|
Fern is an NGO which aims to
improve European Union activities in order to achieve: conservation and
sustainable management of forests; respect for the rights of forest peoples;
greater transparency in EU aid to tropical forest countries. |
NGO Comments on the ‘Elements for Draft Outline Report’ from the ECCP Working Group on Forest Sinks
These comments are presented jointly by
the NGO representatives participating in the ECCP Working Group on Forest
Sinks: Jutta Kill, FERN, John Lanchbery, RSPB, Zoltan Rakonczay, WWF
International
These comments focus solely on the ‘Elements for
Draft Outline Report’, which were presented at the third meeting of the ECCP
Working Group on Forest Sinks on 18 October 2002. We will not comment on
individual candidate technical measures, which were presented by other
participants of the Working Group because it continues to be our position that
EU member states should refrain from using Article 3.4 credits to achieve their
Kyoto targets. We believe that the arguments underlying the EU position in the
intergovernmental negotiations on climate change on Article 3.4 sinks credits
up to COP 6bis remain valid and that every sinks credit used to achieve the
Kyoto emission reduction will only increase the burden on future generations
because each sinks credit merely postpones the permanent emission reduction to
a future commitment period. Thus, FERN, RSPB and WWF advocate that the focus of
the ECCP be on reducing greenhouse gas emissions from fossil fuels and on
initiating a swift transition towards renewable energy production.
Paragraph 3: The paragraph mentions the possibility
to further develop and review the rules for forest-related carbon sinks in
future commitment periods but fails to mention that full exclusion of sinks
credits in future commitment period also continues to be an option should
experience and scientific progress show that problems identified in relation to
sinks credits are insoluble.
We suggest that a paragraph be added, which clearly
states that many issues regarding carbon sequestration credits remain
unresolved and which explicitly mentions the possibility of a full exclusion of
carbon sinks credits in future commitment periods. One possibility would be to
add a caveat at the beginning of the report about the non-permanence of carbon
storage in biomass and about the uncertainties linked to carbon sinks
accounting.
Paragraph 4 (and several other places
later): “EU forests…” This takes into account only the EU-15. It is now very likely that by the first
commitment period, the EU will have 25, if not 27 members. Although some effects of EU expansion are
considered later in the paper (e.g., paragraph 19 (3)), we believe that
enlargement should be better integrated in the document both in terms of policy
analysis and in terms of the figures used.
Paragraph 6 states that ‘European forests act as an
effective carbon sink’. This commonly held view, however, ignores that in time
scales relevant for the global carbon cycle (which links biosphere and
atmosphere) clearing of old growth forests throughout Europe released
significant amounts of carbon into the atmosphere. Present-day, intensively
managed forests throughout Europe store significantly less carbon than the
original forest cover across Europe. In
addition, scientific research suggests that large parts of forests in Europe
may turn into sources of greenhouse gases due to the impact of climate change
on these forests.
We suggest that the first sentence of this paragraph
be reformulated to reflect the historic carbon loss from forests across Europe,
as is alluded to in the last sentence of the paragraph.
We disagree with the view stated in paragraph 7 that
‘forest related measures in the EU can provide a positive contribution
to climate change mitigation’. As mentioned in the introduction, it is our view
that no forest-related measure under the Kyoto Protocol, which justifies an
increase of carbon in the active carbon pool can be considered as a positive
contribution to climate change mitigation. We thus suggest that either this
statement be deleted or that credible evidence be provided substantiating how a
measure that increases the amount of carbon in the active carbon pool
can be considered a positive contribution to reducing levels of greenhouse
gases in the atmosphere.
Paragraph 11. We believe that as long as
forest-related activities under the Kyoto Protocol are linked to crediting,
there cannot be any win-win-win situations, because ultimately, the atmosphere
and futures generations loose out. Crediting turns forest-related measures
under the Kyoto Protocol into a fig-leaf for postponing permanent emission
reductions.
Paragraph 12. With regards to National Forest Plans,
we would suggest a slightly more cautious formulation than that in line 8,
which states that ‘National Forest Plans…are an adequate instrument to
translate the above principles’. While this might be true in some cases,
National Forest Plans may be entirely inadequate - or absent, depending on the national circumstances.
Paragraph 17 indirectly raises an important
question: Given that several EU countries have already and independent of
climate change considerations set very ‘ambitious’ targets for additional
afforestation (Spain, Poland), it is difficult to imagine how any proposed
Article 3.3/3.4 afforestation activities could be considered additional. This
issue has so far not been discussed in detail in the working group, however it
is crucial in assessing which role forest-related measures could play.
We suggest that text be added in paragraph 17, which
raises the issue of how to assess additionality and how to determine baselines
in light of national afforestation expansion plans that pre-date the conclusion
of negotiations on Article 3.3/3.4. Furthermore, should activities linked to
these national afforestation plans be considered as candidate technical
measures, further questions arise regarding the impacts on biodiversity of
afforestation resulting in industrial monoculture tree plantations.
Paragraph 18: The calculations used in this
paragraph appear to ignore at least two important points:
1.
Carbo-Europe
research suggests that most plantations are in fact sources during at least the
first decade due to releases of carbon from the soil.
2.
Calculations
based only on carbon uptake and on above-ground biomass ignore important carbon
pools (soil carbon, below-ground biomass). It should be noted that the IPCC
Good Practise Guidance calls for measurement and monitoring of all carbon
pools, not only above-ground.
The projections in
paragraph 19 do not consider the potential future impact of climate change on
forests. This impact may well require significant downward adjustments to
current growth rate calculations depending on the impact of climate change on forests.
We suggest a more cautious formulation of the potential future contribution of
forests to carbon sequestration.
Paragraph
24: This paragraph covers two separate issues under one heading: The use of SRTPs for energy (as indicated by
the title for paragraph. 22), and secondly, the use of biomass for
E-substitution (the second bullet). In
our view, the latter can very well happen without the former; in fact, it is
often suggested that the biggest potential for E-substitution by biomass is NOT
in SRTPs, but in conventional forestry.
We
suggest that the paragraph be split or the lead line changed.
The
concern expressed in the second bullet appears valid only if the demand for
biomass developed sooner or faster than the supply. Furthermore, should such competition arise, a broader discussion
on the most appropriate use of the biomass / fibre in question would be
required.
We fully support the recommendation following
paragraph 22 regarding short-rotation tree plantations.
A question: Does the calculation presented in
paragraph 23 consider releases of carbon from below-ground carbon pools?
Paragraph 24, Conclusions. While human induced ARD
activities in the EU may ‘provide a
contribution in terms of C-sinks to ghg accounts for the first commitment
period’, we believe that such a contribution to the carbon accounting balance
sheet is no indication that such measures also provide a contribution to
avoiding dangerous climate change. In fact, for the reasons stated in the
introduction to these comments, we believe these measures do NOT contribute to
this goal.
We fully support the last paragraph of the
conclusions reiterating the uncertainties related to carbon sinks.
The assessment of the potential of forest management
activities fails to mention that a discount factor applies to these activities
because of the need to factor out non-human induced increases of carbon uptake.
Paragraph 26 focuses on the forestry benefits of the
proposed candidate technical measures. However, a discussion of the climate
benefits – or lack thereof – of these measures is also required given that the
report outlines potential measures to avoid dangerous climate change. We
suggest that text be added, which clarifies that the working group has not yet
assessed in detail the climate benefits of these proposed measures.
Paragraph 42: There appears to be a contradiction between the last bullet point
of paragraph 41 (recommended - use of thinning products) and the first bullet
point of paragraph 42 (not recommended – use of existing forest resources).
Wood from thinnings does originate from existing forests. And, good forest
management provided, the use of wood to substitute for fossil fuel-based energy
production is a desirable component of a future energy mix. We suggest that bullet
1 be reformulated as follows:
-
use
of industrial-quality wood from existing forest resources.
In closing we would like to share some general
observations regarding the candidate technical measures presented in the
working group:
Ø A large majority of measures
presented appeared to be designed first and foremost with forest management
objectives in mind, while climate change considerations appeared to be an
add-on, which may provide some additional funding for measures.
Ø A number of the proposed
candidate technical measures are clearly not additional.
Ø The cost estimates in almost
all cases only covered the costs associated with the forestry measure. However,
activities, which enter the Kyoto accounts incur additional costs because
carbon storage and sequestration must be measured, monitored and verified. The
costs of complying with these requirements of the Kyoto Protocol accounting
framework may be significant and ought to be calculated to obtain a realistic
and unbiased picture of the potential of such forest-related measures.
Ø Many calculations were based
only on above-ground biomass. The IPCC Good Practise Guidance for LULUCF
however calls for accounting of all carbon pools.
Ø National forest inventories
were discussed in the working group as one source of already existing
information. It must be pointed out however, that one of the limitations of
using National Forest Inventories for carbon accounting is that they are
usually carried out in 10-year intervals while data for carbon accounting under
the Kyoto Protocol is required in the five-year intervals of the commitment
periods.
Jutta
Kill John Lanchbery Zoltan Rakonczay
FERN RSPB WWF
International