, a cap on credits may be needed as a second-best solution for LULUCF rules that are on the verge of becoming even weaker.  But the cap should not be applied to debits; even as every effort is being made to exclude emissions from the accounting, it would be even more perverse to further limit a Party’s obligation to account for emissions by also capping debits. Finally, accounting for Forest Management must be mandatory. After bending over backwards to accommodate the national interests and aversion to real debits by Annex I Parties, voluntary accounting would simply ensure that no good could ever come of this framework.

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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?

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