Memorandum submitted by British Energy
KEY POINTS
— All carbon reduction options will
be needed if we are to successfully address climate change. Carbon
offsets if implemented well can be a valuable option in these
efforts, as they have the potential to engage with developing
countries.
— Carbon offsetting needs to be looked
at as an option along with reductions in use and increases in
efficiency.
— Voluntary carbon offset schemes
require accreditation if they are to achieve a consistent and
reliable reduction of carbon dioxide.
— Offset schemes must demonstrate
clear cost benefit attributes and have the ability to be compared
to other offset schemes.
— Offsetting may potentially have
a negative impact on customers' behaviour resulting with no change
to the frequency of carbon intensive activities.
— Voluntary carbon offsetting schemes
may impact the price of carbon. This may in turn impact on the
mandatory schemes.
SOME INQUIRY
ISSUES
Ought there to be a compulsory UK or European
accreditation scheme for carbon offset projects or companies?
If so, how should this operate?
1. There should be a compulsory UK accreditation
scheme for carbon offset projects if the carbon savings achieved
are to have the same credibility as other carbon reduction projects.
2. Carbon reduction claims made by companies
need to be verifiable. The establishment of carbon offset projects
must be developed in accordance with an approved standard. There
will need to be a set of rules and guidelines for large and small
projects. Companies and organisations that develop the projects
will need to be audited by an accredited external body to ensure
that the data used in the offset process is accurate.
3. The accreditation scheme can be modelled
off existing voluntary accreditation based programs, such as Environmental
Management System ISO14001.
Should offsetting become mandatory for some of
the more carbon-intensive activities, such as flying?
4. Carbon offsetting should not yet become
mandatory for carbon intensive activities, such as flying. The
first option for carbon intensive activities should be reduction
and efficiency.
5. A distinction is required between mandatory
carbon offsetting by companies and by individuals. Compliance
by individuals to mandatory carbon offsetting for activities such
as driving is a complicated process and needs to be considered
carefully.
Is there enough clarity within the offset market
to allow customers to make informed choices based upon robust
information about different schemes at different prices?
6. There is not enough clarity within the
offset market at this time. A suggestion to improve clarity is
to set up a register of carbon offset providers, detailing their
products and the methodology and the data source used for their
calculations. Once on this register they need to be audited by
an approved third party.
Many offset projects involve afforestation or
reforestation. Is the science sufficiently coherent in this area
accurately to assess overall long-term carbon (or other GHG) gains
and losses from such projects?
7. The science behind forestry offset projects
is not sufficiently sound to assess the long term GHG's gains
and losses. Also, see 8) and 9) below.
Is there sufficient data available to guarantee
accurate amounts of carbon or other GHG mitigation in the sorts
of schemes which offset projects finance?
8. There is a large body of evidence to
generate assumptions of carbon sequestration as the science of
forestry is well established, but it is insufficient to guarantee
the long-term results. As with all assumptions it is based on
certain variables. If these variables change at a non-predicated
rate this would alter the results. For example, future temperature
and rainfall data is used to predict the growth rate of trees
in forestry schemes, the predictions have been made on future
climatic conditions but these could change dramatically if we
delay action on climate change.
9. Overall, the degree of certainty is decreased
in forestry and agricultural offset projects as it involves natural
systems, which are dynamic. Certainty of results is increased
in reductions of energy use and mechanical efficiency as it is
a more simple process of input vs. output.
What impact will the voluntary carbon offset market
have on the compliance market if the former continues to grow
as steadily as it has done over the last few years?
10. Voluntary market offset schemes may
have implications for the compliance market by driving the price
of carbon down. Mandatory schemes have a minimum operating cost
that must cover the infrastructure of the system and a more complex
approach to carbon reduction.
11. Voluntary projects may lessen the credibility
of mandatory schemes if there is a high degree of failure in the
projects. Voluntary projects may not deliver as great a carbon
reduction as mandatory projects as there is currently not the
same rigor in the voluntary schemes.
12. As the cost of voluntary schemes is
lower then mandatory schemes this may lead to a reduction of available
land for successful projects.
13. On the other hand, voluntary schemes
may have a positive impact on the mandatory schemes as they may
be able to offer a more pragmatic approach to offsets with similar
results.
What evidence is there to show that offsetting
helps to change the carbon behaviour of the customer?
14. Offsetting could have positive and negative
effects on people's behaviour.
15. On the positive side it could have a
double effect of reducing carbon dioxide emissions with an offset
and also as it costs money to offset consumers hopefully will
reduce the carbon intensive activity as it is costing too much.
16. On the negative side it could lead to
inequality, as some people may be able to undertake in certain
activities as they have the money to offset. For some it might
be easier and cheaper to offset then to change behaviour.
17. Evidence of these trends is shown in
the existing schemes, when the price of carbon is low is not a
driver to implement change.
To what extent are the schemes and projects funded
by offset companies more broadly sustainable, in an environmental,
social or economic sense?
18. Offset schemes that are funded by voluntary
payments must ensure that the price of the offset covers the establishment
and the long term management of the project. As the cost of carbon
increases and thus the price of the offset, emitters may opt out
of carbon intensive activities, not requiring the services of
offset providers.
19. The social and environmental sustainability
merits of current offset schemes need to be broken into two groups:
(a) Afforestation or reforestation—Reforestation
projects implemented correctly are environmentally and socially
sustainable. Afforestation projects have the potential to impact
on the environment and the local community, if the land the trees
are being planted on is not meant to be covered by trees and if
it displaces people who had lived off the land previously.
(b) Renewables—The concept of renewable
energy is environmentally sustainable, but some methods of delivery
can have social, environmental and economic impacts. The impacts
on the local environment need to be first assessed to determine
the sustainability of the renewable project. The financial sustainability
of the projects must also be evaluated.
January 2007
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