Memorandum submitted by Moor Trees
1. BACKGROUND
Since 1998, our charity (Moor Trees) has been
restoring native woodland in and around Dartmoor National Park.
Moor Trees' charitable status and community-based approach requires
a highly responsible, ethical and transparent approach to all
our activities. As such, we are recognized around the region for
our socio-environmental outputs. More recently, we are increasingly
engaged in the issue of climate change, both as a source of information,
knowledge and objective opinion, and a respected resource for
organisations and individuals seeking to play an active role in
climate change mitigation and adaptation.
As with the rhetoric of climate change, carbon
offset has grown in both public awareness and media appeal. This
has inevitably led to a surge in the value (and profitability)
of associated markets, with new organisations (mostly for-profit,
many internet-based) emerging to take advantage of the anticipated
spend, arguably before regulation is introduced. Whilst the (Kyoto
Protocol) model of carbon offset is sound in concept, the delivery
framework is fundamentally flawed, with emerging issues of monoculture
afforestation[21],
programme complexity, high levels of bureaucracy and the much
maligned "business as usual" concept stimulating acrimonious
discussion at many levels.
More recently, the surge of the "voluntary
carbon offset" (VCO) market has, whilst similarly based on
a good concept, suffers from dubious science, failed investments,
accusations of green-washing and, in some cases, a lack of financial
and operational transparency. The "for-profit" status
of the major players is also very much open to discussion, as
is the incredibly low per centage of offset funds that actually
go to the project ie 40%-60% top slicing is common.
What should be considered, however, are the
potential benefits of VCO. Tackling Climate change requires a
holistic approach as we have now moved from prevention to mitigation
and adaptation. VCO offers a partial solution through the added
value of a community-based (partnership) approach bringing educational
as well as purely offset outcomes. In other words, we need to
look at a paradigm shift from the "governing of the environment"
to "environmental governance". This can only be done
through broad stakeholder engagement and partnership working.
VCO could play an important role in this.
2. TOWARDS ACCREDITATION?
The question now beckonshow can this
emerging market be brought into line to remove its defects and
by introducing a more robust and accountable operational framework?
As with many environmental partnerships, commentators
suggest that issues of legitimacy, accountability and responsibility
are the keys to success. These issues desperately need to be addressed
for a partnership approach to environmental governance to succeed.
3. 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?
The market desperately needs a robustly enforced
Government-run accreditation scheme (not an NGO which might be
highly subjective). Bearing in mind projects should be community-based,
funding and expertise must also made available to gain accredited
status.
Should offsetting become mandatory for some of
the more carbon-intensive activities, such as flying?
Many airlines have recently commanded huge media
exposure in defence of their aggressive plans for expansion. Their
predictions for flight market growth are indicative of forecasted
profitability and consumer demand. It is, however, difficult to
argue this case due to the medium- to long-term return on offset
investments compared with the short-term impact made by high-
altitude carbon emissions. The perfect solution is to reduce consumer
demand but as long as the airlines continue to offer cheap flights
(particularly short-haul), the appeal of flying will continue
to grow. Perhaps reductions can only be achieved through taxation
leading to significantly increased air fares encouraging the business
community to use webcast technology and the tourist staying at
home to enjoy the warmer weather.
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?
Information offered by VCO providers is sparse
(invariably due to the in-house media expert) but often flawed.
It is difficult for an uninformed, non-scientific audience to
accurately judge scheme value and credibility. The solution will
come from improved regulation and a governing body.
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?
Tree-planting (when carried out and supported
credibly) undoubtedly helps the natural environment adapt to and
mitigate climate change through the improvement of air and water
quality, protection of biodiversity, creation of migration corridors
and carbon sequestration. However, the science of carbon sequestration
is highly complex due to the huge number of carbon uptake variables
per planting scheme. Additionally, climate change itself brings
further uncertainty due to changing growing conditions, though
it is argued by some that these will improve in the UK.
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.
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?
Due to the lack of bureaucracy, quick return
and accessibility, the impact could be significant.
What evidence is there to show that offsetting
helps to change the carbon behaviour of the customer?
Whilst wide-ranging studies considering behavioural
and attitudinal change are lacking, an empirical focus can be
brought through the assessment of local projects. Taking into
account the activities of our own charity, we have been working
with businesses and individuals over the last 12 months in carbon
awareness raising activities through tree-planting. By publishing
an online calculator using well-researched source data[22],
our Climate Action Plan works in partnership with Quangos to firstly
reduce and then offset customer emissions. Through this direct
engagement in conservation and environmentally focused activities,
we have achieved measurable results in both emissions reduction
and behavioural change. However, the use of carbon offset schemes
by business should be part of a comprehensive environmental management
system that involves employees, suppliers and customers in delivering
environmental improvements.
To what extent are the schemes and projects funded
by offset companies more broadly sustainable, in an environmental,
social or economic sense?
Carbon offset is conceptually underpinned by
the notions of sustainability, with the idea of grass-roots level
investment for environmental, social and economic benefit being
well-rooted in agendas at all levels. Indeed, much discussion
of policy and governance at the beginning of the 21st Century
indicates a significant shift in the model of governance away
from "top-down" government control to a "bottom-up"
partnership approach. This "partnership-working" is
increasingly being seen as an indispensable part of the transition
towards more sustainable development and environmental stewardship.
In part, the growing prominence of partnerships is recognition
that sustainability cannot be achieved through top-down government
but requires the active involvement of a broad range of stakeholder
groups, spanning all sections of society, to ensure that sustainability
strategies are context-oriented, so meeting the needs of local
populations. As such, VCO offers a huge opportunity for increased
(financial) investment in the sustainability agenda. Where many
schemes currently fail is in successful community involvement,
so VCO operational frameworks should reflect this need to both
bridge the implementation gap and bring behavioural and attitudinal
change.
January 2007
21 Leading to adverse effects on biodiversity and
socio-cultural implications and with often poor science. Back
22
Defra, NAEI, CEH. Back
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