Memorandum submitted by CarbonSense
CarbonSense was formed in 2003 with a mission
to help accelerate society's transition towards a low carbon future.
We have worked with many companies such as BT, TNT, HSBC and Thames
Water, with the Carbon Trust and Energy Saving Trust and with
community carbon projects in, for example, Chew Magna and West
Suffolk. We have worked with many organisations on issues associated
with offsetting but we are not offset providers. We bring a truly
independent yet insightful voice to strategic thinking on carbon
issues which is valued in boardrooms in the UK and Europe.
CONTEXT
There has been considerable growth in offsetting
since Applied Energy Services offset power station emissions in
Connecticut by planting trees in Guatemala in 1989. At the same
time, there has been a growth in scientific evidence indicating
that emissions caused by human activity are affecting the global
climate now. It is not clear that while afforestation and reforestation
may in some cases be beneficial for other reasons, they do not
adequately compensate for carbon that has been released from the
geological cycle. Questions about regulation of the voluntary
carbon offset market therefore need to be considered in the context
of current and emerging science on climate change rather than
on the basis of UNFCCC assessments which pre-date Kyoto.
OFFSETTING
Offsetting is an attempt to compensate for an
emission but in practice it is frequently inadequate. Critical
reasons for this failure include:
— The offset is typically delayed in
time, sometimes by many years, relative to the emission.
— The offsetting is typically achieved
only over a much longer period than the occurrence of the emission.
— Some offsets often involve absorption
into the terrestrial biological carbon cycle in an attempt to
compensate for carbon that has been released from the geological
cycle.
The term "offset" itself is a technical
term that also tends to create a false impression in the mind
of the lay person. As a suitable term to use when seeking to obscure
the true meaning of the action it describes, it is perhaps best
equated to "collateral damage". CarbonSense is now using
the word "compensate" rather than "offset".
CARBON NEUTRALITY
The boundaries set for the counting of the carbon
that is being offset are boundaries of practical, administrative
or arithmetic convenience—for example, Scopes 1 and 2 as
defined in the Greenhouse Gas Reporting Protocol, or a flight.
This can give a misleading impression of what is actually being
offset. This is especially the case when, on the basis of offsetting,
a claim of carbon neutrality is made. Many such claims are misleading
and perhaps disingenuous.
There is no standard definition of carbon neutral.
For an organisation, carbon neutrality should require the neutrality
of the whole value chain and whole life cycle of products, services
and operations. A company that sells widgets in the UK that are
actually manufactured in, say, China, should not be able to claim
to be carbon neutral unless they have included the emissions associated
with that manufacturing process, the raw materials, transport
etc within their counting boundary. Carbon neutrality is a convenient
notion but it is open to abuse and obscures a limited and partial
attempt to compensate which can be misleading to the public.
OTHER TERMINOLOGY
Some other terminology currently being used
in the UK also tends to obscure rather than enhance understanding
and appropriate action. For example, the concept of ecological
or environmental foot-printing has proved to be a very useful
way of relating resource demands and impacts to land area. But
to refer to carbon emissions, which are pollution of the atmosphere,
and typically quantified in tonnes, as a carbon "footprint"
is to create a confusing and misleading impression. We have recently
found the term "carbon shadow" is, in many circumstances,
a more meaningful expression for both the consumer and in a corporate
context.
The concept of "unavoidable" emissions
is requires scrutiny. In practice, it typically means "costly"
ie it is a view based on financial considerations, rather than
assessed in terms of climate impact and effects, as if the environment
is a subset of the economy rather than the other way around.
RECOMMENDATIONS
Further to the above points, we recommend that:
1. An offset should be required to deliver
the full carbon benefit equivalent to the emission being compensated
for within no more than one calendar year from the date of the
emission. Any later, or projected later carbon benefit should
be excluded.
2. The Government should stop using terms
such as "carbon footprint" and "carbon neutral"
which require more rigorous scrutiny. These terms are misleading
and will undermine the credibility of positive actions in the
minds of the public. While positive actions and projects are to
be encouraged, claims that offsetting truly compensates for emissions
should be questioned.
3. The Government should only attempt to
regulate the voluntary offset market once it has itself adopted
a more rigorous and responsible stance on these issues.
4. The government should not attempt to make
mandatory a practice—offsetting—which has, to date,
failed to deliver robust results in carbon terms.
5. While afforestation and reforestation
may in some cases be beneficial for other reasons, they do not
adequately compensate for carbon that has been released from the
geological cycle.
January 2007
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