The Cancun Deal

The president of the conference has produced a draft decision text that is receiving rave reviews from country after country in the plenary. The Mexican presidency is being praised for its transparency, adeptness and openness and for producing a decision that has package between the two negotiating tracks (something until now elusive).

It is clearly lacking in ambition and by no means is the end result that is needed. But all are hailing it as the lifeline that was required to re-instill confidence in the process and the foundation for a path forward.

The outcome on LULUCF and the forestry negotiations is better than I expected earlier in the week. There are three key elements of this outcome for me:
* There was no agreement to lock in the logging loophole (reference levels);
* There is an acknowledgment of loopholes and of the need to consider their impacts on targets and ambition;
* Options to the reference levels persist in the text for next year.

Other details:
- The guiding principles from the Marrakesh Accords continue to govern the framework
- The same definitions still apply
- A decision on whether to have a cap on credits/debits and how to exclude emissions from force majeure events (i.e. extreme fire years)will be decided in time for next December
- Parties' proposed reference levels were inscribed in an appendix, but no final decision was made to account using these
- The submission, review and replacement process for reference levels was agreed
- No other decisions on substantive matters were made (e.g. accounting for emissions from other activities, how to account for wood products, etc.)

One other outcome to note is that the negotiators came to an informal agreement on how to define and create a new activity for peatland management ('draining and re-wetting'). I suspect this didn't come into the final decision because many other issues couldn't, but it appears it is ready to formally decide next year.

Next year will be interesting...

The 11th Hour (literally)

It's 11 o'clock on Thursday night and the forestry negotiators are locked in a room behind me trying to hammer out an agreement.

By all reports it's going slowly. But only those content to settle for a 500 Megatonne loophole would say it's going well.

There is a lot of momentum at the 'technical' level. Almost everyone seems content to stitch up this deal.

There are a couple of wild cards on the table. How long will Tuvalu hold out with its principled objection? How long will the African Group hold out with its compromise? What will Ministers do? Will they rubber stamp rules that allow forestry emissions to increase without penalty?

My task now is to hang around outside this room and find out what I can when they finish. Then, we will have to react quickly to influence the political decision that will follow these technical negotiations.

Will Tuvalu's Tactical Moves Still Save the Day?

The 1.5 hours of negotiations on LULUCF planned today didn't happen.

The Island Nation of Tuvalu insisted on discussing concerns about process and getting assurances that its views would not be ignored.

The conventional wisdom is that a decision on LULUCF rules is needed here so countries can get on to the business of setting economy-wide targets. To most, this means there must be no delay and the decision must be made quickly. But Tuvalu appears ready to take a stand that it won't be blackmailed into accepting rules with low environmental integrity. If this is what is happening, good for Tuvalu! We will utlimately all benefit.

Africa Propose Compromise

I should apologize to anyone whose appetite I whet the other day with the teaser about a proposal from the African Group that I haven't followed-up sooner. It's been very busy here as always.

The proposal is a compromise that modifies the reference level approach by combining it with a historical average of data from the first commitment period. This proposal would cut the logging loophole in the second commitment period roughly in half while still giving all Annex I Parties at least part of the ‘break’ on emissions they have been looking for. It’s only a partial fix with its own short-comings, but it is an interesting compromise that could hold some promise for a deal in Cancun, if developed countries are really looking for one.

My sense is that they are not. They feel to close to getting everything they have been asking with the logging loophole.

I should also tell you that things are very much up in the air on the LULUCF negotiations in general.

The Ministers have arrived but without at manageable text on LULUCF for them to work with. There is an extra informal (closed door meeting) tomorrow morning to try to come to some agreement on the text that will be given to Ministers. The key oustanding question is still how Tuvalu's new proposal to go back to the old rules (with some tweaks) will be incorporated.

The best thing about the Tuvalu proposal was the requirement for countries to have to account for any conversion of forests to plantations or primary forests to secondary!

Whet Your Appetite Post

I'm sitting at the computer pool outside the last scheduled closed session of negotiations on accounting rules for land use, land-use change and forestry.

The time is ticking for these negotiators who have worked on and on for 3 and a half years to produce a draft decision that may still not be ready for Ministers as they begin to arrive. The idea is that Ministers must be given clear, simple choices to negotiate. They would quickly be lost and bogged down in the details and complexities of LULUCF.

As of yesterday there was no option that looked politically acceptable to all. And the only decent option for the environment had been roundly rejected by developed countries (Tuvalu's proposal from earlier this year to account for any change in logging emissions from the recent past - called 'net-net' accounting).

We learned yesterday that the facilitators of the negotiations were producing a new draft decision today that would include a 'compromise' being proposed by the African Group (of countries). I suspect they are in there discussing it right now.

This post is to whet your appetite for the news when they emerge...what has Africa put on the table? Is it really grounds for compromise? Is it an acceptable environmental outcome?

Prospects Grim in Cancun

It's end of day 3 in Cancun. As always, it's been a frenzied three days.

The negotiations began along the well-worn path of the last year: developed countries refining the new rules and processes they would use to avoid accountability for emissions from logging and other land uses like croplands.

Then things got interesting.

The island state of Tuvalu, as steadfast in its abhorrence of the 'logging loophole' as we are, put a whole new package on the table. It basically throws out everything that countries have been negotiating on for the past three years - no reference levels (loophole), no credit for carbon stored in wood products (loophole), no special provision for excluding emissions from fires (possible loophole).

The quid pro quo for this tossing out the window of all things bad and troubling in the negotiations is that accounting for everything would remain voluntary. It's hard to get excited about this approach, but easy to comiserate with the apparent desperation caused by the singular focus of developed countries on anything but accounting for emissions from land use.

It's still shocking how, in this convention on climate change and emission reductions, there is no preoccupation with emission reductions from land use - they can go up as long as the practices are 'sustainable'!

It's really not clear where things will go from here. There are now three options on the table on the basic accounting approach, all of which have entrenched opposition. And, ironically, the one thing everyone seems to agree on is that they want an agreement here in Cancun!

Meanwhile, small informal groups of negotiators have been locked behind closed doors trying to hammer out an agreement on the how to deal with natural disturbances and carbon stored in wood products.

Tomorrow may bring more surprises...

Last Chance: The Road to Cancun

I am back home in beautiful Ottawa looking out my window at the colours that make autumn so special in Canada. This beauty is in sharp relief to the thick smog the bus drove through on the way to the Beijingairport on Sunday.

The closing plenary in Tianjin showed that there is still hope for a better outcome to the forestry negotiations. Both the Africa Group (all African countries) and the Association of Small Island States spoke out strongly against the logging loophole: they both rejected the approach of using "projected reference levels" from the future to account for forestry emissions. This resistance and insistence on environmental integrity is important. Although developed countries may not want to take heed of this, we will do our best to make sure they do.

In the next seven weeks before the decision-making meeting in Cancun, I will be working with my colleagues to continue pushing for a strong outcome: campaigning, public outreach, communications and exploring compromises that have environmental integrity. We are in the final stretch.

In the meantime, I will be working to ensure that domestic policies and meausures for forests and climate change are up to snuff!

Forestry Negotiations in Tianjin China: Rolling towards the abyss!

Day 3 of the Tianjin Climate Talks has already past and the Great Fire Wall of China has kept me from posting before now. This post is being made through a friend back in Canada who kindly offered to help me get the word out.

The proposal to allow developed countries to use 'reference levels' from the future to measure their emissions compliance for logging continues to move forward. As one developing country negotiator described it to me: this thing now has wheels.

Unfortunately this proposal is taking us off a cliff from which environmental integrity in this process may never recover. It still amazes me that government representatives from developed countries that have caused climate change and have made commitments to fix it can say with a straight face that it is good policy to allow them to increase their logging emissions without penalty.

There have been two interesting developments in the last 24 hours. The first is that developed countries put forward a process to have expert technical teams review the proposed reference levels. It looks okay as far as technical review goes but all it will really demonstrate is whether countries have done a good job proposing bad reference levels.

The other development was that there was an open session today to discuss an alternative to the reference level approach. The island nation of Tuvalu described its proposal to use emissions/removals from forest management in the first commitment period (2008-2012) as the basis for measuring increases or decreases in the second commitment period. Tuvalu and Belarus both made clear and compelling arguments for why a historical baseline is the only reliable basis for demonstrating whether we are actually moving towards our target of emission reductions. The European Union, New Zealand and Papua New Guinea were the principle defenders of the flawed 'projected reference level' approach.

At the request of Tuvalu, the co-chairs of the session opened the floor to comments from civil society and I was able to make an intervention. I recorded it low-tech style on my iPhone. Picture me in a room full of negotiators in a conference centre that looks like it was designed for giants!

Political Heat Not Reaching Forestry Negotiators

The political heat was turned on the logging loophole at the UN Climate Talks this week in Bonn, but those negotiating the loophole appeared unfazed.

The negotiations were framed with a statement by the Chair that forestry rules should be developed that strengthen ambition. As mentioned in my previous post, presentation after presentation at a Monday workshop on countries' targets showed that they are doing the opposite. These presentations drew attention to the logging loophole and showed that all the loopholes taken together mean that developed countries could actually increase their emissions under their 'reduction' pledges made in Copenhagen. John Vidal of the Guardian wrote on the farce these loopholes are making of rich countries' Copenhagen pledges.

The forestry negotiators showed no sign of this heat after they went back behind closed doors. Some new draft texts came out this morning and nothing has really changed. I believe that this is because, with so many countries concerned primarily with the different 'national circumstances' of their forestry sectors, no one is sure what the political solution actually is. This gives the negotiators of a lot of room.

But it is clear to me that they won't change direction until they are told to by their political bosses. These bosses should be sensitive to the revelation that rich countries are playing a dangerous game with the future of the planet, pretending to reduce emissions when they are actually planning the exact opposite.

Bonn Climate Talks: Part 10 - Where from here?

Though the cough I earned with much hand-shaking and long hours of campaigning persists, the Bonn Climate Talks themselves have wrapped up.

The forestry issues were not resolved in Bonn as some had expected/feared, but these talks have clearly set the stage for some kind of resolution at the next round of talks in August.

In fact, it's probably fair to say that the biggest outcome from the last few days of the talks was a proposal to hold a 'pre-sessional' workshop on LULUCF before the next week-long meeting in Bonn officially begins. ENGOs have written a letter to John Ashe, the Chair of the negotiations under the Kyoto Protocol, to request that observers can attend this meeting. His response may well determine whether a logging deal is stitched up behind closed doors.

For my final post from the June Bonn Climate Talks, I have attached this graph that was shown by the EU at a session on the effects of LULUCF rules on countries' overall targets. The graph shows very neatly the effect of different approaches to reference levels being taken by developed countries:

• Most developed countries have 'conveniently' set their reference levels to exactly equal the emissions they forecast for 2012-2020, thereby hiding net increases in emissions from accounting. These countries show neither credits, nor debits in this graph;
• Norway and Russia have both chosen 1990 as a base year to account for emissions from forest management. Both countries plan to increase net emissions from today but will earn credits because current emissions are lower than they were in 1990;
• Japan is manufacturing credits for itself by arbitrarily choosing a zero sink as a reference level. That means it will get credits as long as its national forest is a net sink, even though it plans to increase net emissions during 2012-2020;
• The most striking feature of this graph to me is Switzerland: it is the only country whose proposed reference level would deliver debits. Like the other countries, its forest will remain a net sink; Like the other countries, it plans to increase net emissions. Very much unlike the other countries, it has acknowledged some accountability for this increase in emissions and proposed a reference level that is between the historical average the forecast increase in emissions. The result will be a carbon price signal to do better carbon management in forests... enough to crown a hero in these negotiations.

Bonn Climate Talks Part 8: The Chorus Grows

On Day 7 of the talks, the chorus is steadily growing to transform the forestry accounting framework with a goal to reduce emissions. The following countries have now all made public statements in supporting this goal:

• The African Group (53 countries);
• COMIFAC - the Central African Forest Commission (10 Central African countries);
• The Coalition of Rainforest Nations (13 countries in Africa, Caribbean, Central America and South America);
  
• India.
  

By contrast, developed countries continue to obfuscate with talk of 'proper incentives' and 'business-as-usual' management.

It becomes more and more clear each day that the "projection of forest management activities" in a country's baseline is absolutely foolhardy:

• it hides increased net emissions;
• it is based on unverifiable assumptions;
• it leads to wild inconsistency in baselines between countries.

In a negotiating session today on 'the numbers' - i.e. countries' overall targets to reduce emissions, several developed countries made it clear that they will only move to the upper end of the range of emission reductions they have offered if they get the LULUCF loopholes they seek. In this context, moving to the upper range becomes totally meaningless.

Closed-door negotiations resume again tomorrow and there will be three sessions in total this week.

Bonn Climate Talks Part 7: Continuing to Fight for the Forests

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 approach is pointed in the right direction, but unfortunately does not get the job done.

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).
  

These two things proposals combined mean that Russia could get credits for increased emissions and virtually never receive debits.

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;

Some final points on what must be done to turn this thing around:

• 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.

Here is the text of G77 and China's proposal (note they say the footnote is not complete):

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;

Bonn Climate Talks Part 4: Chorus to close loophole grows

Everything seemed to change today. Whereas yesterday it felt very unclear whether we would have the chance to close the logging loophole, today I feel much more confident.

A number of important things happened:

• The Chairs of the negotiations have confirmed that there will be an opportunity for substantive negotiations here;
• The coalition of African countries (the Africa Group) formally spoke out in their official intervention in favour of reducing emissions from forestry in developed countries;
• The Central African Nations pointed out in their formal intervention the many flaws in the proposed forestry rules for developed countries and highlighted the discrepency between the rigor that is expected of developing countries wanting support to reduce deforestation and the free-for-all approach being proposed by wealthy nations for themselves;

I take all these things as signs that there will be a chance to address our serious concerns with the draft forestry rules. We are not alone.

It is also clear from speaking to people that our message about the 400 Mt loophole for forestry is getting out and reaching high places. Hopefully we will see that translate into pressure to solve the problem within the technical negotiations.

You can watch my friend and colleague Sean Cadman make the case at the Climate Action Network media conference today.

(You can also watch him laughing at me while filming my video blog)

Bonn Climate Talks Part 3: No Clarity on Forestry Negotiations

On day one of the Bonn Climate Talks, there is no clarity on what will unfold within the forestry negotiations.

Depending on who you talk to the rules are a done deal, there's time to fix them, there's no time to fix them, there's time to go deeper into the data and assumptions, we can change the text, we can't change the text, there will be a political deal, there will be no deal...!

We are meeting with the Chair of the negotiations under the Kyoto Protocol tomorrow, so we will get straight from him what his strategy is for the meeting.

In the meantime, we have starting meeting with heads of country delegations here and expressing our concern that we need a high-level political fix to the forestry emissions loophole. We are at least getting recognition of the problem. We will have many more meetings throughout the week, including with the heads of the European Union's delegations tomorrow.

Finally, we are breaking into the mainstream media with two great stories today, one at length about the forestry emissions loophole, the other highlighting it as one of many problems that need to be solved.

Bonn Climate Talks Part 2: Arriving in Germany

I arrived yesterday in Bonn, Germany and began working right away, despite the jetlag.

Part of the day was spent in a strategic planning exercise with other environmental groups, but the main focus of the day was to start rolling out a plan to find a country that would propose new text to close the logging loophole in the draft agreement under the Kyoto Protocol, which would allow developed countries to increase their emissions without penalty.

It's not possible that such an agreement could be made here in Bonn, but introducing the text into the draft agreement would be a powerful move that would set-up future lobbying as well as draw important attention to the issue.

Early signs are positive; we'll see where it goes.

Campaign Kicks Off to Close the Logging Loophole

I am off to the Bonn Climate Change Talks to help lead a campaign effort to close the logging loophole.

Developed countries have proposed to allow themselves to increase annual logging emissions by 400 Mt CO2 (roughly equivalent to the annual emissions of the entire country of Spain) without penalty or even acknowledgement. They want to hide this emissions increase by using a baseline for forest management emissions equal to what they plan their emissions to be between 2013 and 2020!

At this round of talks we are bringing our campaign to the highest level - the heads of delegations, Ministers, heads of state and heads of government. This problem needs to be fixed.

I can't imagine a worse start to climate talks in 2010 than solidifying a deal to let developed countries increase their forestry emissions when they are trying to focus on reducing greenhouse gases globally.

I will be chronicling the effort with frequent video posts. Looking forward to your comments and engagement!

Will Emissions Loophole be Finalized at June Climate Talks?

The up-coming UN climate talks in Bonn this June could determine whether the World is prepared to allow developed countries increase forestry emissions as part of a global climate deal.

The Chair of negotiations under the Kyoto Protocol has stated in his 'scenario note (para 15a)' (a kind of blueprint for the talks) that he wants to see forestry rules finalized at this meeting.

A call to finalize the talks in Bonn could create significant pressure to simply approve the draft decision that is on the table, which includes the logging loophole. The result is an increase of nearly 400 Megatons of CO2 every year that would be hidden and without penalty (see figure).

Climate Action Network International held a side event at the April 2010 Climate Talks discussing the problematic state of the draft LULUCF decision. You can watch the webcast of this side event including questions and comments from the audience.

Post-Copenhagen Whisperings on Forests

A principle occupation of people working on climate change these days is keeping their ear to the ground for signs of what is to come next. This makes for short blog posts, but I thought it would be worth passing on what I know.

Most forestry negotiators from developed countries seem to expect to pick up where they left off in Copenhagen in 2010, and feel that they are fairly close to a deal on rules for forest management accounting that includes the use of projections (logging loopholes).

Most also expect that these talks will occur at the annual June meeting in Bonn if not sooner.

Keeping my ear to the ground...

300 is the New Climate Change Number Today

350 is the key climate change number - the maximum global atmospheric concentration that the planet can sustain without catastrophic effects from global warming.

The number of today and tomorrow is 300. This is the number of the 17,000 or so observers that were accredited to attend the Copenhagen conference that are allowed to come into the conference today and tomorrow. They were here to bear witness to this effort, bringing honesty, transparency and ambition to this crucial enterprise. The number of environmentalists is 54. The number of Canadian environmentalists is 3.

I am privileged to be among this small number, but am not comfortable with it with so many others excluded.

I was chosen by the International Climate Action Network to be one of the few that still gets access to this globally important conference because I chair its working group on forestry and land use. I see my job in the next couple of days to deliver a strong outcome not only for the forests and the millions that care about this issue, but also for the hundreds of forest campaigners and thousands of climate campaigners who are being explicitly denied access to this same opportunity.

However, the extent of my possible influence is unclear. Negotiators sit in a closed door meeting right now trying to resolve issues that have been unresolved for years. In a way I feel we've exerted most of our influence already - by bringing international public attention to the logging loophole that most developed countries brought to the table here.

Hopefully I've created a space for a better outcome. And I will look for any opportunity to use my presence here to do more.

Course of LULUCF negotiations unclear

It's still not known how the issues related to greenhouse gas accounting for emissions from forestry and land use in developed countries will be addressed.

In preparation for the liklihood that Ministers will have to take over, the Climate Action Network has prepared these high-level lobby points:


URGENT HIGH-LEVEL LOBBY POINTS ON LULUCF

1. To facilitate conclusion of LULUCF negotiations, Option B should be removed from the draft KP text (comprehensive accounting).
2. Overall targets will be undermined if Parties are allowed to 'reconsider' the accounting rules or reference levels after agreement in Copenhagen; only changes to increase certainty and accuracy should be allowed (pg. 19 LULUCF para 11 quater);
3. The forest management reference levels proposed by Parties must be replaced with reference levels based on historical data (an annual average value based on 1990-2007); a historical reference level accounts for actual changes in emissions rather than excusing increased or emissions from business-as-usual forest management (pg. 18-19; Option 2 (reference levels) para 11 and footnote and Appendix ("Option 2, paragraphs 11-11bis);
4. Accounting for forest management must be mandatory. (17-18; LULUCF para 6, 6bis);
5. Stronger environmental safeguards are needed if emissions from natural disturbances will be excluded from accounting, including the use of the highest standard of data and methodologies; this standard should also apply to all of accounting for land use, land-use change and forestry; [There was text in a previous decision that was deleted (proposed by Australia): "Robust estimation methods [will] be used to ensure confidence in the emissions and removals from land use, land-use change and forestry. Parties should be transitioning toward higher level (tier 2 and tier 3) accounting methodologies."]