Memorandum submitted by the Eden Project
KEY CONCLUSION —We believe that current
government proposals to drive the sale of voluntary carbon offsets
towards certified projects from the Kyoto market runs the risk
of substantially setting back the cause of sustainable development,
the rate at which climate change is tackled and the growth of
a constituency of the public willing and able to support change
towards a low carbon society.
The Eden Project's focus is on education of
sustainable development related issues focused on the widest public
audiences. We aim to understand, and find tactics for overcoming,
the barriers to prevent many people from showing commitment or
even interest in fundamentally important social and environmental
challenges.
It is as part of this wider mission that we
have developed an interest in voluntary carbon offsets. We have
partnered with Climate Care, who we believe to be the best offset
provider active in the UK, to develop a new product that will
explore how effective offsets can be at driving positive change.
There are several points arising from this experience, and especially
some perspectives on the goal of `behaviour change', that we believe
are relevant to your review.
Ought there to be a compulsory UK or European
accreditation scheme for carbon offset projects or companies?
If so, how should this operate?
Of course some regulation of the offset market
is needed. Like any trading standards issue, people who are sold
offsets should have confidence that what has been promised will
be delivered, and the quantification of the offset provided should
be verifiable and plausible. (Although this does not necessarily
rely only on technical precision—innovative and exploratory
portfolios can be developed that guarantee a certain minimum return,
but also have the potential to achieve much more.)
Beyond that we do not believe that enforced
methodologies are valuable, in fact they could be destructive.
The development of ways to reduce the threat from carbon is a
field that is in its infancy, and yet could hold the key to humanity's
very survival.
The voluntary offset market should be able to
explore options that are effective in terms of fostering understanding,
motivating people and building funds that can drive sustainable
development and proactive responses to climate change as fast
as possible. The voluntary market complements rather than threatens
the mandatory market, and should be free to be a source of innovation.
The Certified products that are traded through
global mandatory schemes are approved as a result of complex international
negotiation. Inevitably they are risk averse. The mechanisms by
which they are implemented are complex and hard to explain, meaning
that the projects they are rarely motivational.
Should offsetting become mandatory for some of
the more carbon-intensive activities, such as flying?
We support the move towards personal and organisational
carbon allowances across all of society. Tackling specific activities
makes less sense to us. There will ultimately be a potential issue
of double counting, if individuals offset their annual carbon
footprint, but also find that particular activities are compulsorily
offset.
If individual industries are to be given a carbon
offsetting challenge the important question is how should this
be done. An important quality of the trading model for pollution
reduction is that it drives innovation by providing an incentive
for carbon reduction. If compulsory payments are applied in all
circumstances, with no link to efficiency, then the incentive
for change disappears.
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?
Not at the moment—the system is complex.
We support the recent developments of "consumer advice"
papers that evaluate offset provision.
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?
We do not feel that forestry projects should
be encouraged, by either the voluntary or compliance markets,
until policy is more evolved and robust. It is not just a question
of science. Forestry has complex qualitative dimensions and plantations
of fast growing trees can be disastrous for water reserves or
biodiversity. Forestry also has complex governance issues and
the scope for corruption seems too great. These issues can be
addressed, but a framework is needed.
Is there sufficient data available to guarantee
accurate amounts of carbon or other GHG mitigation in the sorts
of schemes which offset projects finance?
No—not for either the compliance or voluntary
markets. In both cases projects can fail and promised delivery
may not materialise. However the question is not helpful, because
accurate guarantees are not the only way to structure the schemes.
Offset schemes should be more akin to investment portfolios—providers
should offer guaranteed minimum returns, and still be free to
invest in projects that could give spectacular additional performance.
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?
The two should be complementary, with the voluntary
market free to prove the value of innovative projects and meet
wider sustainable development goals. Many voluntary market projects
will then be able to move to the compliance market, raising the
overall standard.
What evidence is there to show that offsetting
helps to change the carbon behaviour of the customer?
Many of the people who call for behaviour change
by others are not presenting a well thought through argument,
and show a limited understanding of of human behaviour and motivations.
In some cases the arguments presented verge towards a poorly focused
moral tirade against consumerism. Of course there are aspects
of modern "throw away" society that are depressing and
worrying, but to really achieve change we need to recognise that
social behaviours arise from a complex network of causes, and
to really achieve change we need to better understand the role
and potential of individual action in a wider context.
There are also complex issues of social justice
involved. Whose behaviours need to change, and who decides? Does
everyone need to change (in which case is there a case for legislative
action) or are we looking for leadership action? If the latter,
isn't motivation a better tactic than criticism?
Our perspective is as follows:
Firstly we feel that in many instances spontaneous
and voluntary mass behaviour change is not the only positive goal.
We believe that voluntary offsets can provide an effective mechanism
for encouraging greater understanding and literacy with regard
to carbon footprints, carbon allocation and mitigation. The most
important outcome may be the development of a wider constituency
prepared to accept, and able to see the value of, legislative
changes.
To this end we have been exploring different
approaches to the presentation of carbon offsets to our visiting
public at Eden Project. Our expectation, and our experience, is
that the principle of offsetting is still strange and confusing
for many people, and there is a substantial education and awareness
challenge to be overcome before carbon allocations and the potential
for carbon trade become widely accepted. It is important to recognise
that the potential learning that comes from seeing offsets for
sale is not limited to those who first choose to buy them.
There is also an important question that relates
to the potential contribution that personal behaviour change can
make to the overall challenge of climate change. The reality is
that there are many aspects of the bigger picture that are not
in the control of individuals, and need action at a societal level.
Simply put, is it enough to change our light bulbs and insulate
our homes if the greatest energy wastages are in power stations
and across the grid? Is it enough for the UK to tackle its domestic
challenges and not look for ways to reduce major emissions elsewhere
in the world?
There are many aspects of contemporary life
where people are not really individually responsible for the situations
they respond to, and where they feel unable to achieve the change
they would like to see. Our "behaviours" are often not
really in our control. Many of us own cars and drive simply because
we live in places where our homes, workplaces and the places we
go for goods and services have been separated by planning regulations,
and where we have no really effective and affordable public transport
options available.
One of the most important dimensions of the
voluntary offset market is that offsets give people agency—for
the first time we are able to make a contribution to solving bigger
infrastructure problems that are normally out of our sphere of
influence.
From this perspective there are also strong
relationships with a wider international and sustainable development
agenda. Offsets give people a chance to invest directly in the
future that they want to see. Projects such as better stoves for
Africa are powerful because they help tackle multiple problems
and are strongly motivational. They show that positive change
is possible, and can be influenced by individuals. This is the
behaviour change conversation that would be worth having—focusing
not on a list of things that "should be stopped" but
on a broader question of how we can encourage people to proactively
act, and invest, to make the world a better place.
It is often suggested that people who buy voluntary
offsets do so to assuage guilt and to justify an unchanged lifestyle.
We believe that this is fundamentally flawed thinking, and our
research confirms this. Anyone who has understood what an offset
is, and how valuable it can be to resolve climate change, to the
point where they are prepared to spend money voluntarily is likely
to be fundamentally committed to the idea that they should do
what they can. Cynics who don't really care or who don't believe
in the issue, or those who don't understand it, will have no reason
to buy an offset anyway.
Interestingly if a personal carbon allowance
was introduced by law, then the question would disappear. People
who don't care about climate change will be forced to comply.
There is simply no way to avoid the fact that anyone who has the
money to do so will probably be able to purchase additional allowances.
If they wanted to, they could use these to drive inefficient cars
or continue with any other behaviour they choose. The only way
to tackle these problems would be to make things like inefficient
cars illegal, or find some other incentives.
However even then the net effect of a compulsory
scheme would be to discourage people from carbon use and increase
consumer demand for manufacturers to produce more energy efficient
products. If it was introduced, a scheme of this kind would be
like any form of "green tax"—the behaviour change
looked for is forced by hitting the pocket and does not rely on
a moral "buy in" from the people who are taxed. Does
it matter?—maybe not. The most crucial thing is that the
problem needs to be tackled urgently.
Even recognising that there may be no real change
in attitude for some people with a compulsory scheme, we don't
really believe that paying a carbon offset will encourage wasteful
energy use, as is sometimes suggested. Does paying an additional
tax to have rubbish removed mean that people will run out and
look for ways of producing even more waste?
To what extent are the schemes and projects funded
by offset companies more broadly sustainable, in an environmental,
social or economic sense?
It's a very good question—they can and
should be focused on wide sustainable development goals, or we
tackle the superficial causes of climate change but not the underlying
and fundamental ones. Climate change is dangerous in part because
it raises the tensions associated with iniquitous global development—how
can it be correct that the solutions to climate change do not
try and address these issues?
However identifying and verifying good projects
that meet multiple aims is complex. Forcing adherence to the compliance
market is simply not the right way to try and achieve this. The
global map of CDM projects demonstrates this beyond any debate.
We desperately need mechanisms that can innovate and promote new
solutions in eg Africa.
January 2007
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