Select Committee on Environmental Audit Minutes of Evidence


Examination of Witnesses (Questions 105-119)

MR ERIC BETTELHEIM

11 MARCH 2008

  Q105 Chairman: Good morning and welcome to the Committee. Thank you for coming in at relatively short notice.

  Mr Bettelheim: My pleasure.


  Q106  Chairman: Would you just like to introduce yourself—we do not all know you—and tell us a little bit about your background.

  Mr Bettelheim: Yes, of course, Mr Chairman. My name is Eric Bettelheim and I am the Executive Chairman of a company called Sustainable Forestry Management, which was established about nine years ago. My co-founder in that effort was Richard Sandor, who is now the Executive Chairman of Chicago Climate Exchange and I think widely regarded as the father of emissions trading, particularly having established the efficacy of emissions markets through the sulphur dioxide market, which solved the acid rain problem in the United States. Our company is focused entirely on forestry in the tropics and subtropics, particularly on the environmental services they provide, the key one of which, I suppose, for current purposes is carbon sequestration and storage. I think the regime that we have had to operate under has not exactly been the most encouraging and I would like to say, if I may—I know the Committee has a number of questions but just by way of opening remarks—that I think this topic that the Committee is now addressing could not be more important and could not be more timely. What is clear is that over the nine or ten years of experience that we have had in this is that the architecture for the post-Kyoto world has to be very different from that which has prevailed up until now, if we are really to solve the problem of climate change over the next few decades. I have asked that your staff hand up to you a document which I would like to refer you to. I would like to commend this to the Committee. It is a working paper—not my testimony—prepared by your colleague, Stephen Byers MP, in his capacity as Chairman of the Working Party on Market Mechanisms for Globe 8. This came out following their recent meeting in Rio. If I can just draw the Committee's attention to a few of its recommendations, if you would turn to the third page in the document, there are four recommendations which I think are of the utmost salience in this discussion. The first—and this is recommendation number one at the bottom of page 3—is to start any new regime with a level playing field. In our context what I would emphasise is that it is a level playing field between the developed world and the developing world. The Kyoto Protocol, as I think the written evidence which I submitted demonstrates, is biased against the developing world, certainly against that part of the developing world which is not rapidly industrialising. Almost all the benefits of the Clean Development Mechanism have accrued to just a handful of countries, basically, China, India and Brazil, and the rest of the developing world, and in particular the least developed countries, have received virtually nothing and are outside of the system and do not benefit from it. Of course, that has significant implications for any new treaty which needs their support as we look forward into those negotiations. So I think the bias against the South needs to be removed. The second of the recommendations is to set clear long-term targets for carbon dioxide emissions or greenhouse gas emissions reductions. The systems now in place, particularly EUETS and the Kyoto Protocol process, have a little bit of the old Soviet five-year planning approach to this. Investments that are to pay off over decades cannot possibly be made if there is regulatory and political interference every five years, changing the goalposts, moving the target. I think in the next round of negotiations it is critical that the world set long-term targets, hopefully 30 years or 40 years into the future. Of course, those targets could be revised, made more stringent, as time goes on but it would at least give a clear, simple direction to the market which investors can rely on. The third item is number four in the document, which I think is very important to change for any new architecture if a treaty is to be successful, and that is to move from prescriptive regulation to principles-based regulation. This is the evolution which I am sure members of this Committee have seen in the Financial Services Authority over the last ten years or so. This has made a significant difference; indeed, the United States financial regulatory system is now seeking to imitate the development towards principles-based as opposed to prescriptive regulation in financial markets. The fourth item is number five in the document, which I think is absolutely essential for any new architecture, which is the creation of a new independent regulatory body for the carbon markets. The Prime Minister, as you know, has suggested this and I think it is an opinion increasingly shared by those of us in the markets that the Clean Development Mechanism is not functioning as an effective regulator, that it is unrealistic to expect the United Nations to serve as a regulator of what is essentially a financial market, and that there are other bodies, like the European Central Bank in the case of EUETS, and like securities regulators and central bankers, who are more appropriate regulators for such a market and are experienced in that. There are two last items I would add, and then I will finish my introductory remarks. Although they are implied in this, they are also dealt with in other papers published by Globe 8 at the same time, in particular Lord Jay's report. One is to create a multilateral fund of some sort, whether run by the World Bank or otherwise, which will build capacity in those countries, particularly in the developing world, in the least developed countries, which do not have the infrastructure necessary for private sector investment and participation in the carbon markets. They need help with measuring, monitoring and verifying their carbon and their emissions; they need help with administration and so on. These are not particularly expensive items but they are essential to the countries, many of whom cannot afford this capacity. That is a vital area, I think, for public sector involvement. Finally—and this, I suppose, leads on to my particular focus, which is carbon sequestration—it seems to me essential that the developing world be given credit for their biomass if we are to have a successful negotiation. I notice that very recently India and China have made it clear that they will demand that increases in their biomass through reforestation and afforestation be included. By the same token, those countries that have existing forests that are being degraded or deforested will also demand such compensation if they are to participate in the market, all of which I happen to think would be a very good thing. In conclusion I would say—and I know this may sound heretical—that I think we have our priorities wrong. I think we are trying to force technological change before it can happen and we are not taking up the biological mechanisms which are available now. We seem to have got that inverted. We are delaying in dealing with the one system we know works, which is photosynthesis, and trying to force an early transition technologically. It is probably more logical at least, even if politically difficult, to take up the opportunity which the forests of the South offer us in terms of mitigation of climate change while industry makes the adjustments which the investments over time that it can to take up the running thereafter. Mr Chairman, thank you for that. I am sorry if I have overstayed in my initial remarks but I thought it was very important for this Committee and for political leaders generally to start focusing on a new regime and not simply an extension or modification of the old regime.

  Q107  Chairman: Thank you. We would like particularly to focus on forestry and forestry-related issues this morning but, just responding to a couple of things you said, I am interested in your view—I think I have got this right—that you think central bankers might be better regulators than the UN of a new system. That I find interesting given your concern about recognising the importance of developing countries. I did not realise that central bankers were particularly expert in that area, or indeed that developing countries would necessarily see them as a better holder of the ring than the UN. In relation to long-term targets, the question that arises in my mind is that since the science is changing steadily, long-term targets that might have been set five years ago are clearly going to be grossly inadequate in the light of our present knowledge, and it seems to me that what we actually want is tougher short-term targets. The problem is we set all these targets for 2050 and keep making them tougher, and actually that ignores the fact that we may use up the whole of our budget by 2030 in terms of emissions, and even if we had a 100% cut by 2050, it might be too late. I would slightly take issue with this prescription.

  Mr Bettelheim: Let me respond to the second point first. As I said, I think if you set a long-term target, that does not mean you cannot make it more stringent over time as science improves and as urgency may become more manifest. Climate effects may come faster than we expect them to; they also may be delayed longer than we expect. I think what is important for business is to know that there is at least a minimum line, if I can put it that way, which is a trajectory which will not be changed. It may be to make more stringent but it is not going to be relaxed, and that gives integrity to planning. As for the point about central bankers and the United Nations, I was not suggesting that central bankers understand the developing world. I think the rules, the principles, need to be set by a United Nations-type negotiation and discussion. That would be the principles base, but when it comes to implementation of those principles, it seems to me firstly, we should be able to allow nation states to regulate their own affairs in meeting their national targets, whatever those are, as agreed under a new treaty. Secondly, that when it comes to the detailed, day-to-day management of the market place, of the regulation of the market place, that should be in the hands of financially trained and market-trained individuals as opposed to those who do not have that kind of background. One of the fundamental flaws has been that regulations have been impossible to comply with, at least, certainly in my sector.

  Q108  Joan Walley: May I just follow that up? I was interested in what you are saying about an independent regulatory body for the carbon markets and, just adding to what the Chairman has just said really, how that would fit in. I would not see bankers as the right people to do that but presumably you would have to work out very clearly as well how that sits with the WTO specifically. I was interested in your thoughts on the interface with the WTO.

  Mr Bettelheim: Let me take that in two parts, if I may. The first is the reality that there is not going to be a single global market called Kyoto or anything else. The reality is that there are regional and national markets emerging all over the world: in Australia, New Zealand, the United States, and Europe of course, and that will continue. It will be just like other commodity and financial markets. It is like that now. It increasingly means that different countries are taking different trajectories to reaching whatever targets they set themselves or which will be set in a treaty context. Therefore, you have to look at any international oversight or any international role in that as being one essentially of connecting those things up in a fungible way, that is, creating a common standard against which they will measure themselves. Some credits will meet that standard and some will not. I think it is naive to continue a debate on the basis that the entire world is going to sign up to a single carbon market run by the United Nations. That is not going to happen. It is not happening. If you accept that, then you have to look at how those national regimes should be regulated and how there should be common principles of regulation for those regimes. I am suggesting that the common principles should be established by, say, the United Nations international treaty obligations, but that the implementation of those should be left to national regimes which are capable of handling those issues. That includes, by the way, adding other expertise, not just financial expertise. I did not mean to exclude other participants. Right now we have the reverse situation, where no financial expertise and very little private sector expertise is being brought to bear within the regulatory system. As for the WTO, I think there are some very serious issues as to how that will integrate, particularly if you are talking about carbon being a commodity that is available to everyone. You are talking about affecting the fundamentals of each country's economy—you cannot escape that—and you start to get into debates such as the one in the European Union, which I find extremely troubling, where the view is taken that "If we have a high price for carbon and other countries have a low price or no price for carbon, we will impose a tariff law; we will create a trade barrier." As I mention in my written submissions[72], that is the kind of thinking that I would have thought became obsolete in about 1935, but it has reared its head again because the European view seems to be that a high carbon price is the solution. My view—and I understand people may think that that will work—is that whether it will work or not, it is not going to work in the real world, that the rest of the world is not going to impose a high carbon price, is certainly not going to enforce €40 or €50 or €60, which is what the European Union is now suggesting by its recent stance, on carbon. If you look at what is being proposed in Australia or the United States, you are talking about $10 or $15, which I appreciate has depreciated somewhat recently. There is no chance that the rest of the world is going to go the extremely high carbon price route. Therefore, you do end up with very serious potential trade issues and I think you will find debates which could be extremely destructive, not just about climate but about international trade generally, which would naturally be something the WTO would become involved in, and there would be a very complex series of disputes as a result.

  Q109 Chairman: Do you not think that one consequence of a lower carbon price might be to delay or deter investment in low carbon technologies?

  Mr Bettelheim: On the contrary, I think that everyone realises that markets have a tendency to take the low-hanging fruit first but, once they know they can calculate that, they also know what is coming further out and they take steps to anticipate that. In the example I mentioned to you, in the sulphur dioxide market experience, which is the precedent for carbon trading, the predictions by all the think-tanks—Harvard and others—was that what companies would do when they were given a trajectory of reduced emissions over a decade or so was to track just below that line, to just meet compliance obligations. In fact, they did nothing of the kind. The curve of compliance went like this (indicating). In other words, they over-achieved by having a lower price of compliance. I have a feeling that, if you look at the global situation and the global demand for this under potentially a new treaty and a world in which the Americans—which I believe they will—will have a carbon programme, I think you will find that what business will do is it will over-achieve; it will anticipate what is coming five or ten years from now, even if the low-hanging fruit helps them cope in the short term, which I think is the right approach to market economics. To create a spike in the price now does nothing except encourage business to seek evasion, and even the European Commission in its recent recommendation says, "If we do this, industry is going to leave." All right, it will leave. Where will it go? It will go to those places where they are effectively unregulated. I think it is wiser to have industry stay and innovate under a current low but gradually increasing cost, because the low-hanging fruit is being exhausted, than to have it effectively being told "If you stay here, you are uncompetitive." I think that is foolish and I do not think it stimulates the kind of investment that you consider worthwhile. Businessmen are not as short-sighted as they sometimes are depicted. In the sulphur dioxide market they over-achieved dramatically. Once they knew what the cost was going to be over a decade, they knew how to cope with it and they cut costs much faster, because that is what businessmen are very good at, than anyone ever predicted and I think you will find the same thing in the carbon market.

  Q110  Mark Lazarowicz: On that point the Chairman has raised, do you really think, for example, technologies like carbon capture and storage are really going to be driven forward without a fairly high carbon price to encourage investment, one in which there is a fair degree of certainty behind a relatively high carbon price fairly soon and which will stay at a high level over a period of time?

  Mr Bettelheim: There is a lot of debate about carbon capture and storage. I am not a technology expert but those in the energy industry who have been involved in it are pretty much of the opinion that this is 15 to 20 years away in terms of commercialisation. In that ten, 15 or 20 years that it takes not only to develop into a commercial product that can be distributed but actually to distribute it, which also takes enormous investment, I think you are going to waste a lot of time waiting for it, and the price is not what is going to drive it. What is going to drive it is the expectation of a rising price, the expectation that coal is going to be used until the end of the century. They know that; we all know, if we are rational, if you look at the International Energy Agency predictions, that coal is going to have to be used by mankind to meet its energy needs for as far as anyone can see. There may, of course, be a technological breakthrough of some kind—fusion or what have you—but if you are not betting on that, if you are betting on relatively gradual increases in efficiency and introduction of technology over the coming decades, you know that coal has to be dealt with, whether you call it clean coal or you call it carbon capture and storage, but in both cases that technology is not going to happen tomorrow, no matter how high the price is.

  Q111  Mark Lazarowicz: It is going to take even longer to start, is it not, if the price is low?

  Mr Bettelheim: No, I disagree. Businessmen and financial markets anticipate what the price is going to do. They know it is going to rise. They know this is coming, so they will invest now to be prepared in ten or 15 years to roll out that technology. I think it is unwise to try and force technological change by a price mechanism. What you are doing is you are inverting the priorities of businessmen to look for low-cost solutions. Carbon capture and storage in coal-fired power plants may not be a good solution. It may sound like it now but it may not be. What you really want people to do—and this is what I find rather odd about this debate—the purposes of markets, the reason emissions trading has been adopted by everyone is to drive down the cost of compliance, not to increase it. This is somehow being lost in this debate, particularly in Europe. If there is a better technology, a cheaper technology than carbon capture and storage, we should adopt that, not carbon capture and storage. This kind of debate smacks very much of picking industrial winners. We have had a long track record of governments betting on this or that technology and finding out, lo and behold, that there is someone in a garage in California who wipes the floor with IBM. I think that impulse should be resisted. In the last ten years in which I have been deeply engaged in this I have seen a fashion for about a dozen different technological solutions and if you really examine them, if you really examine how fast they can develop, how much they will cost to distribute, you find out that there are enormous difficulties and they are very unexpected. A recent study by Berkeley University Department of Economics showed that solar power in California, where the sun does shine, is 600 times more expensive to distribute to households than natural gas-fired power plants. That is not intuitively obvious, and a lot of the solutions that people find fashionable at any particular time in the debate—solar, wind, tidal, carbon capture and storage—will not be the technologies that actually solve this problem, and in fact innovation will occur because people anticipate that steady price rise over time and will adjust themselves to that. Trying to force this or that technology as the solution I think would be a bad mistake. It will be a mistake for any economy that adopts it.

  Q112  Chairman: Let us get back on to forestry, if we may. Do you think it is getting the attention that it should have in relation to the negotiations on post 2012?

  Mr Bettelheim: I think, Mr Chairman, since Bali—and Bali was quite a turning point when it comes to forestry, and tropical forestry in particular—it is attracting much more attention than it had prior to that. Whether or not some of the proposed solutions or approaches to dealing with it will be effective I think remains to be seen. Certainly I am very sceptical of some of the approaches that have been floated of parallel markets and separate treaties and so on and so forth. As far as forests are concerned, it is really very simple. You just need to integrate them into the market place, where they have been excluded previously by regulation, and once that happens, you will find they are credited and that the benefits of tropical and subtropical forests accrue not only in terms of carbon sequestration but in all of the other co-benefits, not least of all adaptation by poor people, who are dependent on those forests. When their environment deteriorates, they become migrants. They become internal migrants and also international migrants. When the soil has gone, you do not eat; when the fresh water has gone, you do not drink. Those are pretty fundamental needs, and I think that is beginning to be appreciated, but again, we seem, in the Kyoto context at least, to be drifting into a CDM-like negotiation of detailed prescriptive rules, of the same sort of approach to regulation which I am afraid will probably have the same effect: it will kill the investment in that sector and we will again have a broken promise to the developing world, particularly that part of the world which is not rapidly industrialising, and I think you probably will not have a treaty at all because it will become obvious that no-one is going to invest in the sector. I think it is relatively common ground that private sector investment is essential and that the public sector is not going to pick up the burden of $15-$30 billion a year of investment in this one area.

  Q113  Chairman: Even before Bali, of course, Nick Stern had highlighted the contribution that curbing deforestation could make in part of the solution.

  Mr Bettelheim: Indeed he did.

  Q114  Chairman: Given that we have pretty broad agreement that global emissions are going to have to be reduced to half 1990 levels by 2050, do you have any sense of what contribution avoiding deforestation could make to that?

  Mr Bettelheim: Yes. Mr Chairman, you may recall the last submissions I made to this Committee when it considered the voluntary market[73]. The McKinsey cost curve and the Stern report are more or less aligned and subsequent studies confirm that it is about 20-25% of emissions reductions which can be contributed and it is about a 50-50 split between afforestation and reforestation on the one hand, growing new trees, and avoiding deforestation and forest degradation on the other. It is about 3 billion gigatons per annum by each sector, so 6 billion tonnes altogether, and that roughly accumulates to the percentage reduction in emissions that forestry can contribute.

  Q115 Dr Turner: You are in a particularly good position to assess the costs involved in achieving the reduction and elimination of deforestation, and reforestation as well preferably. Have you any handle on what the global cost of doing this really effectively, achieving the sort of carbon reductions that you have just been talking about, are and how they can be raised and delivered?

  Mr Bettelheim: Yes. I think you will find in recent research done by the Woods Hole Institute in the United States on what is essentially the opportunity costs for avoiding deforestation and forest degradation, prices vary but I think, to be conservative, and our experience would verify this, you have to anticipate an opportunity cost of $5 a tonne. So you have to pay forest owners, whether they are public or private or communal owners, about $5 a tonne to avoid converting tropical forest into agricultural or timber use. If you take the three billion tonnes that is probably available per year—and that is, of course, the maximum, which is probably not achievable in the real world—the Woods Hole analysis in Brazil shows that you can probably get 90% of deforestation compensated at $5 a tonne. The remaining 10%, of course, is the area which has a much higher marginal cost because it has much higher value uses, maybe in an urban area, for example, that will have development opportunities, so you get a 90-10 return, and if you assume it is $5 a tonne, you are something in the order of three billion tonnes, $15 billion for avoided deforestation and reduced degradation of forests. That is consistent with Nick Stern's analysis of that subject. When you come on to afforestation and reforestation, of course, that is more expensive because it is much cheaper to hold something intact than it is to actually prepare land, to plant it and so on, which is a significant part of our business. Even under the best circumstances, you have to assume that the minimum cost of that is about $10 a tonne, so if you take that multiple times three billion, you are at $30 billion for the other half of the six billion tonnes per year of avoided deforestation and re-absorption of carbon that is potentially possible. You can make some more sophisticated analysis of what land can be used in spatial terms and so on, but I think the order of magnitude is something north of $30 billion a year, and that has to be maintained. It is very important to understand that it is not a one-off payment; it is an annual payment, it is a rent, because as soon as the rent stops being paid, the land is going to be converted again or the investments are not going to be made. Certainly, in most terms of international aid flows, you are talking about quite a significant flow and of course, it has to be managed into these economies, many of which do suffer governance problems, do have high political risk and so on, and some of them are in extremely remote areas. That having been said, it should be calculated that you are looking at something north of $30 billion, probably closer to $40 billion a year flow of capital from North to South essentially in order to make forests make that contribution of 20-25% to emissions reduction. In my view, and I think that of most objective observers, there is no source for that kind of payment and, more importantly perhaps, no more efficient source, than the private sector, and that means carbon markets. Generally speaking, businessmen are better at allocating capital than governments to this kind of investment, and they are more likely not to get involved in activities which are opaque, because they cannot deliver opaque credits. If the credit is from bad land, if it is illegal, if it is not traceable back to its source and to a property register and so on, it cannot be sold; it is worthless. If you want the inefficiency of that $30-$40 billion a year to be at its highest, it needs to come from the private sector. With the proviso I mentioned in my opening remarks, many of these countries do need capacity building in order to get private sector investment. They do need land registration systems, they do need administrative systems and so on, which the private sector is not good at implementing. You have a free rider problem that the private company that pays for that benefits everybody, so this is a public sector issue. There is a transitional period. This is one of the points I would like to make that I think is very important. When I was at law school I was always taught by my trial practice seminar that when your opponent gets to the "floodgates" argument, you know you have won. The floodgates are not going to open because it is going to take five to 10 years to prepare many of these countries to the point where they can actually measure, monitor, verify, and reliably deliver to the carbon market credits from their forests because there are serious infrastructure issues that have to be addressed, so this is going to be a gradual process. Even if you agreed that everything will be credited today in the forests, only a very small proportion of that would actually be available over the next five to ten years.

  Q116  Dr Turner: So you think that basically this will be delivered through market mechanisms. Which market mechanisms in particular? Do you see this as a function of an international emissions trading scheme? Can you be more specific?

  Mr Bettelheim: Yes, I do, but not a scheme. This is what I was trying to explain. We are participants in these debates and in these developments around the world. National and regional markets are developing independently of Kyoto. The countries may or may not be an annex one country already bound by Kyoto. I am absolutely confident, working closely with Congress, that the United States will have a carbon trading system under the next administration. My bet is 2010. Maybe it will be delayed by politics or maybe accelerated by politics. I do not know, but, in one form or another, the Lieberman Bill will be adopted, and I do not think there is much doubt about that when you review any of the presidential candidates. That system will not be Kyoto but it will include forestry, both domestic and international forestry. The precise rules as to that are still being worked out and are being debated by Congress and by regulatory authorities but I have absolutely no doubt that that is the case. In Australia and in New Zealand it is already clear that forestry will take the lead position in their trading markets. You may have observed that Australia is only meeting its Kyoto target because of forestry. It is way over its industrial emissions. The reason it is meeting its somewhat increased cap—I think of 103% over 1990—is because of forestry. These countries understand the enormous impact that forests can have in meeting whatever targets they have set themselves or which they have agreed to under the Kyoto process. So yes, I think those markets will be the place at which money will be generated and transferred for the preservation and restoration of forests around the world. That is where the demand will come from.

  Q117  Dr Turner: But clearly, regulation of this activity is going to be absolutely crucial, otherwise somebody will make a lot of money and nothing will actually happen.

  Mr Bettelheim: That is absolutely right.

  Q118  Dr Turner: Mechanisms like the Clean Development Mechanism do not seem to be adequate to this task. Greenpeace suggests that a brand new stand-alone mechanism should be set up to regulate this process. What are your thoughts on how it should be regulated?

  Mr Bettelheim: The reason I am smiling, sir, is that I am delighted that Greenpeace has come to the view that these forests are important. Greenpeace is one of the organisations that has spent the last decade fighting tooth and nail to keep them out of the Kyoto system and to keep them out of the European Union system, so I am delighted that they have joined in our opinion that these forests are worth preserving and restoring. Secondly, I am also pleased, reading their position paper and their proposal that they realise that the markets have some role to play in this. However, if you go on and look at their proposal, you will see that they are going over the same ground yet again that we had with the CDM, a whole list of issues which have been resolved long ago, some of them under CDM analysis but most of them independently but, even worse, you are creating another unaccountable body like the CDM which will go through a CDM-like process and stifle just this kind of activity. I am afraid that creating things out of whole cloth at this stage in the game is too late. It is 2008. We have 40 years. If you are going to get this kind of investment, $30-$35 billion moving every single year for the next three decades to these countries, we do not have time for another five years of negotiating what is a forest: is it additional, and will it be permanent? All of this mediaeval theology that has developed under this process needs to be done away with. Let us get rid of it and let us move on. That is why I think it is so important that the next treaty, if it is to be acceptable and if it is not to be immediately obsolete, does approach this in a much simpler fashion: set long-term targets, admit biomass as long as it is verified, let national governments and nation states make their own decisions about the sovereign use of their land, and allow the capital markets and the financial markets to finally start spending money where it is really needed and where you get a very quick return on the money in terms of climate mitigation. You do not have to wait ten years for a forest to do its work.

  Q119  Dr Turner: How would you audit this process?

  Mr Bettelheim: First of all, as in any commodity market—and I think it is high time we looked at this as a commodity market or a hybrid between financial and commodity markets—the way in which things are audited is through exchanges and clearing houses and securities regulators, in the ordinary way. Buyers and sellers are very sensitive to what they are delivering and what is being delivered and the price they are paying for it. Market discipline is remarkably efficient, and they can tell the difference and adjust the price for the quality of the thing being delivered and, if there is doubt that the carbon credit came from a place that is legitimate or from a legitimate system, that credit is either unsaleable or at a very steep discount. So you can have pretty good confidence that self-interest, not to mention the profit motive, of businesses and investors is going to impose governance and rules which are already being developed substantially in the voluntary sector. This Committee will be aware of the number of regimes, including most recently the Voluntary Carbon Standard, which was developed under the auspices of the International Emissions Trading Association, with wide consultation with the NGO community and developing countries, which is a very rigorous process of regular intervention by third parties to determine the veracity and the permanence and the additionality of each credit that comes out of a particular area or project. So we have the tools. We do not need to invent anything new. The tools have evolved over the last ten years and are ready for use.



72   See Ev 56 Back

73   The Voluntary Carbon Offset Market, Sixth Report from the Environmental Audit Committee, HC 331, Session 2006-07. Back


 
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