Memorandum submitted by the Confederation
of Forest Industries (ConFor)
ConFor represents the interests of members across
the timber supply chain, including woodland owners and managers.
We would make the following observations in
respect of your current consultation on voluntary carbon off-setting.
We do believe that there should be a general
and compulsory accreditation scheme for UK carbon off-set schemes,
although we make our comments with particular reference to forestry
off-sets. A compulsory regulatory regime should not be necessary:
the market should be capable of understanding. the difference
between accredited and non-accredited off-sets. We suggest that
an accreditation system, accompanied by an appropriate information
strategy, is essential.
Any scheme should be made as simple as possible
for sellers to adhere to and gain accreditation from, and the
onus should be on transparency of information with respect to
the off-setting claims of the scheme. There are obvious universal
requirements for any off-setting scheme, drawn from the principles
of the UNFCCC protocols and accords, namely those of: additionality,
permanence, biodiversity and socio-economic impacts, and leakage.
In addition to these principles there will also be the requirement
to monitor and verify that the claimed sequestration/reductions
have occurred and will continue to occur for as long as is contracted.
Forestry carbon off-setting schemes hosted in
the UK will face fewer of the problems with respect to socio-economic
and biodiversity impacts which may obtain in other countries,
due to the strict regulation of the industry in the UK. The management
of all woodlands in the UK is carried out against provisions of
The UK Forestry Standard—the Government's approach to sustainable
forestry. The sustainable management of a significant area of
the UK's forests and woodlands is already independently assessed
against the UK Woodland Assurance Standard (UKWAS) and the scope
of this could easily be extended to encompass the independent
accreditation of carbon offsets. The science of how much carbon
is sequestered by any one planting scheme, could be formulated
by another independent body, such as a research institute, and
applied in the independent accreditation process. This would ensure
that the carbon sequestered by a given pl;anting site was not
oversold. We believe that an accredited forestry carbon offset
scheme should always be able to show clearly that there is an
"insurance margin" between the amount of carbon sequestered
and the amount sold. Transparency in this area would ensure that
the market would be able to identify the insurance margin provided
for by different schemes.
The principles of additionality, permanence,
biodiversity and socio-economic impact and leakage are all capable
of being satisfied by a properly accredited forest carbon off-set
scheme. We believe that the science is strong enough in the areas
of afforestation and forestry management to allow credible carbon
off-set trading, with the proviso that, as stated above, there
is a minimum insurance margin of carbon sequestered, held within
the scheme, as a reserve against contingency.
Forestry off-set schemes in the UK are sustainable,
both environmentally and economically. Carbon sequestration accounts
for only around 10% of the non-market benefits of forestry in
the UK, meaning that carbon finance produces considerable environmental
and socio-economic co-benefits. Carbon finance also makes the
significant, marginal, contribution that makes sub-economic planting
viable and ensures that schemes go ahead that would not otherwise
have done so.
January 2007
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