Annex 2
Environmental Audit Committee Visit to Brussels,
18 March 2008
Participating Members:
Mr Tim Yeo, in the Chair
| Mr Martin Caton
Colin Challen
Mark Lazarowicz
| | Jo Swinson
Dr Desmond Turner
Joan Walley
|
09:30—Damien Meadows: The EU ETS and its role in building
a global carbon market and incentivising an international agreement
Damien Meadows is Deputy Head of Unit, Market Based Instruments
Including Greenhouse Gas Emissions Trading, DG Environment.
Mr Meadows explained that there was a lot of interest around the
world in the EU ETS. The Commission would not be able to keep
within the 2 degree temperature threshold without the ETS.
Mr Meadows said the Commission was working hard on
linking the EU ETS internationally, with a particular focus on
the US. The Commission was also looking at widening the EU ETS
to cover more of the economy (as in the US proposals), and to
cover policy measures (also proposed in the US). They were also
considering an EU-wide target rather than NAPs, and developing
a long-term trajectory in line with US proposals. Aviation was
also covered by Lieberman/Warner Bill, and the Commission was
looking into this area. The schemes were now recognisably similar.
Mr Meadows explained that the Commission was looking
to increase auctioning (as in the US proposals). There would be
three levels of auctioning in order to deal with carbon leakage.
If a global agreement could not be reached there would be calls
for protectionism.
In the US there had been proposals to hypothecate
all auctioning revenues to tackle climate change. Mr Meadows explained
that in the EU there had been resistance to this, with the UK
and other countries arguing that it was up to them to decide what
happened to the revenue.
The EU ETS now covered 30 countries—including
countries outside of the EU such as Norway and Iceland. Mr Meadows
said that although there could be ways of bringing in more countries,
there would be challenges in deciding allocations and the Commission
would need to ensure that there was similar stringency between
schemes. The EU could link with Chile and many other countries.
Japan was now shifting its position on carbon trading due to movement
in the US.
Mr Meadows said that a federal ETS in the US would
be preferable to the proposed regional system. The regional system
was not bad in itself, but only covered energy and there was
a risk of carbon leakage between states. Mr Meadows said that
there was also a need for caution if other schemes accepted sectors
that the EU did not, as the ETS would end up de facto accepting
credits which it would not accept directly. Forestry credits,
considered sub-prime in a company-based system, were one area
where there could be difficulties.
Mr Meadows said that the EU would have to wait to
see how the US system functioned before it would consider linking
it to the EU ETS. It would be important to make sure the system
was stringent enough.
Mr Meadows explained that the US was particularly
concerned about international carbon leakage, and would therefore
include international emissions from aviation and shipping in
their ETS to try and deal with this. The Lieberman/Warner Bill
had indicated that there would be 100% auctioning in the ETS.
The Commission had suggested that less should be auctioned—60%
in 2013, if the Commission proposal was agreed to in the Parliament.
Mr Meadows said there could be an agreement in the
US on the Bill in 2008. The EPA was already dealing with reporting
requirements. It could happen quickly. There could be a global
carbon market by the middle of the next decade. It was important
to ensure that all the ETS linked up to get the major benefits
of a trading scheme.
Mr Meadows explained that through the use of CDM
credits in the EU ETS, 150 countries had been involved in the
carbon market. He though this was very positive. In order to give
certainty about the future post 2013, the Commission had indicated
what was likely to happen. But there remained challenges:
Mr Meadows said that CDM had to be an incentive for
developing countries to join an international agreement—rather
than a reason for them not to (i.e. that because they received
help through the CDM they did not need to undertake any action
themselves). Also, it was important to limit CDM credit use to
ensure that action happened in the EU, and that the EU ETS ensured
there was investment in European renewables capacity. Otherwise
it would cost significantly more to reach European renewables
targets.
Mr Meadows explained that although the EU had been
restricting credit use somewhat, it remained the most generous
in the world. There had been reputational damage to the CDM due
to projects on dams and HFCs. These needed to be dealt with, but
the CDM could be successful. The Commission had proposed harmonisation
among Member States by accepting only those projects that all
Member States also accepted, to ensure only the best projects
were used.
Mr Meadows said that the US was highly unlikely to
accept CDM credits from competing industries such as concrete
manufacturing. The US did not want to help competing companies
and would probably restrict credit use to biomass projects and
similar projects. In the proposals, 700 million tonnes would still
go though CDM in the absence of an international agreement. But
this would be expanded if there was an agreement.
Mr Meadows said that the US was including road transport
in their ETS. The Commission was not, as this would involve removing
fuel duties and other similar taxes. ETS would happen in the US
and would include road transport, meaning that the US system would
have broader coverage. It might cover 87% of emissions.
Mr Meadows explained that the Commission did not
have a target carbon price—but it had been calculated that
a 40 Euro cost was required by 2020 if Europe was to reach renewables
and GHG emission reduction targets. These high prices were also
needed to stimulate CCS and other more expensive technologies.
The US system would not include agriculture and forestry,
because they shared the same concerns as the EU. The US had suggested
that these matters should be covered through offset projects and
related measures.
Mr Meadows said that industry was generally more
supportive of 100% auctioning if the revenues were used for R&D.
Mr Meadows said although there was pressure to increase
the 3% CDM figure, this was a reasonable compromise. Some NGOs
thought that with a 20% target all effort should be within the
EU. Mr Meadows believed this would make matters more expensive.
The Commission had tried to balance effort and cost.
Mr Meadows explained that Germany was pushing for
far greater auctioning and reduction targets. However, Germany
was also determined that there should not be carbon leakage.
The UK was working hard at pushing ETS in the US,
and this had contributed to increasing business interest in this.
Mr Meadows said that sectoral agreements would be
required if carbon leakage was to be avoided, otherwise there
would be problems in the post Kyoto phase. This could mean that
a border carbon tax would have to be introduced, which would not
be desirable.
10:20—Lynn Sheppard: International climate
change, from Bali to Copenhagen
Lynn Sheppard is Policy Officer for International
Climate Change negotiations, DG Environment.
Ms Sheppard explained that the EU needed to intensify
cooperation with third countries in a range of bilateral and multilateral
fora. In particular, there was a need to flesh out what was expected
of and by other countries. The EU had set out its headline expectations
in the 2007 climate change and energy package, eg for LDCs. It
was also important to identify the incentives required to bring
people on board and to differentiate between the developing countries.
Ms Sheppard said the Commission was working on this to try and
establish how responsibilities should differ.
Ms Sheppard said that an impact assessment published
in 2007 had linked the 2 degree target to policy options and costs,
and had modelled the contributions of other possible parties.
Ms Sheppard believed that Poznan would be key in
providing a milestone for the negotiations. In advance of the
Poznan talks, it would be important to narrow down what needed
to be done, especially with regard to developing countries and
what assistance could be made available to them. Such assistance
would need to encompass financing, technology and adaptation.
Ms Sheppard explained that the EU was aiming for
a 'top-down bottom-up' approach. The 2 degrees target had been
identified as the main objective at the top. Meanwhile, policies
at the bottom aimed to deal with the same headline target, but
in an equitable way.
The Commission had three main reasons for engaging
with developing countries on climate change: to build capacity,
to build political will and trust and to fulfil obligations under
the millennium development goals. Furthermore, climate change
was integrated development aid and foreign relations. The Commission
always addressed climate change in discussions with third countries.
Ms Sheppard said there was a realisation among a
number of developing countries that they needed to take real action
to tackle climate change, and that there were links between climate
change objectives and other objectives such as energy security
and sustainable development.
Ms Sheppard said that the EU also had contacts with
OECD countries.
Ms Sheppard stressed that it was crucial to get emerging
economies on board due to their rising emissions. Ms Sheppard
said that over the next year it would be important to explore
the contribution that could be made by developing countries. Part
of this would involve making clear to them the costs and benefits
- such as using Stern-type reports. However, India had rejected
the offer of a Stern review, saying that they preferred to do
this internally.
In terms of developing country cooperation, the EU-China
Climate Change Partnership was the most advanced. This project
aimed to improve practical capacity and improve political will
and trust. Project activity included work on CDM and CCS, adaptation
and market based mechanisms. Ms Sheppard explained that the NZEC
project was one of the key outcomes, and the UK was very involved
in this. The project was currently at phase 1 (i.e. R&D on
issues such as storage and the technology), and the joint steering
committee would be ready to report in late 2008/early 2009. Phase
2 would be more specific feasibility studies and phase 3 would
involve actual construction and operation. Ms Sheppard explained
that originally Phase 3 to be completed by 2020. However, she
said the Commission was clear that that was not soon enough and
was trying to bring the date forward. The Chinese had not been
sure about this, but they had recently appeared to be more willing
to bring it forward. Ms Sheppard hoped that phase 3 would now
be complete by 2014. She said that it would be hard to bring it
further forward: although the technology was not particularly
novel there were certain technological issues which would take
time. The Commission was currently trying to work out funding
mechanisms for Chinese and EU demonstration projects. Ms Sheppard
believed this would depend on the carbon price.
Damien Meadows agreed that a good carbon price was
essential. The revenues from auctioning could help. The ETS was
stimulating development of this technology.
Ms Sheppard said that, in terms of improving the
CDM, the Commission was looking at the CDM Executive Board to
ensure that it had the resources it needed, and that it worked
in a transparent and coherent way. It was also important to ensure
that host countries took responsibility for ensuring the sustainability
of projects.
Ms Sheppard said that climate change had a high profile
in discussions between the EU and China. There would be a focus
on climate change during the 'Jumbo' visit in April 2008. Behind
the scenes the Chinese had definitely been constructive in Bali.
It was important to avoid duplication, so it was
necessary to manage and coordinate different processes. For example,
it had been decided that the talks at Hokkaido would focus on
the long term stabilisation target. Ms Sheppard explained that
in the Major Economies Meeting, the Commission would be ensuring
that the MEM supported the UNFCCC process. Ms Sheppard believed
that these meetings could have the potential to be quite helpful
due to those involved. The challenge for the EU was to avoid getting
mired in process, and to ensure that any declarations or conclusions
led to a unified conclusion further on from the previous position.
Ms Sheppard admitted that it was difficult to keep up with all
the meetings. She believed that the UK was best placed staff-wise
to work on this. However, it remained a challenge. Better coordination
was needed on all bilateral contacts—7 or 8 Member States
were working in China and achieving good cohesion. But in other
countries this was not always the case.
11:30—Stavros Dimas, Environment Commissioner
Tim Yeo MP (Chairman) welcomed Commissioner Dimas.
He asked whether, with the increasing consensus on the need to
reduce emissions, the Commissioner thought that the EU should
go further than 20% unilaterally to get the required action.
Commissioner Dimas said that the EU target was 30%.
The EU had fought for this in Bali, but it would only make sense
as part of an international agreement. The EU was aiming for a
2 degree reduction, and this would require a 50% reduction globally
by 2050. Commissioner Dimas said that it was important to fight
for this in the EU and globally—and to fight not only fight
for the targets but also for their implementation. Some states
had expressed concern about trade exposure and this could have
an impact on their ambitions.
Mr Yeo asked whether auctioning revenues should be
used to pay for technology.
Commissioner Dimas said that this had been the EU's
original proposal—not only for technology but also for education,
adaptation in LDCs, technology transfer and other related matter,
even tackling fuel poverty. Commissioner Dimas explained that
the EU had encountered resistance from a number of countries,
in particular the UK. Even so, the UK had said that some of this
money would be used to deal with these issues.
Commissioner Dimas said that a number of states wanted
100% auctioning for the power sector—including the UK. The
Commission had concluded that this was right, but for energy intensive
sectors it had also been decided that they should not be required
to buy so many credits. They might be given 100% free allowances
or importers might be required to pay for allowances to make up
for this uneven playing field. It was possible that 10% of auctioning
funds could be hypothecated for developing countries.
Commissioner Dimas said that carbon leakage was bad
for the environment and for employment. However, he insisted that
whatever was done to address this needed to be in line with WTO
rules and in the spirit of common but differentiated responsibilities.
The EU's international partners would have to accept that the
EU was not going to allow the complete loss of its industries.
This issue had to be addressed because if these industries were
to move overseas there would actually be an increase in emissions.
Commissioner Dimas insisted that, whatever the degree
of auctioning, the EU would meet its 20% target as the cap would
be reduced in a trajectory.
Colin Challen MP asked whether the WTO should be
made to address climate change more robustly. Mr Challen suggested
that the need to tackle climate change should trump the competition
rules of the WTO.
Commissioner Dimas agreed with Mr Challen. He said
that there may be some difficulties if the EU required importers
to buy into the US. However, the US was also looking at this matter
(in the Lieberman/Warner Bill), so the EU was in line with the
US on this particular topic.
Commissioner Dimas stressed that the EU could benefit
from implementing climate change policies. For instance, meeting
the EU's 20% target would mean that EU air quality requirements
would be met as a co-benefit, at zero cost. This would be a saving
of some 10 billion euros.
Commissioner Dimas explained that the EU had tried
to get shipping and aviation on the agenda in Bali, but it had
been unsuccessful. Nevertheless there were some hooks for addressing
this at a later point. The EU had asked the ICAO and IMO to come
up with proposals by the end of 2008. Otherwise some proposals
would need to be moved. This was not ideal as the EU would prefer
a global deal.
Martin Caton MP asked whether we had reached a stage
where climate change trumped biodiversity. He gave the development
of the Severn Estuary project as an example.
Commissioner Dimas said that in these cases it was
important to use common sense to balance the benefit. For instance,
wind farms should not be put in known bird flight paths. An environmental
impact assessment would help to identify ways to balance the problem.
Commissioner Dimas said that this was a difficult matter that
required care.
Commissioner Dimas said that the Lieberman/Warner
Bill, and other measures, indicated that the US was moving forward
on climate change. However, their ETS would be slightly different
from the EU ETS because it included surface transport. The EU
was working with all these countries and states with a view to
linking the European ETS with their schemes in the future. This
had already been achieved with Norway. Commissioner Dimas said
that this should be the EU's ultimate goal.
Mr Challen asked whether the EU should use contraction
and convergence, and whether policy was already moving towards
this anyway.
Commissioner Dimas said that it was important to
have a shared goal for the long term, such as a temperature limit,
a concentration limit or a targeted reduction. There would have
to be common but differentiated responsibilities, like those negotiated
in the EU. A similar solution could work. Another option would
be to have international sectoral agreements, country sectoral
agreements or other measures. The per capita emissions would be
reflected in an ultimate agreement.
Commissioner Dimas said that although the US still
wanted China and India to have binding targets, this was not feasible.
Commissioner Dimas said that it was important to
ensure that the CDM went to the LDCs rather than fast developing
countries such as South Korea or China who should be required
to take on more commitments. The transfer of technology and funding
would play a role in this. Commissioner Dimas insisted that these
countries also needed to accept energy efficiency targets and
similar measures, especially where there were large co-benefits.
Commissioner Dimas thought that this was a reasonable thing to
ask.
Mark Lazarowicz MP asked whether Commissioner Dimas
had any concerns about biofuels.
Commissioner Dimas said that he did have concerns
about biofuels, both environmental and social. He was particularly
concerned by food prices. He also said there was a risk that a
10% target could end up causing the destruction of tropical forests.
For this reason the EU was introducing sustainability criteria,
the first targets of their kind in the world in relation to biofuels.
These targets had to prevent damaging land use change and would
require at least 35% greenhouse gas savings. The Commission had
said that the target should not be reached if the fuel could not
be sourced sustainably.
Commissioner Dimas said that the Commission was trying
to promote second generation biofuels. However, the Commission
still had concerns over these fuels, in particular where waste
fuels were being used. It was important to assess whether biofuel
was the best way of using this material. There were also a number
of issues. Commissioner Dimas felt that the initial enthusiasm
for biofuels had declined.
Commissioner Dimas said that it was also crucial
to ensure that there was no displacement. This was a particularly
difficult issue to deal with. Preventing deforestation was very
important both for biodiversity and climate change. Deforestation
was one of the most important aspects of the Bali negotiations,
given the emissions and how cheap they were to deal with.
Mr Yeo asked the Commissioner whether there was anything
he wanted to say to the Committee.
Commissioner Dimas asked the Committee to continue
its good work. He said that the UK Parliament and UK Government
had both played an important role in ensuring that climate change
was on the agenda. The UK had been instrumental in persuading
other countries in the EU, and as a consequence there was a better
chance of reaching an international agreement. Commissioner Dimas
said the UK had also played an important role in the US.
12:50—NGO lunch
Participants: Stephan Singer (WWF), John Hontelez
(European Environment Bureau), Alexander Woolcombe (Oxfam), Matthias
Duwe (CAN-Europe), Mahi Sideridou (Greenpeace).
The NGOs said that they would like agreement on a
long-term goal of 2 degree Celsius, and a framework in line with
the IPCC Scenario, such as reducing emissions within ten years.
It was important to ensure that the EU had a leadership
role by keeping up domestic pressure on Governments. An agreement
would also depend on arranging commitments to adaptation and technology
transfer.
The NGOs said that more secure and long term funding
sources needed to be agreed. Stern had said that $300-400 billion
per year was needed to pay for adaptation and everything else
that was required for the next few decades in order to keep within
550 ppm, even though this limit was already too big. There needed
to be hypothecation of auctioning revenue from the ETS—this
could generate some 30-60 billion euros per year. The NGOs were
worried that this money could disappear if it went straight back
to the states. They felt that possibly 50% should be held back
to pay for adaptation. If the money was not going to come from
this type of hypothecation then member states should say where
it would come from and what would be required to deliver it. Funding
should be built into international schemes, such as the adaptation
fund.
The NGOs agreed that there was a need to shift current
expenditure on energy, which was currently some trillion dollars
per year, to low carbon forms and energy efficiency.
The NGOs said that action was failing to live up
to rhetoric, for example on policies to reduce emissions from
cars.
The NGOs insisted that EU and domestic policies needed
to be decided this year due to changes in the EU Parliament and
the arrival of new Commissioners coming in next year. The need
to fit in with Bali was another factor.
The Committee and the NGOs discussed the balance
of power in the EU. The Commission was now the main driving force
for climate change policy in the EU rather than the Council of
Ministers. The NGOs named some key UK MEPs in the climate change
debate, including Linda McAven, John Bowis and Caroline Lucas.
A new NGO-run website would soon be launched for
EU citizens, giving information about climate change action in
the EU. The website could be found at www.ourclimate.eu
The NGOs said that climate change needed to be mainstreamed
into aid funding. This was only just beginning to happen. Aid
needed to be climate-proofed.
14:15—Walter Kennes: Developing countries
and climate change
Walter Kennes is Head of Sector, Sustainable Management
of Natural Resources, DG Development.
Mr Kennes presented the Global Climate Change Alliance
(GCCA) and gave the Committee an information note. Mr Kennes explained
that the Commission was aiming to make developing countries realise
that they had to deal with climate change for development reasons.
The Commission was also seeking to provide funding for adaptation.
Mr Kennes believed that dealing with deforestation
could be advantageous for development, poverty and climate change
reasons. Action in this area should be carefully prepared because
the drivers of deforestation were complex—energy needs (charcoal
and firewood), population increase, illegal logging etc. It was
also important to prevent the degradation of forests. The Commission
is undertaking studies on this, such as that on paying for avoided
deforestation in developing countries. The Commission felt that
this work should also be linked with the poverty/livelihood needs
of the people living in the forest. There was also a link with
biofuels, because it was important to ensure that this did not
cause deforestation or an increase in food prices.
Mr Kennes said that getting forestry into the CDM
was a complex matter. It is important to distinguish private sector
activities in ETS from the Government activity to reduce emissions.
Mr Kennes said he understood that for the non-ETS part member
states could use reforestation projects under the CDM. However,
private companies could not do this because these projects were
not permitted in the ETS. Mr Kennes acknowledged that there were
concerns about allowing these projects into the ETS. Such concerns
are for example related to the possibility of destabilising the
carbon market as well as to the issue of monitoring. Mr Kennes
thought that, from a development perspective, it was a pity that
developing countries, particularly Least Developed Countries,
could not benefit from reforestation projects, which in addition
to climate benefits also generate benefits in preserving biodiversity
and improving livelihoods.
Mr Kennes said that the Adaptation Fund was still
very small at present, but that it could build up gradually and
become very large after 2012. He said that the Commission would
prefer adaptation to be mainstreamed in development strategies.
It should preferably be implemented by budget support rather than
on a project by project basis in order to reduce transaction costs.
Mr Kennes thought there could be more innovative forms of funding
such as hypothecation of future auction revenue. Mr Kennes hoped
that by the Poznan meeting there would be progress on adaptation
funding and the GCCA.
Mr Kennes explained that commitment in developing
countries to mainstream climate change adaptation and environment
more in general into their strategies had been limited so far.
Often the Minister for the Environment in these countries was
quite weak in comparison to other Ministers, and commitment was
fairly limited. But there are examples of countries that showed
commitment like Mozambique and Tanzania. And there are many island
states that are committed. Mr Kennes said it was important to
differentiate between developing countries. It was also necessary
to ensure that those countries that were poorest and that would
not have any emission commitments, did make efforts to move towards
a low carbon growth path and deal with their deforestation emissions.
However, they would still be exempt from cuts.
15:30—Mark Major & Stefan Moser: Clean
air and transport issues
Mark Major, DG Environment and Stefan Moser, Deputy
Head of Unit, Clean Air and Transport, Directorate General.
Mark Major said that the IMO adopted in 2005 a decision
on how to reduce emissions. The Secretariat of the IMO was pushing
hard on this, but had little power. Norway and Denmark had called
for a charge on bunker fuel to fund offsets and/or pay for adaptation
or fund a technology programme. This could raise tens of billions
of euros per year. The EU was pessimistic about obtaining a successful
agreement in the IMO. Also, the UK had a 'principled' objection
to this hypothecation.
ICAO was opposed to aviation being included in ETS
without mutual consent (i.e. between both countries).
In 2005 the EU launched a strategy to reduce emissions
from aviation. It was decided to use the ETS.
The Commission had said that if the IMO and ICAO
did not deliver proposals, the Commission would issue proposals
itself. The Commission may also call for the inclusion of shipping
in the ETS, or mandatory standards, variations in harbour dues
or other measures. The picture would be clearer in 2008. Proposals
on aviation had already been established.
Colin Challen asked whether there should be a European
capacity for aviation, to put an end to arguments that countries
needed to expand their airports because otherwise they would lose
business to expanding airports in other European countries.
Stefan Moser said that the Commission did not support
this type of intervention. The Commission was focussing on the
ETS to reduce the emissions. He hoped that the US would come on
board. He did not think the Commission's ETS proposals would fail—but
in the event that they did, another way of dealing with emissions
would need to be established.
Mr Moser said that it was not clear whether IMO and
ICAO would be able to move forward—but it was important
to give them a chance to take action, rather than acting unilaterally
from the start.
It would be unfair to other sectors if the post-Kyoto
agreement failed to address aviation and shipping. If other countries
were not willing to reach an agreement then the EU would go forward
unilaterally. However, action would be less substantial in this
case than if all countries were in agreement, because care would
have to be taken to ensure European economies were not damaged.
Mr Moser said that if a carrier rejected the fees
they would not be permitted to land. This could contravene WTO
rules so it would be important to ensure that all parties were
treated equally. Mr Moser believed that this action was legally
viable, although he recognised that the US disagreed. He acknowledged
there was a risk that the EU could be found against in ICAO.
The Commission was not really looking at changing
transport modes, rather it was seeking to get their carbon price
reflected. It might be that, in order to reach the 2050 target,
aviation would end up using all the permitted emissions.
Rail was now covered by the ETS due to its use of
electricity. Cars were not covered, but the EU was undertaking
work to improve car efficiency.
Mr Moser said that the Commission had a number of
work programmes trying to improve rail in the EU, especially international
rail.
Mr Yeo said it was quite ironic that rail was the
only mode of transport fully included in the ETS even though,
environmentally, it was one of the best forms of transport. Mr
Yeo asked whether EU's proposal of giving a large proportion of
allocations for free would simply act as a permit to keep emitting.
He was concerned that the credits would simply provide a windfall.
Mr Moser explained that total emissions would be
capped, and that the sector would have to stay within that cap
by purchasing credits, even though the sector was expanding.
Mr Yeo asked whether there were any proposals for
ensuring that vehicles were driven in a better way.
Mr Moser explained that this was possible, technically,
but it was considered difficult to do. Instead, the Commission
was focusing on standards based on a typical driver. There was
concern that focusing on eco-driving would take the onus away
from manufacturers' to improve fuel efficiency. Mr Moser said
there were plans to propose an eco-label for cars. It was hoped
that better standards in the EU would improve standards in poorer
parts of the world.
Mr Major said there was tremendous potential for
getting transport projects into the CDM. This needed to be looked
at in order to help avoid the damaging transport patterns seen
in developed countries. There was currently only one transport
CDM project, in Bogota. Mr Major said there needed to be more
focus on programmes like these. This had been mentioned in the
sixth environmental action plan. The CDM could be a way of getting
action on this.
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