The forestry negotiations came back into the open on Saturday in a public session. Two main events occurred: The Group of 77 (G77) and China (a negotiating bloc of developing countries and China) delivered a proposal designed to limit the damage of the weak forestry rules being contemplated here. The second is that Russia delivered a proposal to hide increased net emissions and maximize credits.
The G77 and China's proposal has two main elements:
- A rigorous, independent, expert review of a county's proposed reference level for forest management emissions; the reference level would be adjusted if they are shown to be either fraudulent or flawed.
- A cap on the credits that a country can get from forest management;
The review will increase transparency and take care of methodological problems. And the Group clearly hopes that the review can also get at substantive problems with the reference level as well: they propose that it can be used to adjust reference levels if they do not meet a set of guidelines still to be established. I think it makes sense to develop these guidelines, but also that the criteria for setting a reference level must be improved. In particular, countries should not be allowed to build new policies into their baseline (e.g. higher harvest rates).
The cap and the review is the best that G77 and China seem to think they can get in the face of an unwilling dance partner that is focused on hiding emissions and protecting its forest sector from the negative side of carbon prices. We should and could do much better if developed countries were willing to step forward to help the climate.
This limitation was illustrated by a two-part proposal made by Russia in the same session:
- a country should get no penalty for increased net emissions until its entire forest sink is wiped out;
- there should be no limit to the credits a country can claim for its forest sink if it uses a historical baseline (this was clever because Russia is using a historical baseline and most of the concern so far has been expressed about the projected reference levels).
The Island of Tuvalu, clearly concerned with the direction things are going, asked the Chair of the negotiations to hear what civil society had to say about the proposals. The Chair agreed to hear from us. After a few hurried conversations with my colleagues in the room, I delivered the following points:
- We want to see emissions from logging reduced and none of the proposals on the table do that;
- We acknowledge that the proposal from G77 and China is pointed in the right direction, and especially appreciate the focus placed on the importance of historical emissions in assessing the countries' projections;
- The adjustment of the reference levels must not erase the effect of new policies that have been implemented (e.g. increased harvest rates);
- We agree that a cap needs to be considered, but for all circumstances, not just projections;
- We completely disagree with Russia's proposal because it completely avoids accounting for increased net emissions;
- The goal of forest management accounting must be to reduce emissions, and not allow them to increase;
- Make forest management accounting mandatory (it's incredible that some countries still want it to be voluntary after making the rules so convenient for themselves);
- If there is a cap, it should only be on credits - there is no need to cap debits after the great lengths developed countries have gone to remove debits from the equation (e.g. through the reference level, excluding natural disturbance emissions, accounting for carbon stored in wood products);
- Make the reference levels permanent so they can't always be revised;
- Further constrain the criteria for setting reference levels, and do not allow countries to build new policies and increased harvest levels into their reference levels.
11 ter. [For the second commitment period, additions to [and subtractions from] the assigned amount of a Party resulting from forest management under Article 3, paragraph 4, and from forest management project activities undertaken under Article 6 shall not exceed X percent of its assigned amount pursuant to Article 3, paragraphs 7 and 8.] 11 quarter. [ REFERENCE LEVEL DEFINED Immediately after a decision is adopted on LULUCF under the KP for the second commitment period, the reference levels inscribed in the appendix shall be registered by the UNFCCC Secretariat. INFORMATION PROVIDED ON REFERENCE LEVEL CALCULATION No later than six months after the COP/MOP adopts a Decision on the treatment of LULUCF for the next commitment period, Parties shall submit to the Conference of the Parties serving as the meeting of the Parties to the Kyoto Protocol (COP/MOP) information on its reference level for accounting of emissions and removals from [forest management] [forest land]. The submission shall contain a transparent information and comprehensive description of all the elements used to calculate the reference level in a transparent, complete, consistent, comparable and accurate way, thus conforming to good practice in LULUCF, and including, inter alia, the assumptions, model, and data, including data on harvesting, age structure dynamics and consumption of domestic wood, and of how the items contained in footnote 2 of paragraph 11 have been taken into account. PROVISION FOR REVISION OF THE REFERENCE LEVEL Before the start of the commitment period reporting, if an inconsistency between historical data on [forest management][forest land] and the registered data applied for estimating the reference level is demonstrated by a Party, an Annex I Party that is Party to the Kyoto Protocol shall submit a revised reference level along with the revised information on elements used to calculate the reference level and justification for the new, revised value. FIRST REVIEW As part of the review process of Annex I Parties annual inventory report in 2012, a review of the reference levels and information contained in the registry shall be carried out, following guidelines on reference levels to be developed and adopted by the COP/MOP no later than its eighth session, in accordance with relevant decision related to Article 8 of the Kyoto Protocol. REPORTING BY ANNEX I PARTIES START FOLLOWED BY ANNUAL REVIEW Upon reporting for the commitment period to which the reference level refers, as part of the national inventory report to the Kyoto Protocol, Annex I Parties shall submit information regarding the reference level which allows to verify consistency between data and methodologies used to calculate the reference level and those used for the purposes of accounting, including, inter alia, consumption of domestic wood. Review of that information and of information contained in the registry shall be carried out, following guidelines on reference levels to be developed and adopted by the COP/MOP no later than its eighth session, in accordance with relevant decision related to Article 8 of the Kyoto Protocol. If an inconsistency between the elements used to calculate the reference level and those used for the purposes of accounting is identified, the accounted quantity shall be recalculated, in order to remove the effect of the inconsistency on the amount of RMUs to be issued.] -- 1. When applying the reference level upon accounting, an adjustment shall be applied in order not to credit, among other inconsistencies: i. Reduction in consumption of domestic [wood] [HWP] for production of energy during the commitment period compared to the reference level; ii. Substitution of consumption of domestic [wood] [HWP] with imported wood during the commitment period compared to the reference level;