Memorandum submitted by the Timber Trade Federation (FOR07)

 

Timber Trade Federation Update

 

Since the EAC 2006 report the UK TTF have now made environmental due diligence mandatory for all members and are now in the process of fully implementing this. All members are either expected to implement the Responsible Purchasing Policy or an equivalent system to meet the requirements of the TTF's Environmental Code of Practice.

 

Since the EAC report the Code of Conduct has also been strengthened. The TTF itself, if given due cause, can instigate an investigation into any member, without relying on a complaint from another member. The UK TTF remains committed to the principle of introducing EU legislation to address illegal logging and set a fair, level playing field in the market place.

 

The TTF continues to work with the financial support of the Department for International Development to support activities in raising the awareness of illegal logging and initiating business to business improvements. These funds have been invaluable to our work. The funds have supported market reports demonstrating the increased purchases of certified timber products. Several roadshows in producing countries have brought about direct improvements with suppliers, greater networking with other industry federations, as well as buyers increasing their commitment to act responsibly.

 

Executive Summary

 

Forests play important roles for local communities, biodiversity as well as carbon storage. The careful management of forests can play a vital role in mitigating climate change in a number of ways; reducing emissions from deforestation and forest degradation, enhancing the sequestration rate in existing and new forests, providing wood fuels as a substitute for fossil fuels, and wood products as a substitute for more energy-intensive materials. The introduction of a carbon fund that is dedicated to forestry projects is a welcomed addition but incentives to implement such projects must be reviewed. Additionally ensuring the funds are targeted at the people who are in greatest need will be the challenge under the proposed initiatives such as Reduced Emissions from Deforestation and Forest Degradation (REDD). Carbon funds are one part of the jigsaw, consequently it must work in conjunction with other national forest programmes and initiatives such as FLEGT as well as existing certification schemes to ensure sustainable forest management that benefits local communities and biodiversity.

 

1.0 The role financial mechanisms might have in helping to address emissions from land use change

 

Forests can play a vital role in a number of ways; reducing emissions from deforestation and forest degradation, enhancing the sequestration rate in existing and new forests, providing wood fuels as a substitute for fossil fuels, and wood products as a substitute for more energy-intensive materials. The causes of deforestation and degradation are due to several reasons; illegal logging, exploitation, poor governance and conversion. Forests play important roles for local communities and biodiversity as well as carbon storage.

 

Kyoto introduced Clean Development Mechanisms (CDM) and Joint implementation (JI). However, forestry has yet to play a leading role within these mechanisms but could provide a cost effective mechanism for mitigating climate change. The Land Use, Land Use Change and Forestry (LULUCF) initiative has had little take up, partly due to the perceived restrictive CDM requirements. The carbon storage function of forests is not accounted for in the first commitment period of Kyoto. We hope that in the post 2012 arrangements carbon credits from the LULUCF and/or Reduced Emissions from Deforestation and Forest Degradation (REDD) will be included in the EU Emissions Trading System (ETS). However forestry has found favour in the rapidly growing voluntary carbon market.

 

Certification coupled with various market drivers and donor programmes have had limited success in tropical countries. Carbon markets can add a further economic incentive for producer countries to protect and responsibly manage forests and thus reverse deforestation and degradation. In some countries poor governance is a factor contributing to deforestation, particularly illegally driven land conversion activities. Therefore carbon programmes alone are not the complete answer. Any carbon market initiative must ultimately halt deforestation and degradation but also complement other national and international forestry programmes as well as policies such as FLEGT that help address the other causes of deforestation such as poor governance and law enforcement.

 

2.0 The environmental and social risks and benefits of using such financial mechanisms

 

Environmental and social benefits are a clear objective of carbon finance funds. Whether the funds have been successful in achieving this is perhaps too early to determine; a review needs to be conducted.

 

 

 

 

3.0 The use of land use change credits in carbon markets and in meeting emission targets

 

Measures that prevent changes of land use from forests to agricultural crops such as biofuels and palm oil plantations, as well as incentives for afforestation and reforestation are welcomed. It is important to value forests which have wider environmental and social benefits over other land uses. As yet carbon credits are not included in the EU ETS, this issue needs to be reviewed as its exclusion has lead to a lack of investment in forestry projects (see comments under 1.0).

 

4.0 The World Bank's Forest Carbon Partnership Fund

 

To have a carbon fund dedicated to forestry is a welcome initiative. However lessons learnt from the operation of the BioCarbon Fund and LULUCF must be taken on board to ensure its success. The fund promotes the concept of REDD which puts a value on the carbon in standing trees. The challenge will be to ensure funds are distributed to those that desperately need them and that works with programmes such as FLEGT and other national efforts to improve governance.

 

5.0 The role of technologies such as remote sensing in the verification of land use change credits

 

Technology that could monitor land use changes would be helpful to ensuring that the carbon markets are successful and claims are verified.

 

6.0 The success or otherwise of Government efforts in reducing emissions from international land use change

 

No Comment

 

7.0 The Congo Basin Forest Fund

 

The fund has common objectives with carbon markets in terms of addressing deforestation. Therefore it should be a complementary programme.

 

8.0 The interaction of carbon finance mechanisms with the timber trade

 

Carbon finance mechanisms should support implementation of sustainable forest management. The projects funded under the carbon finance schemes should be complementary to existing policies, programmes and certification schemes. Certification schemes are the accepted market label to provide assurance that the timber is sourced from well-managed forests. Therefore a carbon market which supports the implementation of certification, particularly in countries where take up and progress is slow would be an additional stimulus to enable suppliers to meet changing market requirements.

 

With the increasing need to consider the carbon footprint of products, it is necessary to internalise the price of carbon into the cost base of manufactured goods. The timber trade would welcome this as the production of wood is largely a carbon-neutral process. Therefore there would be no cost implications. Intensive carbon using processes will be at a price disadvantage thereby incentivising environmentally friendly purchasing.

 

9.0 Government progress on tackling illegal timber since the EAC 2006 Report on sustainable timber

The UK is the 4th largest net importer in the world. Our influence on the world's forests is, and has the potential to be quite powerful. The UK Government's timber procurement policy was therefore a welcome introduction. The policy has proven to be a significant incentive for producers even though implementation of the policy has been slow.

 

The Government, post 2009 have changed their policy to restrict timber purchases to those from either sustainable or FLEGT licensed sources. The recently published timber guidance note does offer some opportunity to provide other evidence of legality and/or sustainability. However, the Construction report conducted by CPET suggests that the guidance note is not widely read or circulated. Therefore the perception is that exclusion of all other evidence of legality is now likely to act as a disincentive for producers who are trying to do the right thing. Not every country is eligible for FLEGT e.g. US, similarly not every country sees the VPA process as politically popular e.g. Brazil. Even the EU themselves have indicated that other forms of evidence should be allowed as well as FLEGT licensed timber.

 

The UK Government's commitment to FLEGT, and the resources dedicated to maintaining CPET are to be commended. Where necessary the TTF has supported both Defra and Dfid during VPA negotiations and given advice on the practical implementation of legislation.

 

10.0 Government sustainable procurement of forest products

 

A report conducted by CPET concluded that implementation of the policy was patchy within the government construction sector, the largest user of timber. Clearly communication is a major task and timber is not a major priority, particularly on construction sites. However anecdotal evidence from the trade has shown that demand for legal and sustainable timber is increasing.

 

The TTF have supported Defra in their efforts to increase awareness and also to encourage adoption of the policy by Local Authorities. Although not mandated by the central government policy, Local Authorities account for a significant percentage of total timber procurement in the UK. A recent Ends Report (respected environmental journal) investigation revealed that 6 out of 10 local authorities do not even have a policy, let alone operational procedures to check that the timber purchased is legal and/or sustainable.

 

11.0 The success or otherwise of the EU Forest Law Enforcement, Governance and Trade (FLEGT) Action plan, and Government support for it

 

FLEGT is an important mechanism to address several issues, illegal logging, deforestation and poor governance/development agendas. The UK Government has demonstrated strong support for the programme. As the action plan is aimed at both producers and consumers, progress is steadily increasing as each side implement changes. However FLEGT licensed timber, as predicted, is not available. Politically the process is perhaps making progress; we now need to see on the ground successes.

 

October 2008