Memorandum submitted by the Royal Society
for the Protection of Birds (RSPB)
INTRODUCTION
1. The RSPB considers that human-induced
climate change poses the biggest long-term threat to global biodiversity.
To avoid a catastrophe for wildlife, anthropogenic greenhouse
gas emissions need to be cut hard and rapidly, with global emissions
peaking within the next ten years and then declining steeply.
2. In any international regime to combat
climate change, forests have a vital part to play. Emissions from
deforestation, mainly in tropical countries, account for about
one fifth of all emissions, roughly the same as the USA or China.
Uptake of carbon dioxide by forests is, after the oceans, the
most important natural mechanism for removing carbon dioxide from
the atmosphere. By conserving and enhancing forests we can both
decrease carbon dioxide emissions to, and increase removals from,
the atmosphere on a huge scale.
(i) The RSPB therefore strongly supports the
initiative by Papua New Guinea and the Coalition for Rainforest
Nations to build into the international, post-2012 regime a mechanism
for reducing emissions from deforestation and degradation in developing
countries (REDD).
(ii) Recongising that tackling emissions from
deforestation is likely to cost in excess of US$10billion per
year, we consider that the mechanism should either be market-based
or market-linked.
(iii) If a REDD regime is to begin in 2013, considerable
effort (and money) must be expended on building capacity in developing
countries with forests. At present, far too little money is forthcoming.
Despite vocal support for REDD development, particularly from
the UK government, rhetoric has not been followed up by new funding.
We believe there is a need to review the UK's funding plans for
REDD activities, to ensure that these are commensurate with the
scale of the challenge, timely, and managed in a way appropriate
to the needs of recipient countries.
(iv) REDD has now been under negotiation in the
UN Climate Change Convention process for nearly three years; the
negotiations are well advanced and no nation has opposed the REDD
concept. There is thus a strong case for fast-tracking REDD in
the international process.
3. Finally, the RSPB has concerns about
the certification of voluntary carbon offsets from UK forestry.
It would be difficult to determine carbon "additionality"
in relation to such activities, ie to be confident that they would
not have happened without funding from the sale of offsets.
THE ROLE
OF FINANCIAL
MECHANISMS
4. We consider that financial mechanisms
have a key role to play in protecting and enhancing natural forests,
depending upon where such mechnisms are located and how they are
constructed. We see mechanisms established jointly by governments
in the form of international regimes as the way forward, because
these provide the scale of both geographical coverage and finances
needed to do the job, whilst potenially providing a regulatory
framework to guard against perverse outcomes. We do not see private
markets as playing a significant role, although they might help
in some niche areas.
5. Currently, the pre-eminent prospective
mechanism for protecting and enhancing forests is Papua New Guinea's
initiative in the UNFCCC on reducing emissions from deforestation
and degradation in developing countries (REDD). Negotiations on
this subject are well advanced and, since the 13th conference
of parties (COP13) to the UNFCCC in Bali last year, includes not
only deforestation but also enhancement of carbon stocks (potentially
afforestation, reforestation and sustainable management) and probably
also a compensating of rewarding countries that are not currently
deforesting significantly, such as Surinam, Guyana and the Democratic
Republic of Congo. The REDD regime thus has the potential to cover
all aspects of tropical forestry and we therefore focus on this
subject in this submission.
6. Currently there are three main types
of financial mechanism being discussed for REDD: a market-based
approach, a market linked approach and a fund. The market-based
mechanism, advocated by Papua New Guinea and the Coalition for
Rainforest Nations would involve nations setting a baseline, based
on historic emissions, and generating credits for any reduction
below the baseline which could be traded in the Kyoto market,
or its successor. At the opposite extreme is a fund, proposed
mainly by Brazil, into which developed countries would pay and
the money would be disbursed to countries that reduced their emissions,
again below a baseline. There are several market-linked proposals
that would use money generated by a carbon market but would not
be directly linked to it. For example, a developed country emission
allowances might be auctioned and the proceeds used to pay for
reducing emissions from deforestation.
7. For us, a key factor is the choice of
a financial instrument is whether it is likely to deliver money
on the scale necessary to address the drivers of deforestation
worldwide. Stern estimated that tropical deforestation could begin
to be addressed at a cost of US$10 billion per year, although
many consider this figure to be conservative. To deliver finance
on this scale, we some no option but to employ either a market-based
or a market linked mechanism. We do not envisage a voluntary fund
delivering anywhere near this amount of money.
THE ENVIRONMENTAL
AND SOCIAL
RISKS AND
BENEFITS OF
USING FINANCIAL
MECHANISMS
8. There are potential environmental and
social risks associated with all of the mechanisms mentioned above
and any agreement should contain safeguards for biodiversity and
both indigenous and local people.
9. In market-based approaches the most commonly
perceived risk, expressed by many indigenous peoples groups, is
that entrepreneurs will purchase their forest from under the local
people and then try to throw them out, as has happened so often
in the past. This is a reasonable fear, although not one that
would necessarily occur due to implementation of an international
REDD regime. The type of market-based system envisaged by most
governments would involve trading between states, as in the Kyoto
Protocol's emissions trading scheme, rather than trading between
private commercial entities. Whether there was domestic market
would be entirely up to individual governments. For example, Papua
New Guinea is a main proponent of a market based approach but
has said that it might take the revenues from an international
market and put them in a trust fund; which would fund local communities
to conserve their forests in perpetuity. A state-based trading
scheme does not therefore necessarily presuppose any particular
domestic mechanism, which could comprise a fund, a trading scheme,
straightforward regulation or a combination of these. The EU,
for example, is a participant in the Kyoto Protocol's cap and
trade scheme but it has chosen to achieve some emission reductions
via the EU emissions trading scheme, some by regulation and much
by various different forms of mechanisms in member states.
10. International funds offer the prospect
of fairly and equitably delivering money to where it is needed
but, in practice, have a very poor record of doing so. Also, governments
have a poor record of giving substantial sums of money to voluntary
funds, certainly not US$10billion per year for many years into
the future. A hybrid approach, such as a fund using money raised
by auctioning emission allowances might get around this problem
but the difficulty in establishing a fair and equitable distribution
system would remain to be solved.
THE USE
OF LAND
USE CHANGE
CREDITS IN
CARBON MARKETS
AND IN
MEETING EMISSION
TARGETS
11. A clear potential difficulty of any
market-based approach to REDD is that it may lead to the market
in emission reduction allowances from developed countries being
flooded with cheap, offsetting forestry credits. This would not
only have the effect of reducing the amount by which developed
countries reduce their emissions at home (and hence put at risk
their timely transition to a low carbon economy) but it would
not serve REDD well either. To displace lucrative drivers of deforestation,
such as conversion to oil palm plantations, a high carbon price
of at least $20 or $30 per tonne carbon dioxide is required, more
with a biofuels boom.
12. There are several ways of avoiding this
difficulty. The simplest is for developed countries to take on
substantial emission reduction targets of which a proportion could
be met using REDD credits. For example, if developed countries
were to take on 40% emission reduction targets by 2020 from 1990
levels, in line with climate science (as expressed in the IPCC's
fourth assessment report) then 5 or 10% of this target might be
achieved using REDD credits. This type of arrangement might be
formalised in several different ways, as outlined by Papua New
Guinea and some NGOs, notably Greenpeace and the Centre for Clean
Air Policy.
13. Fund-based options, including market-linked
ones, generally avoid this difficult although they can present
different problems, as outlined above.
THE WORLD
BANK'S
FOREST CARBON
PARTNERSHIP FUND
14. We see the FCPF as filling a potentially
useful role in building developing country's capacity to implement
a REDD regime, in advance of a REDD regime coming into force in
2013. In setting up the fund, the Bank consulted widely with both
developing countries and NGOs, including the RSPB, although we
suspect that they might not have done so as thoroughly had the
German Presidency of the G8 insisted on it.
15. However, we have a number of reservations
about the FCPF. The first is that the sums of money available
are small in relationship to the scale of the task. When split
amongst the many countries that could be eligiable for REDD, there
will be only a few million US dollars available for each country
spread over a period of four years, far too little to build capacity
adequately in the largere countries such as Brazil, Indonesia
or the Democratic Republic of Congo and arguably not even enough
for small countries. We are encouraged that the amount of funding
looks as though it may increase by a factor of four (to about
$1 billion) but even that is barely sufficient.
16. We are also concerned that much of the
money available from the Bank may be in to form of concessional
loans. Whilst such loans may be suitable for the activities that
the Bank usually funds, and we can understand concerns by developed
countries about giving money to emerging economies, loans are
poorly suited to capacity building.
17. We are also concerned about the overall
modus operandi of the Bank and, indeed, the UK's faith in it to
deliver environmental objectives. The Bank is set up as, and operates
as a bank. It has considerable experience in making loans, with
a good return to its investors countries, and has generally good,
or at least well developed, relationships with finance ministries
Worldwide. Like all banks, however, it is less good at giving
money away and has poor or non-existent relationships with environment
and forestry ministries. As a consequence, many such ministries
in developing countries dislike and distrust the Bank. A number
of major forested countries have expressed to us a clear preference
for direct bilateral assistance from the UK where, in contrast,
DfID has a good record of forest-related assistance.
THE ROLE
OF TECHNOLOGIES
IN THE
VERIFICATION OF
LAND USE
CHANGE CREDITS
18. It is generally agreed in the UNFCCC
negotiating group on REDD that remote sensing has a key role to
play in assessing deforestation, where forest has been clear cut,
although it is universally recognised that remote sensing must
be accompanied by "ground-truthing", ie ground-based
measurement.
19. Since Bali, however, degradation has
been included in the REDD discussions and, at present, remote
sensing is probably not adeaquate for assessing degradation which
would depend considerably on ground-based measurement. There is
the prospect of assessing degradation remotely but, for the near
future, accompanied by a significant amount of measurement on
the ground. It should be stressed that the difficulties associated
with ground measurements are often overexagerated and that once
a system is established it is not onerous to maintain it.
THE CONGO
BASIN FOREST
FUND
20. Whilst we welcome the Government's introduction
of a special fund for the Congo Basin, the amount of money in
it is inadequate (£40 million over three years). The Congo
Basin countries are a special case amongst the rainforest nations,
in that most of them are not deforesting significantly at present,
many of them are very poor with weak governance and, consequently,
need significant amounts of capacity building if they are to successfully
implement REDD. Indeed, it is questionable whether many of the
nations would be in a position to implement REDD as early as 2013.
A reliable means therefore needs to be found for building capacity
over the medium term.
21. With some of the northern South American
countries, such as Guyana and Surinam, many of the Congo Basin
countries are not deforesting significantly at present, although
there has been significant degradation in some. They thus pose
a difficulty for a REDD regime in that a system that pays for
reducing emissions from deforestation might encourage nations
with low deforestation rates to increase them in order to be paid
for stopping again. A means of avoiding this perverse incentive
might be simply to artificially skew the baselines of such countries
to indicate a fairly high deforestation rate, even when there
is not. If done in an open and transparent way, this approach
might well work but other solutions are still being sought.
THE INTERACTION
OF CARBON
FINANCE MECHANISMS
WITH THE
TIMBER TRADE
22. Since the major climate change meeting
in Bali last year, REDD now includes not just deforestation but
also enhancement of carbon stocks and hence afforestation (plantations)
and reforestation (restoration of natural forest). Therefore,
assuming that REDD is market-based or market-linked, there will
inevitably be and interaction with the timber trade—because
REDD will cover all, or nearly all, tropical timber production.
23. If successful, a REDD regime should
increasingly slow and, eventually halt, the extraction of timber
from natural forests, and hence any trade in it. However, Timber
could still be produced from plantations. In many parts of the
World, especially South East Asia, natural forests are destroyed
not so much for the value of their timber but as part of the business
model for oil palm production. The trees are cut and sold to provide
"upfront" cash for establishing oil palm plantations
whilst millions of hectares that are already clearcut or degraded
remain unused. The situation is often similar, if more complex,
in Latin America where soya production often displaces cattle
ranching which displaces forest. The relative costs of different
activities are evident in such processes: soy is lucrative, cattle
ranching less so and, at present, natural forests are almost worthless.
An effective REDD process would value forests at a higher level
that the activities that currently destroy them.
EU FOREST LAW
ENFORCEMENT, GOVERNANCE
AND TRADE
(FLEGT) ACTION PLAN
24. We support the EU initiatives on illegal
logging and both we and our BirdLife Partners in developing countries
have participated actively in them. However, they are limited
in their scope because of inadequate funding and so, whilst they
have both helped to prevent illegal logging and helped local communities,
they have made limited inroads on the problem as a whole.
25. To be successful, REDD would have to
halt illegal logging as a necessary step on the way to halting
emissions from deforestation.
CARBON OFFSETS
IN UK FORESTS
26. The RSPB has concerns about the certification
of voluntary carbon offsets from UK forestry. It would be difficult
to determine carbon `additionality' in relation to such activities,
ie to be confident that they would not have happened without funding
from the sale of offsets. The RSPB considers that a key climate
change issue in the UK is reducing emissions from society at source,
rather than afforestation in the UK, to mitigate a small proportion
of the UK's greenhouse gas emissions.
27. The UK's importation of timber and wood
products from environmentally unsustainable managed sources outside
the UK, including high conservation value boreal and rainforests,
is of great concern. This is for reasons of irreparable biodiversity
loss and damage, as well as the climate change impacts of such
forest loss and degradation.
28. The RSPB welcomed the UK Government
and devolved administrations' initiative at the 2002 World Summit
on Sustainable Development on timber procurement, forest conservation
and certification. We have concerns about the quality and robustness
of the subsequent definition of environmental "sustainability"
of timber that has been developed. Using "CPET" guidance,
for the UK, country and local government procurement. This concern
also includes the impact on the environmental quality of UK woodland
management, and its credibility of proposals for simplified statements
of sustainability under CPET "Category B" for timber/wood
product specifiers and procurers. Meeting the UK Forestry Standard
must be a minimum requirement for CPET Category B compliance,
backed up by robust auditing by Forestry Commission and Forest
Service Northern Ireland.
29. The devolved forestry policies of the
UK must continue to promote sustainable multi-benefit forest management,
including through EU co-financed land management grants. All new
woodland planting must be appropriately located, designed and
managed to enhance, not damage, important biodiversity, such as
wetland sites, semi-natural grassland, wader areas, peatland,
heather moorland and coastal dune systems. Existing woodlands—native
woods and forestry plantations—must also be managed to protect
and enhance priority biodiversity.
30. The RSPB supports the removal of recent
forestry plantations from restorable important semi-natural habitats,
such as blanket and raised peat bogs and lowland heathland. This
is to meet the UK's and devolved administrations' country, UK,
EU and International biodiversity commitments for wildlife species,
habitats and designated nature conservation sites.
31. It is imperative that rigorous standards
and guidance for UK forestry are developed, to ensure that the
carbon offsets industry and carbon customers have the proper level
of quality assurance for both carbon and sustainability. RSPB
would expect the development of any standards and their certification
to be open, and inclusive—reflecting environmental as well
as economic and social interests. This could build on the existing
mandatory UK Forestry Standard and the voluntary UK Woodland Assurance
Standard (which meets international sustainable forest management
criteria).
32. Carbon standards for UK land management
must be based on robust science, ensure genuinely additional carbon
benefits, ensure that any future banked carbon is safeguarded,
be transparent and independently verified by accredited auditors,
be consistent with sustainable forest management policy and practice,
meet biodiversity policy and practice needs.
33. The RSPB does not accept that so called
"compensatory" planting in the UK is an appropriate
mechanism to increase the UK's woodland area for climate change
mitigation reasons. Targeted grants for high quality woodland
expansion and management in the UK should be strategically employed,
assisting with climate change adaptation for native woods, instead
of a project-based "compensatory" planting approach.
34. We would welcome the introduction of
forest management measures in the UK to reduce unnecessary green
house gas emissions from UK forest operations, and help improve
sequestration and storage, when consistent with the principles
of sustainable multiple benefit forestry including biodiversity
conservation.
October 2008
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