Memorandum from the Royal Society for
the Protection of Birds (RSPB)
EXECUTIVE SUMMARY
The RSPB considers that an international cap
and trade scheme is feasible and, anyway, already exists in the
form of the Kyoto Protocol's Trading scheme. This scheme is deficient
in a number of ways, including the way in which its caps were
set, its limited number of participants and its compliance and
enforcement mechanism. However, it can be improved and the alternatives
all look less promising in terms of their potential effectiveness.
However, although we consider that the existing
Kyoto Protocol trading scheme should form part of a post-2012
agreement, we do not consider that the emissions trading system
should form the framework for negotiating any future agreement.
In our opinion, to focus on emissions trading during the UK's
chairmanship of the G8 would be a mistake. It is too technical
and specific.
The imperative for the G8 should be simply to
start the international negotiations on the international climate
change regime post-2012, and these negotiations should begin with
no preconditions regarding organising principles, such as contraction
and convergence, or delivery mechanisms, such as emissions trading.
To be effective in the longer term, the G8 must focus on restarting
the negotiations and not be distracted by side issues. The G8
and rapidly industrialising developing countries should together
initiate the review of the adequacy of the commitments in the
Climate Change Convention.
A key task for the UK's Presidency of the EU
should be to review its progress towards meeting its emission
reduction targets. The review should initiate a process for ensuring
that existing EU policies and measures are fully implemented in
member states, strengthening those measures and developing new
ones.
INTRODUCTION
1. The RSPB is Europe's largest wildlife
charity with over one million members. We manage one of the largest
conservation estates in the UK with 182 nature reserves, covering
more than 126,846 hectares. The RSPB is part of the BirdLife International
partnership, a global alliance of independent national conservation
organisations working in more than 100 countries worldwide.
2. We consider that human-induced climate
change poses the biggest long-term threat to global biodiversity.
A recent paper in Nature indicates that in a sample region covering
about 20% of the Earth's land surface "`15 to 37% of species
in our sample of regions and taxa will be `committed to extinction'
as a result of mid-range climate warming scenarios for 2050."[1]
3. To avoid such a catastrophe, greenhouse
gas emissions need to be cut hard and rapidly. We therefore support
policies and measures which reduce the anthropogenic greenhouse
gas emissions that cause climate change. We particularly favour
emissions trading schemes as economically efficient means of reducing
emissions and are thus supportive of the overall objective of
this inquiry: to assess the feasibility of such schemes as framework
for negotiating a "post-Kyoto" agreement or, as we would
put it, a post-2012 agreement.[2]
4. We were actively involved in the development
of both the Kyoto Protocol and EU emissions trading schemes and
thus have practical experience of cap and trade schemes, including
compliance assessment and enforcement. We consider that emissions
trading can be at the core of a post-2012 climate regime. Indeed,
it is already the main emission reduction delivery mechanism in
the Protocol, although the current system is not perfect and could
be improved.
5. However, we consider that to focus on
emissions trading during the UK's chairmanship of the G8 would
be a mistake. The imperative is to start the international negotiations
on the climate regime post-2012, and these negotiations should
begin with no preconditions regarding organising principles, such
as contraction and convergence, or delivery mechanisms, such as
emissions trading.
6. The international climate change process
has been stalled for some years now, partly because major developing
countries considered that major developed countries, including
the EU and Japan, were attempting to impose preconditions on the
post-2012 negotiations. We should not repeat this mistake. Neither
should we make our main objective the linking of differing trading
schemes, such as linking the EU scheme with the prospective Japanese
and US state level schemes. Whilst this may be worthwhile, it
is certainly not a solution to the problem of climate change because
it is insufficiently comprehensive in the scope of emissions it
would include. As an aim for the G8, it would be a tacit confession
that we had given up hope of an all-inclusive, global climate
regime.
INTERNATIONAL EMISSIONS
TRADING SCHEME
7. The RSPB believes that an international
emissions trading scheme is feasible, although there are several
factors that make it hard for a global regime to be as effective
as a national one, many of which are highlighted by the deficiencies
in the Kyoto Protocol's trading regime. In this section we discuss,
in turn, the key features that an ideal emissions trading regime
should possess, how an international regime might fall short of
the ideal and how such deficiencies might be corrected, if at
all.
The cap and how to set it
8. The magnitude of the cap determines the
environmental effectiveness of any cap and trade regime, assuming
that compliance can be enforced. It should ideally be set at a
level that will solve, or at least begin to solve, the environmental
problem it is intended to address. A significant cap is also needed
to drive trading, for if the cap is set too low, none of the participants
will need to trade. In addition, the cap should ideally be set
independently of the participants, who might seek to dilute it,
and at a single level for all.
9. Whilst is it possible, at least in theory,
to meet all of these criteria if national governments are setting
targets for their own organisations, it is much more difficult
to meet all of them in an international scheme. Indeed, even national
caps can be set at far lower levels than the scale of the environmental
problem would ideally dictate, as recent experience of setting
National Allocation Plans (NAPs) in the EU Emissions Trading Scheme
(EU ETS) has shown. Also, instead of setting a single, overall
cap, the NAPs set different caps for different industry sectors,
with the UK, for example, allowing business-as-usual in all sectors
other than electricity generation (because that is not subject
to international competition).
10. Internationally, however, it is inherently
more difficult to set a significant cap, in large part because
governments are likely to be both the target-setters and the participants,
as in the Kyoto system. In such circumstances, there is always
likely to be a race to the bottom in terms of setting caps, as
each participant attempts to avoid being placed at what it considers
to be a competitive disadvantage compared to the others. In the
Kyoto trading scheme, the caps were set in a sort of bidding process
in which the USA and its negotiating bloc (JUSCANNZ) started by
proposing a zero cap (from 1990 levels by 2010) and the EU started
by proposing a 15% cap. In the end, most major emitters ended
up taking caps of 7 or 8%.[3]
This is not an ideal way of arriving at a cap, or rather caps,
particularly as some countries took advantage of the process by
giving themselves significant emission increases, such as Australia
with 10% increase and Russia, which took a target of zero when
its emissions had fallen dramatically since the baseline year
of 1990. However, it is hard to think of a politically realistic
alternative to this type of process.
11. There are alternatives to a Kyoto-type
process but none appear either promising in terms of approaching
the ideal or, indeed, practical from a political standpoint. For
example, it would, in theory, be possible to establish a global
trading scheme in which an international regime regulated firms
directly, but this would be very hard to achieve in practice,
both because there would be many participants to regulate and
because governments would be reluctant to allow an international
body to regulate their industry. Even within the EU, the ETS leaves
cap setting up to member states via their NAPs, largely for the
latter reason.
12. Another option might be to link existing
trading schemes or add new schemes to an existing one. The EU
ETS might, for example, be linked to the prospective Japanese
scheme and to the prospective West and East coast American/Canadian
schemes. In terms of cap setting, the disadvantage with this approach
is that caps are likely to be set on a completely different basis
under the different schemes. Whilst a Kyoto-type process of cap
setting has its deficiencies, a process in which different schemes
set different caps independently of each other is likely to be
even worse.
13. A number of organising principles have
been suggested as frameworks for setting caps, such as contraction
and convergence. Whilst such schemes are usually fair, equitable
and would address the climate change problem if applied, it is
hard to see major emitting countries locking themselves into tight,
long-term emission limitation frameworks. Under Presidents Bush
senior, Clinton and Bush junior, the USA, for example, has shown
no inclination at all to do so. For the USA, and most other large
emitters, the reduction target they take, if any, has been an
uncomfortable and sometimes nonsensical balance between mitigation
costs and the environmental imperative to cut emissions. This
is unlikely to change because, even if more nations begin to balance
mitigation costs against damage and adaptation costs, the mitigation
costs are always likely to be taken more seriously because they
have to be borne in the short-term and are easier to estimate.
14. On balance, therefore, the Climate Change
Convention and Kyoto Protocol cap setting processes are probably
as good as we are likely to get. They are, anyway, the only ones
that we realistically have. Other, alternatives are likely to
lead to outcomes that are even further from the ideal and there
is currently no global forum in which to negotiate them.
Participation
15. Cap and trade schemes clearly achieve
greater emissions reductions if they include more participants
(emitters). Economic efficiencies are also likely to be greater
if participation is maximised. An ideal cap and trade scheme would
include all sources of emissions.
16. In practice, no trading scheme is likely
to include all emissions for two main reasons. Firstly, there
are considerable technical and administrative difficulties in
including many small emissions sources, such as motor vehicles.
Allocating emissions allowances to any nation's vehicle fleet
and then monitoring them would obviously be impractical. There
are alternatives to allocating to individual sources, in particular,
it is possible to allocate "upstream". In the extreme
case, this would entail allocating at the point of fossil fuel
extraction from the ground or import to a particular country,
thereby capturing all fossil fuel emissions. One difficulty with
this approach is that the allocation is to fuel, rather than emissions,
and that the fuel will be used for a variety of purposes that
yield significantly different levels of emissions. The other difficulty
from a political point of view is that because an upstream allocation
would encompass all fossil fuel emissions it would be hard to
exclude any activities, as governments invariably wish to do.
For example, domestic fuels would be included and their price
would thus tend to rise, perhaps impeding social policies.
17. A key advantage of the Kyoto Protocol's
emissions trading scheme is that it avoids this problem completely,
by allocating emissions to countries and not directly to sources.
This not only potentially allows all emissions to be included
in the scheme but also limits the number of participants to manageable
proportions, ie the number of nations in the World. Although the
Protocol has disadvantages in terms of cap setting, it is almost
ideal in encompassing all emissions, although only if all countries
participate.
18. However, the second main difficulty
with having an all-inclusive international system is that developing
countries do not have caps under the Climate Change Convention
and its Kyoto Protocol. We discuss this problem in detail in the
following section on the UK Chairmanship of the G8.
Leakage
19. Linked to the question of participation
is the question of leakage from the cap, which occurs when emission
reduction credits from project-based mechanisms in uncapped players
are allowed to be interchangeable with emission allowances issued
to capped participants in an emissions trading scheme. The ideal
is to have no credits from uncapped participants because they
"inflate" the cap, making the target less stringent
for the capped players. Also, to have any benefit at all, credits
from uncapped players must clearly demonstrate that they arise
from activities that would not have occurred otherwise—which
is intrinsically very difficult to demonstrate.
20. Yet almost all trading schemes allow
credits from uncapped players. The UK trading scheme does, the
Kyoto Protocol does and the EU ETS does, by allowing the use of
Kyoto project credits from uncapped, developing countries via
the Protocol's Clean Development Mechanism (CDM). Proponents of
project-based mechanisms in developing countries argue that they
provide a means of financing carbon limitation projects in poorer
countries which would not have occurred otherwise and which offer
cheaper credits than could be obtained at home.
21. This may be true but, on the other hand,
not only does allowing such credits mean that developed countries
cut their emissions less than they would otherwise do but it sets
a very bad example to developing countries. It perpetuates the
dubious assumption that reducing emissions is expensive and to
many developing countries it seems as though, having been largely
responsible for creating the climate mess, the developed countries
are now paying the developing ones to clear it up for them.
Compliance and enforcement
22. A difficulty with all international
regimes is that it is almost impossible to enforce compliance.
Indeed, just assessing compliance can be hard in any emissions
control agreement, both because of technical difficulties in estimating
some emissions and because of the fact that in all agreements
countries report on themselves. However, the Kyoto Protocol has
a basically sound reporting and review process. It conducts in-depth
country reviews where reviewers actually visit countries, similar
to some arms control agreements. It is probably as close to the
ideal as one is likely to get in an international agreement.
23. Enforcement, however, is intrinsically
hard in any international agreement. The reasons for this are
obvious: international agreements are not like national laws,
backed up by courts and police forces to enforce them. They are
basically contracts between states, into which states enter voluntarily
and from which they can withdraw. There is ultimately no way of
enforcing them other than by extreme measures, such as invasion
or trade sanctions.[4]
It is possible to impose fines but if these are set too high,
states will either not pay them, or withdraw from the treaty or
both.
24. Most "enforcement" in most
international agreements, consists of shaming recalcitrant states.
This can be effective, as when Russia was found to be in non-compliance
with the Montreal Protocol and Russia found the experience of
having to say "sorry" deeply humiliating. Indeed, some
Russian's cite it as one of the reasons for their caution about
ratifying the Kyoto Protocol.
25. The Kyoto Protocol's compliance group,
which negotiated its compliance procedures, investigated the subject
of enforcement over a period of several years. Two potentially
practical means of enforcement were proposed, both of which addressed
the question of how to penalise non-compliance automatically,
without having to retrospectively enforce it, which is impractical.
The first proposal came from the USA and involved obligatory borrowing
of credits from future commitment periods and the second, from
the EU, involved a so-called commitment period reserve.[5]
26. The US idea made use of the fact that
the Kyoto Protocol sets up emission budgets for each country in
each so-called commitment period, within which it must keep if
it is to achieve its target. Under the US compliance scheme, if
a country exceeded it budget it would have had the number of tons
of carbon that it was out of compliance subtracted from the budget
in its next commitment period. This could have worked except that
negotiations on the targets and budgets for the second commitment
period would begin before the end of the first period, when countries
would have a fair idea of how much they were likely to be out
of compliance. If they thought that they would be in non-compliance,
they could thus negotiate their second period target to take of
the amount that would need to be borrowed from it. To work, the
procedure would thus have to borrow from the next commitment period
but one. However, this would mean that compliance was being penalised
at least five years in arrears which raising the question of whether
it was really fair.
27. The EU enforcement idea involved a levy
on all transfers of allowances (Assigned Amount Units). The proceeds
would accumulate in a central fund until the end of the commitment
period when they would be returned to compliant states and withheld
from non-compliant ones. Although this would clearly only be effective
if non-compliant parties traded significantly, it was assumed
that they would do so in an attempt to stay in compliance and
so the cash that they had paid out as a levy would be significant.[6]
A more important difficulty with the concept was that it was,
in effect, an international tax. Finance ministries worldwide
tend to strongly dislike international taxes over which they have
no control and so the original proposal foundered, although it
persisted in a much-modified form.
28. As far as we know, no other potentially
viable means of enforcing non-compliance in international emissions
trading schemes have been proposed. (We do not count the EU scheme
as international.)
Alternatives to an International Emissions Trading
Scheme
29. The RSPB believes there are alternatives
to an international emissions trading scheme, but they are unlikely
to be as effective. The idea of having a trading scheme under
the Kyoto Protocol was mainly a US idea, backed strongly by Canada
and Australia. The EU originally saw the regimes mainly as a target
setting mechanism and a means of coordinating policies and measures
internationally. Their idea was that many mitigation policies
could potentially affect competitiveness if not coordinated with
other nations, which may be true but it was always difficult to
envisage precisely what form coordination would take.
Approach and objectives to climate change
during UK presidency of G8 and EU in 2005
UK chairmanship of the G8
30. The Prime Minister has already announced
that his priorities for the G8 will be climate change and Africa.
We strongly support this choice but are concerned that the G8
agenda will fill up with numerous worthwhile but ultimately less
important matters, diverting attention from the big issue.
31. On climate change, by far the biggest
single issue is starting international talks on how to limit emissions
after 2012, the end of the Kyoto Protocol's first commitment period.
To be effective in the longer term, the G8 must focus on this
matter and not be distracted by side issues, such as a further
renewables conference with voluntary targets, linking emission
trading schemes, encouraging biofuels as part of WTO and CAP reform,
and a host of other worthy but less important matters.
32. To make progress on tackling climate
change a binding international agreement to cut emissions is essential.
Without such an agreement, countries will always pull back from
making substantial emission cuts because of fears of loss of competitiveness,
as we have recently seen in the race to the bottom by EU countries
in setting targets for the EU ETS. Also, even to begin to stabilize
atmospheric concentrations of greenhouse gases, and hence limit
global temperature rise, all countries need to constrain their
emissions, certainly the larger emitters, as mentioned earlier.
Political background
33. Involving all countries in a global
agreement may be essential but it will be hard to achieve, as
is shown by experience of the Kyoto Protocol. Not only has the
USA left the Protocol but none of the developing countries, including
the rapidly industrialising ones, have commitments to limit their
emissions. Ethically, it is right to say (as the UN Climate Change
Convention does) that developed countries have a historical responsibility
for causing the problem of climate change and that they should
take the lead in clearing it up. However, this does not solve
the practical problem of limiting climate change, as is indicated
by the figure below. If developed country emissions are not cut
hard and developing country emissions at least constrained, climate
change will continue indefinitely and catastrophically.
34. In the USA the Bush Administration has
been denounced for pulling out of Kyoto, but it is sometimes forgotten
that even if the President asked the Senate to ratify the agreement
then the Senate would probably refuse. The Byrd-Hagel Senate Resolution
of 1997 clearly stated, just prior to the Kyoto meeting which
led to the Protocol, that the Senate would not ratify a treaty
on climate change that did not include "meaningful participation"
by at least some, more developed, developing countries. The Senate
passed the resolution by a vote of 95 to 0. The issue of rapidly
industrialising country participation is therefore not simply
a practical matter of reducing emissions but it is of key importance
in achieving US engagement in any agreement.
35. Moreover, since 1997, the USA has done
very little to limit its emissions and they have continued to
climb steeply under both the Clinton and Bush Administrations.
It is thus arguable whether it is now possible for the USA to
achieve its Kyoto targets, and any US administration, and probably
any Senate too, would argue that it is not.
36. It is also extremely unlikely that any
developing country will take on legally binding emission reductions
in the near future. All of the major, rapidly industrialising
countries are parties to the Kyoto Protocol, under which they
have no obligations to limit emissions, certainly before 2012.
Moreover, the developing country negotiating bloc (the G77 and
China) firmly adheres to the position that developed countries
should take the lead in reducing emissions.
37. Until 2012, the end of the first Kyoto
Commitment period, the prospects of either the USA or major developing
countries agreeing to limit their emissions under an international
treaty are therefore slim. It has been argued that an agreement
other than Kyoto might be set up, in the form of a "coalition
of the willing", but this has a number of serious disadvantages.
It could potentially undermine both the Protocol and, more importantly,
its parent convention, the UN Framework Convention on Climate
Change (UNFCCC) to which almost all countries belong, including
the USA. Also, a coalition of the willing is, by its nature, likely
to achieve little more than its members would do anyway. It is
the unwilling that need to be persuaded into agreement.
38. For the post 2012 period, however, the
prospects of agreement look better. Most US politicians from both
parties now accept that climate change is a serious problem, as
is shown by the climate-related measures being taken by Governor
Pataki in New York State, Governor Schwarzeneger in California
and by Senator McCain (Republican, Arizona) and Senator Leiberman
(Democrat, Connecticut) who tabled the "Climate Stewardship
Act" that narrowly failed to pass through the Senate by 43
to 55 votes in October 2003. (McCain and Lieberman will resubmit
the Bill.)
39. Rapidly industrialising countries, especially
China, also take climate change increasingly seriously. Qin Dahe,
head of China's Meteorological Administration, recently told the
Chinese Academy of Sciences that "global warming brought
about [an] unbearable, irreversible and sustained effect to the
Chinese economic and social development."[7]
Initiating post-2012 negotiations
40. The G8 meeting in 2005 is an almost
ideal time to initiate talks about action on climate change post-2012.
That date is still a long way off in terms of the typical governmental
timescale of four or five years and so even wary governments may
be willing to start talks as long as there are no preconditions
about commitments. A climate-skeptical US Administration and major
developing country governments that fear taking on emission reduction
targets could, at a high level, agree to start talks.
41. The high level commitment is, however,
important because, without it, executive officials are likely
remain mired in their present, "do nothing" positions
as they have for three or four years now. It is also vital that
the UK Chair of the G8 engages not only the G8 members but also
major developing countries in any G8 decision. A G8 resolution
without the active involvement of at least some major developing
countries is likely to raise suspicion and antagonism. One idea
is to hold a "G10" or ideally "G12" meeting
of the G8 leaders together with those from China, India, Brazil
and South Africa
42. A G8 and developing country decision
should not be complex. At its most basic, it need only call upon
the parties to the UNFCCC (to which all G8 members and all major
developing countries belong) to conduct a review of the adequacy
of the commitments in the Convention. The Convention specifically
provides for such a review. Indeed, it is overdue. Article 4.2.d.
of the Convention says that it "shall take place no later
than 31 December 1998". The review, even if based only slightly
in reality, should conclude that the commitments in the Convention
are inadequate and act accordingly to take corrective action.
(The first review of the adequacy of commitments in 1994 concluded
that the commitments were inadequate and led directly to the process
that concluded with the Kyoto Protocol. It would be inconsistent
to conclude that the commitments were adequate now when they were
not in 1994.)
43. It is particularly important that no
attempt should be made by the G8 to impose preconditions on the
negotiations, especially in the form of organising principles,
such as "contraction and convergence". These should
emerge during negotiations, not before them, and preferably from
developing countries rather than the G8. The only guiding principle
that should be employed is one that is already agreed as the ultimate
objective of the Convention which is:
. . . stabilization of greenhouse gas concentrations
in the atmosphere at a level that would prevent dangerous anthropogenic
interference with the climate system. Such a level should be achieved
within a time-frame sufficient to allow ecosystems to adapt naturally
to climate change, to ensure that food production is not threatened
and to enable economic development to proceed in a sustainable
manner.
44. At present, it seems unlikely that this
globally agreed objective will be met. As may be seen from the
figure on emission projections for major countries, stabilsation
of atmospheric concentrations at any level at all is clearly not
going to occur without significant global cuts in emissions. According
to the Intergovernmental Panel on Climate Change:
"natural systems can be especially vulnerable
to climate change and some will be irreversibly damaged or lost",
and
[there will be] "a general reduction in
crop yields in most tropic, sub-tropical and mid-latitude regions."
UK presidency of the EU
45. The latest available data for 2002 shows
that the EU 15 has achieved only a 2.9% reduction in greenhouse
gas emissions from 1990 levels. As a result, the EU is not on
course to meet its Kyoto target of 8% by 2010, let alone a 21%
target, and clearly needs to do much more if it is to achieve
it, both by strengthening existing policies and measures and introducing
new ones. The figure below, from the European Environmental Agency,
shows how well, or badly, the EU 15 countries were performing
in attaining their burden-sharing targets in 2001.[8]
46. A key task for the UK's Presidency of
the EU is thus to review its progress towards meeting its emission
reduction targets and initiate a process for ensuring that existing
EU policies and measures are fully implemented in member states,
strengthening those measures and developing new ones.
47. The UK will have strong legal grounds
for conducting a thorough review of policies and measures during
the Presidency. By 2005, the developed country parties to the
Kyoto Protocol are obliged to have made "demonstrable progress"
in achieving their commitments under the protocol. A review of
both implementation and of the adequacy of policies and measures
is clearly essential in demonstrating progress, or not. (The EU
inserted the "demonstrable progress" text (Article 3.2)
into the Protocol and so it is particularly important that the
EU shows leadership in implementing it.)
48. Measures that require strengthening
and adding to at the EU level are similar, or in some case the
same, as those at UK level. In particular, a key task will be
to ensure that methods used in drawing up National Allocation
Plans for the EU ETS are far better harmonised, firmly set cap
so as to ensure that competitiveness concerns are minimised and
more challenging NAPs are set for the second phase of the scheme.
(The Emissions Trading Directive already allows for such harmonisation.)
49. As at home, the UK should also do much
more to restrict transport-related emissions during its presidency
of the EU. The UK should work to put in place an EU-wide emissions
charge on aviation and set in train a process for opting aviation
emissions into the EU ETS. They should also strive to put in place
an EU-wide well-to-wheel carbon tax on all road vehicle fuels.
CONTRIBUTIONS BY
INDIVIDUAL UK GOVERNMENT
DEPARTMENTS
50. DEFRA has the most expertise in this
area, on both the science and policy, and should thus take the
lead on any national or international initiative. The FCO, DTI
and DfID also have valuable experience and expertise to bring
in specific areas and should thus be part of any DEFRA-led team.
HMT have paid increasing attention to the use of economic instruments
for environmental purposes in recent years and thus have a role
to play, although they may lack much relevant experience internationally.
DfT would benefit greatly by participating in work led by others.
51. DEFRA, DTI, DfID and the FCO should
have sufficient experience of working together on climate change
to deliver a coherent UK agenda to which HTM could contribute
in some areas.
October 2004
1 Chris D Thomas et al, Extinction risk from
climate change, Nature, 8 January 2004. Back
2
We are concerned that the phrase "post Kyoto" implies
the abandonment of the Kyoto Protocol, whereas post 2012 implies
nothing more than that the nature of the international climate
regime after the Protocol's first commitment period that still
needs to be negotiated. Back
3
JUSCANNZ was the name for the negotiating bloc made up of Japan,
the USA, Canada, Australia, Norway and New Zealand. Norway has
now left the Group but Russia has now joined and it is now know
as the Umbrella Group. Back
4
Agreements that regulate trade can, and do, initiate or approve
of sanctions. CITES, for example, banned international trade in
all wildlife products with both Italy and Thailand in 1992, until
they complied with treaty provisions on domestic enforcement. Back
5
There is still a commitment period reserve in the ancillary agreements
under the Kyoto Protocol but its is not the same as that originally
proposed by the EU, although it metamorphosed from it. Back
6
It was proposed that the levy that was withheld might go towards
funding emission limitation projects in developing countries. Back
7
"Scientist suggests to set up national policy on climate
change", People's Daily Online, 7 June 2004. Back
8
Greenhouse gas emission trends and projections in Europe 2003,
European Environment Agency, 2003. Back
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