CAN Comments: LULUCF accounting in the Geneva text, May 2015

~~CAN is encouraged that the Geneva negotiating text includes substantive sections on principles to govern LULUCF accounting.  We have long advocated such principles and we agree with much of the text.  However, we consider that it can be improved by streamlining the many similar options. In this briefing document, we first outline some things that we are particularly keen to see in the Paris agreement, then we outline the substantive options in the current text and we finally suggest a specific option.

Where we are coming from
We wish to have common accounting rules because these are essential for assessing comparability of effort. 
We consider that accounting should both comprehensive and complete, so that nations ‘account for what the atmosphere sees’ in terms of emissions and removals.  Whilst we appreciate that a comprehensive land-based approach should give very similar coverage to an comprehensive activity-based approach, we think that the latter has developed a dubious reputation as a result of the Kyoto LULUCF rules. Moreover, as the Paris agreement will be under the Convention, the general rules of the Convention should apply.  The Convention employs a land-based system of reporting and this should also be applied to accounting.  The 2006 IPCC Guidelines also employ a land-based approach. 
Clearly, some nations are not yet in a position to account comprehensively, notably LDCs and SIDs, but all advanced economies are able to do so and the aim should be for all countries to be in a position to do so eventually.
Our other main concern is the use of business as usual reference levels, as employed for forest management in the Kyoto Protocol accounting rules.  These usually exclude emissions from accounting and so they should not be employed because they do not represent accounting for what the atmosphere sees.  Either a common base year should be employed, as in all other sectors, or a base period, as used in REDD+.