Memorandum submitted by the Institution
of Mechanical Engineers (IMechE)
INTRODUCTION
The Institution of Mechanical Engineers (IMechE)
is a professional body representing over 78,000 engineers in the
UK and overseas. The Institution's membership is involved in all
aspects of energy conversion, supply and use. They operate in
the automotive, rail and aerospace industries, in construction
and building services, in renewable energy, fossil-fuel derived
power generation and nuclear power, and in the over-arching field
of sustainable development. As a Learned Society, IMechE's role
is to be a source of considered, balanced, impartial information
and advice.
GENERAL COMMENTS
The Institution agrees with the Carbon Trust
and many others in stating that carbon offsets, as currently established,
should only be considered by an individual or organisation after
they have first focussed on their own direct emissions and, second,
on indirect emissions arising from within their supply chain.
IMechE supports the "energy hierarchy"
approach, which puts energy conservation (not using energy needlessly)
as the top priority, followed by energy efficiency (using less
energy to perform a given task), then making use of renewable,
sustainable energy sources, then making use of low carbon, non-sustainable
sources.
The key challenge for the carbon offset market
is to ensure it delivers genuine carbon reductions, in accordance
with energy hierarchy priorities and to meet climate change objectives.
As it is currently structured, the Institution does not believe
it will do so. The fundamental problem at present is that offset
projects, at best, only prevent an equal volume of past emissions
being emitted again elsewhere, and therefore make no contribution
to reducing current emissions, only to preventing the doubling
of those emissions in the future. Even those schemes that aspire
to actually remove carbon from the atmosphere (forestation projects),
rather than prevent future emissions, can offer no long-term guarantees,
as trees will almost inevitably fall down, burn down or be chopped
down at some stage.
Until such time as a viable and verifiable method
to remove carbon from the atmosphere and store it securely is
developed, the concept of carbon neutrality through offsetting
is a misnomer. Such a process is not impossible (nature manages
it through photosynthesis, the passage of millions of years and
the exertion of enormous pressures to turn atmospheric carbon
into oil, natural gas and coal). However, to be truly "carbon
neutral", while still emitting all the carbon we do now,
means our challenge will be to artificially replicate this process.
In IMechE's view, it is unlikely that this is a realistic objective
over the timescale likely to be available for action against catastrophic
climate change.
In the context of current and likely future
options, scientific knowledge and technologies, IMechE would suggest
that the following criteria be applied to voluntary offset schemes:
1. Schemes should only be used once all
reasonable measures to reduce direct and indirect emissions have
been taken. The offset providers should work with their customers
to ensure this has been done. There is a strong link here with
the concept of Energy Services Companies (ESCos) and we see no
reason why ESCos cannot also be offset providers and vice-versa,
as part of an overall carbon management strategy.
2. Schemes should save significantly more
than 100% of the emissions being offset.
3. Schemes should be favoured according
to the energy hierarchy, that is focus on energy conservation
first, then energy efficiency, then exploitation of renewable
sources.
4. Schemes should support climate change
and sustainable energy education and research.
5. Schemes should not include forestation
projects unless, and until such time as, schemes can prove that
they really do sequester the declared volumes of carbon, and keep
them sequestered.
6. Schemes should meet the best available
standards in terms of additionality, verification, life cycle
analyses, promotion of sustainable development, and the avoidance
of double counting, eg along the lines of the Clean Development
Mechanism (CDM) Gold Standard, developed by WWF and others.
7. Schemes should not be used (or perceived)
to suggest that individuals and organisations can simply buy their
way out of reducing their own carbon footprint. Offsetting should
not be the cheap or easy option, and the term "carbon neutral"
should be legally protected to restrict its use to those who genuinely
and demonstrably make no net contribution to overall carbon emissions.
RESPONSES TO
SPECIFIC QUESTIONS
Ought there to be a compulsory UK or European
accreditation scheme for carbon offset projects or companies?
If so, how should this operate?
Yes—in accordance with the criteria outlined
above.
Should offsetting become mandatory for some of
the more carbon-intensive activities, such as flying?
All carbon intensive activities, including aviation,
should be included in the compliance market, eg the EU ETS. Legislative,
fiscal and market pressures, including offsetting, should be brought
to bear progressively, so as to drive the behavioural, cultural,
organisational and technological changes needed to reduce global
carbon emissions by at least 60% by 2050.
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?
No—that is why accreditation is needed.
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?
No—while the ultimate aim of offsetting
schemes should be to permanently and fully remove the emissions
to be offset from the atmosphere, afforestation and reforestation
projects cannot yet demonstrate either that they sequester a verifiable
quantity of carbon or that they can keep it sequestered indefinitely.
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. Offset providers currently attempt to forecast
the emissions that would have been produced had their projects
not gone ahead. They are based on projections and assumptions
and can therefore never guarantee complete accuracy.
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?
There is a danger that there will be too few
CDM projects to meet demand from both the compliance market and
voluntary market. The voluntary market will favour CDM projects
because they reduce risks of double counting and both markets
will favour CDM projects because they tend to be much lower cost
than similar schemes in the developed world. Unless very tightly
regulated, the likely consequence is that the verifiability and
additionality of projects will become increasingly dubious, and
the claimed/credited carbon reductions will not, in reality, be
achieved.
What evidence is there to show that offsetting
helps to change the carbon behaviour of the customer?
IMechE is aware of some evidence for this (eg
work by the Eden Project), but existing arrangements lend themselves
to the allegation that the "carbon greedy" can (falsely)
claim to be doing their bit simply by giving a small amount of
money to an offset provider. Accredited schemes must address this
issue.
To what extent are the schemes and projects funded
by offset companies more broadly sustainable, in an environmental,
social or economic sense?
This seems to be highly variable at present—another
reason for accreditation. The CDM Gold Standard goes some way
to address sustainability issues, principally by ensuring community
involvement in offset projects, but there remains tremendous scope
to improve the broader sustainability aspects, particularly in
overall life-cycle assessments and in encouraging energy conservation.
January 2007
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