Memorandum submitted by the World Wildlife
Fund
SUMMARY
The expansion of the global carbon markets
through linking domestic cap and trade schemes could play a positive
role in global mitigation efforts. However, it is very important
that certain criteria are met before any schemes are linked.
Baseline and credit "offset"
mechanisms such as the CDM are at best a zero sum game for the
climate. The current project-based mechanism suffers from several
structural problems and substantive reform and potentially widespread
replacement with a credible sectoral based mechanism is needed
post-2012.
Carbon markets are not a panacea for
tackling climate change. Other policies and measures are certainly
required both to deliver decarbonisation within developed countries,
and to deliver financial flows to help developing countries move
on to a low-carbon pathway. In Europe the impact of the recession
on the EU ETS makes it even more crucial that additional policies
and measures are rapidly put in place to buttress the carbon price
and drive low-carbon investment.
With specific regard to the power sector
in the UK and Europe, WWF is advocating the adoption of a plant-based
greenhouse gas emissions performance standard to prevent lock-in
to a new generation of unabated coal-fired power plants.
The revenues from auctioning pollution
allowances should be used to fund climate protection measures
domestically, and also crucially within developing countries.
The UK should also consider additional innovative ways of financing
climate change mitigation and adaptation in developing countries.
1. Potential contribution of international
emissions trading to delivering a global greenhouse gas stabilisation
target, consistent with the UK's goal of limiting global warming
to 2°C
Based on the latest science WWF believes that
global emissions must be cut by at least 80% below 1990 levels
by 2050. By 2020 the IPCC suggests that developed country
targets should be in the range of 25-40% cuts below 1990 with
developing countries deviating from business as usual emissions
by 15-30%. WWF notes that even with these cuts we will only have
a 50% chance of keeping below the 2°C tipping point
This leads WWF to conclude that:
Cap and trade schemes will alone not
be able to deliver the radical global decarbonisation needed.
Serious targeted policies and conscious decisions on infrastructure
will be needed to drive this, particularly in the strategically
important power sector.
Baseline and credit "offsetting"
schemes for international emissions trading will merely help developed
countries meet their 25-40% targets. Additional financial mechanisms
are needed to assist developing countries in meeting a 15-30%
deviation from business as usual emissions. If these mechanisms
are not put in place then there is clear risk that emission reductions
will be double counted.
The expansion of the global carbon markets through
linking domestic cap and trade schemes in industrialised countries
could play a positive role in global mitigation efforts. However,
it is very important that certain conditions are met before any
schemes are synchronized. The carbon markets are only one tool
to reduce emissions and must not be considered the universal silver
bullet. Other policies and measures, including setting standards,
and implementing phase-outs are also important to achieve the
aim of sustainable, low-carbon economies. Policies and measures
at the national level, enhanced where possible through bior
multi-lateral cooperation, are vital for many sectors, to phase
out inefficient technologies and to incentivise efficient ones.
Carbon markets are efficient in finding lowest
cost carbon credits. However, they may not be effective in driving
the development and deployment of technologies that will be necessary
to achieve a rapid decarbonisation of the economy.
In addition, many developing countries are looking
to enhance their existing mitigation actions under the Copenhagen
post-2012 climate change deal. It is essential that no-regrets
and low-cost mitigation options in developing countriesthe
"low hanging fruit"are not cornered by CDM project
developers and used to count towards developed country targets.
In WWF's view all credits generated under the
CDM, or any comparable mechanism post-2012 must be Gold Standard
equivalent certified.[5]
There are currently several worrying structural problems with
the current project-based CDM, and substantive reform and potentially
widespread replacement with a credible sectoral based mechanism
is needed.
2. Whether, and under what circumstances,
emissions trading ought to be supplemented or replaced by tax
or regulation
There is currently a lively debate underway,
particularly in the US, about whether a carbon tax of cap and
trade mechanisms are the best options at hand to tackle climate
change. We consider that neither mechanism will be sufficient
on its own. Indeed both are subject to being undermined by a lack
of political will and special interest lobbying which will weaken
their implementation.
Whilst a well-designed and ambitious cap and
trade scheme can offer several advantages it is in no way a substitute
for regulation, incentives and policies to develop and deploy
low-carbon technologies. For example there is a clear need for
focussed policies on energy efficiency, the deployment of renewables
and an emissions performance standard for power plants. These
are essential in order to overcome barriers which an uncertain
and variable carbon price will not achieve.
3. The extent to which the carbon price will
be sufficient to drive low-carbon investment, in particular decarbonisation
of energy
In 2006 the Stern review warned that during
their development carbon markets would need to be complemented
by other policies, such as tax and regulation, and also by targeted
action to promote the rapid deployment of emerging low-carbon
technologies. The Review noted that "Carbon pricing alone
will not be sufficient to reduce emissions on the scale and pace
required."[6]
"In this transitional period, while the credibility of
policy is still being established and the international framework
is taking shape, it is critical that governments consider how
to avoid the risks of locking into a high-carbon infrastructure,
including considering whether any additional measures may be justified
to reduce the risks."[7]
With specific regards to Europe and the EU ETS
WWF recognise that the scheme should be a key element of EU climate
change policy, but we consider it reckless to regard it as the
only tool to drive forward decarbonisation of the sectors covered
by the schemeparticularly the power sector. Indeed, the
UK Government already accepts the need for targeted policies to
support renewable electricity, as does the EU through its support
for ambitious renewable energy targets for 2020.
Former Energy Minister Malcolm Wicks also conceded
that the EU ETS is only part of the answer: "I agree with
Nick Stern's analysis
I certainly concede that, as
far as we can tell at the moment and for the foreseeable future,
it is not the whole answer, just part of it[8]
.I
have always been happy to concede that, in the foreseeable future
the ETS is unlikely to be the whole answer as it will depend on
the price of carbon."[9]
The recent report from the UK's Committee on
Climate Change also noted that "Any feasible path to a
80% reduction by 2050 will require the almost total decarbonisation
of electricity generation by 2030" "There is
a strong case for buttressing the carbon price lever by establishing
a clear and publicly stated expectation that coal-fired power
stations will not be able to generate unabated beyond the early
2020s".[10]
The Committee's report made clear that decarbonising the power
sector is critically important for several reasonsit is
the biggest polluter, a range of low or zero carbon technological
options exist, and a low-carbon power sector is a route to decarbonise
other sectors such as transport and heating through electrification.
However, it also clearly concluded that the ETS alone will not
deliver this strategically important outcome.
Finally, an article by ENDS Europe regarding
a new report by Deutsche Bank stated "Outlining the report
in a conference call on 24 February, lead author Mark Fulton
stressed the important role currently being played by command-and-control
regulation and legal mandates rather than carbon markets 'Day
to day what's driving investable markets is regulations' he said.
Mr Fulton described legal mandates for renewable energy as 'very
important'".[11]
All these comments are particularly relevant
given the current proposals to build between 60 and 70 new
coal fired power stations across the EU, with six or more of these
proposed for the UK.[12]
To support the EU ETS and the carbon price as it develops WWF
is calling for the immediate introduction of an individual plant
based emissions performance standard (EPS) on all new EU power
plants at a level of 350g CO2/kWh (and all existing plants by
2020-25). We consider this will be necessary to prevent high-carbon
lock-in. An EPS is already in force in California, and other U.S
states are following suitmoreover, a recent proposal in
the US by an impressive coalition of business and environment
groups proposed a three-legged policy of cap and trade, emissions
performance standards and demonstration programmes to bring forward
emerging technologies, particularly carbon capture and storage.[13]
The introduction of an EPS for new power plants was supported
by the European Parliament in its vote on the EU climate and energy
package in October, and the policy is also backed by the UK Conservative
and Liberal Democrat parties.
WWF also notes with interest the recently-announced
Government target to reduce CO2 emissions from aircraft to
below 2005 levels by 2050. Correspondence with the Department
for Transport has indicated that this will be a gross target relating
to the sector's actual emissions, ie carbon credits or offsets
will not count towards it (if this were not the case, the target
would be effectively meaningless, since under the terms of the
EU ETS aviation is capped at this level anyway). This is a further
(and welcome) acknowledgement from Government that emissions trading
should be supported by other policies. We only regret that the
target was established at the same time as permission was granted
for construction of a third runway at Heathrowa perfect
example of the long-lived, high-carbon infrastructure that the
EU ETS is currently failing to prevent and for which supporting
policies are necessary. To grant permission for the runway without
first assessing its impact on meeting the target is surely to
conduct policy backwards.
THE EU EMISSIONS
TRADING SCHEME
4. The record of phase II of the EU ETS, and
prospects for the success of phase III
Phase II (2008 to 20120)
Whilst some reports indicate that in 2008 phase
II of the EU ETS was starting to influence operational decisions,
specifically with regard to fuel switching from coal to gas in
the power sector during 2008,[14]
there is no indication that the scheme is as yet influencing longer-term
investment decisions.
Indeed between 2008 and 2012 we are
likely to see continued windfall profits accruing to the power
sector due to the free allocation of the majority of pollution
allowances[15]although
these may be reduced in the short term due to the indirect impact
of the recession on the carbon price.
The economic recession and it's knock on impact
on the carbon price, which has plummeted recently, is now raising
concerns that as with phase I (2005 to 2007), the carbon
price in phase II will be suppressed for a significant period
of time.
Phase III (2013 to 2020)
Some significant improvements have been made
to the third phase of the scheme such as the introduction of a
harmonized cap set at the EU level, harmonized allocation methods,
and full auctioning of allowances to the power sector in most
countries.[16]
However, major weaknesses still persist:
Whilst the excessive access to credits
from CDM projects in phase II of the scheme was recognised by
the European Commission when they announced their draft proposal
to amend the scheme in January 2008[17]the
final revised EU ETS Directive could still allow some 50% of the
emission reductions required by the scheme to take place outside
of the EU between 2008 and 2020.
Weak criteria for establishing the "carbon
leakage" threshold may mean that around 90% or more of the
manufacturing industries emissions could be defined to be at risk
from carbon leakage and as a result they may continue to get all
their allowances for free.
As a sop to the German power industry
the revised EU ETS also allows for the use of revenues from the
auctioning of allowances to support the construction of power
plantsincluding new coal build. Given the UK's commitments
to reduce greenhouse gas emissions under its Climate Change Act
and the recommendations of the Climate Change Committee's report
that the UK power sector needs to be almost completely decarbonised
by 2030we would urge the UK Government to give explicit
assurance that it will not use any revenues generated from the
auctioning of pollution allowances to support the construction
of new coal fired power plants. We would also urge the Government
to encourage other Member States not to make use of this optional
provision.
The suggestion that Member States should
spend at least 50% of revenues generated from auctioning pollution
allowances on adaptation measures is non-binding. The UK Government
has been one of the Member States who strongly opposes the idea
of ring-fencing or hypothecation in this way*.[18]
*Despite its opposition to the ring-fencing
of auctioning revenues it is worth noting that the UK Government
is supportive of allowing the revenues raised from the auctioning
of 300 million allowances from the New Entrants Reserve to
be used to fund carbon capture and storage demonstration projects
within the EU.[19]
Surely this could be considered a form of hypothecation.
There are also several implementation measures
which still need to be addressed such as the establishment of
benchmarks for the industrial sectors (although these will be
largely be dealt with through the Comitology procedure). In addition
once a global climate change deal has been signed the Commission
is obliged to come forward, within three months, with proposals
which include the adjustment from a 20% to a 30% EU emission reduction
target.
5. Impacts of economic recession on the workings
of the EU ETS
Since June 2008 the carbon price has fallen
from around 30 to around 11 today.[20]
This has been driven by the slow down in manufacturing within
the EU resulting in lower emissions and hence less demand for
pollution allowances, and has been exacerbated by the sell off
of unwanted carbon allowances by manufacturing industries. One
recent newspaper article notes "Up to 1 billion-worth
of carbon emissions permits are said to have been sold off in
recent months as industrial companies see an opportunity to bring
in funds at a time when their carbon output is expected to fall
due to lower production."[21]
The price of carbon is unlikely to drop to zero,
as is it nearly did during the first phase of the scheme, due
to provisions which allow unlimited banking of EUAs between phase
II and phase III. However, banking of this excess "hot air"
could significantly reduce the additional environmental effect
of the scheme. It will make 2020 emission targets easier
to hit and deflate the carbon pricefurther reducing the
scheme's influence over operational and more crucially longer-term
investment decisions. For example the scheme may have driven some
fuel switching from coal to gas in 2008 but the plummet in
the carbon price is likely to mean that fuel switching is not,
today, incentivised by the scheme.
There has also been a fall in the price of credits
in the CDM market (which is closely linked to the EUA price) with
CERs currently trading at around 8 having fallen from
over 20 in the Summer of 2008resulting in a
slowdown in investment in offset projects in developing countries.
The falling carbon price has led some carbon
market commentators such as Deutsche Bank to suggest that the
EU should intervene if low prices persist. Options proposed include
the establishment of a reserve-price mechanism for the EUAs that
are to be auctioned from 2013, and changing the ETS Directive
to allow for regular reviews of the annual cap reductions beyond
2020.[22]
Other options could include further restricting access to certified
emissions reductions (CERs), which inflate the cap, or stopping
access entirely; and immediately tightening the cap in line with
an EU economy wide 30% 2020 emission reduction target.
WWF considers that the impact of the recession
on the EU ETS makes it even more crucial that additional policies
and measures are rapidly put in place to buttress the carbon price
and drive low-carbon investment, particularly within the power
sector. Without these additional measures there is a clear risk
that power companies will continue to invest in long-lived unabated
coal plantslocking us in to decades of soaring emissions.
Similar measures may be necessary in other sectors which are planning
significant investment in potentially high-carbon infrastructure.
Please see our response to question 3 for further details.
6. Implications of the EU ETS for business
competitiveness, and how to address them
Please see relevant briefing sent with this
submission (please note that this assessment pre-dated the recent
tumble in the carbon price).
8. Allocation or auctioning of EU ETS credits,
and the use of auctioning revenues
For a comprehensive response to this question
please see our submission to the recent EAC inquiry into the Pre-budget
report in January 2009, enclosed. In short WWF believes that the
UK should commit to use a sum equivalent to the full revenues
from auctioning of allowances under the EU Emissions Trading Scheme
(ETS) for climate protection measures. In our view, half of this
sum should be used to aid the transition to a low-carbon economy
in the UK. Equally importantly, the other half should be set aside
to help meet the adaptation and mitigation needs of developing
countries (including stopping deforestation)this second
purpose will be critical to ensure a successful global climate
deal in Copenhagen this year. WWF notes that the Government is
opposed to hypothecation as a budgetary principle but this does
not prevent it from committing to spending the equivalent amount
accrued from the auctioning revenues.
Whilst the use of revenues from auctioning carbon
allowances may provide a significant contribution post 2012 (depending
on the carbon price) the UK must also consider other additional
measures to finance mitigation and adaptation in developing countries.
This is particularly important in light of the current economic
situation which will have an impact on the levels of revenues
raised from auctioning.
It is also perhaps worth noting that US President
Obama is planning to allocate a proportion of the revenues raised
from auctioning pollution allowances, in an economy wide cap and
trade scheme, on climate protection measures. The new federal
US budget blueprint stated that "Through a 100% auction
to ensure that the biggest polluters do not enjoy windfall profits,
this program will fund vital investments in a clean energy future
totalling $150 billion over 10 years, starting fiscal
year 2012,"[23]
DEVELOPMENT OF
A GLOBAL
CARBON MARKET
9. Progress of cap and trade schemes in other
countries (notably, the US), and the prospects for, and practicalities
of, linking between them
The EU ETS should only be linked to other credible
cap and trade systems. So as not to undermine the structure of
the EU ETS strict criteria must be set before linking to other
systems takes place. For example these criteria should include
(but are not limited to):
equivalent emission reduction trajectories
in the same sectors;
similar compliance failure penalties;
equal and fair access to pollution permits
across schemes, and comparable Monitoring Reporting and Verification
(MRV) structures.
10. The robustness and effectiveness of "offset"
schemes such as the CDM, and the issues around linking them to
cap and trade schemes
The current project based CDM has demonstrated
the limitations of market mechanisms for delivering sustainable
development, particularly in the absence of adequate quality criteria
such as those defined by the Gold Standard. For example India
sets rather ambitious criteria on paper but to date the government
has failed to reject a single project put forward for approval.
The mechanism has been blighted by poor quality, structural inefficiencies,
concerns over lack of additionality of many projects, and misguided
investments in sub-prime business-as-usual projects. This clearly
undermines financial assistance to developing countries in core
sectors such as sustainable power generation, and low-carbon industrial
production. To highlight just two of the growing number of studies
that have raised concerns over the lack of additionality in particular:
A report to WWF by the Öko-Institut
concluded that approximately 20% of credits generated by CDM projects
are likely not to be additional (equivalent of around 34 million
tonnes of CO2 per year).[24]
An assessment by International Rivers
found that the majority of hydropower projects in China applying
for CDM registration (370 projects comprising 11.7 GW
of power and 9.4% of total expected annual CDM credits worldwide)
were mostly non-additional.[25]
The current CDM (a baseline and credit scheme)
is at best then a zero sum game when used to offset emissions
from industries covered by a cap and trade scheme. At worst, when
credits from non-additional offset are used, the result is an
increase in overall global emissions.
Furthermore, continued reliance on offsetting,
even when these offsets come from credible projects, creates several
serious problems:
A recent "non-paper" by the
European Commission noted that high levels of access to JI/CDM
credits "will result in fewer incentives for innovation
and investments within EU Member States, creating a severe risk
that we will not be able to achieve the objectives of all three
pillars of our climate change and energy strategy, especially
improving energy security, driving innovation and domestic job
creation."
High levels of access to imported credits
risks greatly undermining any real policy drive for energy efficiency
or investment in renewables.
Conversely, offsets can be used to legitimise
investment in long-lived, high-carbon infrastructure (with new
coal-fired power stations being just one example).
In the UN negotiations, the EU is calling
for developed countries to reduce emissions by 25-40% below 1990 levels
by 2020. The latest climate science makes it clear that only the
top end of this range will give confidence that global warming
can be kept below 2°Cand that the substantial majority
of this reduction needs to be made domestically.
It is also clear, and confirmed by the
EU's presentations at the UN climate change negotiations in Poznan
in December 2008, that any offsetting by industrialised countries
to help meet the 25-40% range needs to come in addition to, and
not instead of, very significant "MRV" action to help
developing countries reduce emissions by 15-30% below business
as usual. As already statedoffsetting is, at best, a zero
sum game for the climate.
UK CARBON BUDGETS
11. The relationship between emissions credits
and the UK carbon budgets set up under the Climate Change Act
WWF notes that clauses 11 and 15 in
the Climate Change Act require the Government to "have regard"
to domestic action on climate change and to set a limit on the
use of carbon offsets to meet the carbon budgets. In WWF's opinion
clause 11 is the more important but it allows the Government
to set a limit at its choosing and to exempt any type of carbon
unit from this limit. The Government, therefore, could set a very
lax limit on carbon offsets and significantly limit the scope
of this restriction. The Government has until 1 June 2009 to
set this limit for the first carbon budget (2008-12)
12. Transparency of and justification for
counting the purchase of emissions credits (especially from "offset"
schemes) as decreasing emissions from the UK
The UK Government recently consulted on the
type of carbon units that can count towards the net UK carbon
account (which would be used to would monitor compliance with
the targets and budgets set under the Climate Change Act).[26]
Although this consultation focused on carbon accounting it gave
a clear indication of the Government's continuing intention to
rely excessively on the crutch of "offsetting" and the
EU ETS to deliver the carbon budgets. WWF is very concerned that
this excessive reliance on offsetting is undermining the clear
need, which is only reinforced by recent climate change science,
for rapid and radical decarbonisation of industrialised countries'
economies in addition to significant mitigation action
in the developing world.
WWF has consistently called for a very substantial
majority of the emission reductions under the Climate Change Act
to be made domestically, within the UK. In our view, the preferred
approach would be that the UK's actual emissions should be recorded
in the carbon account (with an appropriate provision to allow
flexibility around this figure by accounting for carbon trading).
This approach would require an effective strategy and policy framework
to guide decarbonisation across all sectors of the economy. In
contrast, the Government's accounting proposals appear in theory
to allow essentially unlimited potential for use of offset credits
across the economy as a whole.
With particular regard for the sectors covered
by the EU ETS the consultation document noted that "
whether
or not actual emissions by UK EU ETS operators exceed or fall
short of the cap, the final contribution from the EU ETS to the
net carbon account will be equal to the cap..". This
completely opaque "smoke and mirrors" accounting approach
somehow makes the real pollution from industrial sectorsaccounting
for half of the UK's CO2 emissionsdisappear into thin
air. WWF finds it completely unacceptable that the actual emissions
from the EU ETS sectors (including the power sector) will not
actually be recorded in the UK's carbon account and that these
sectors may therefore not be required to make any additional effort
to meet the carbon budgets. This is particularly alarming given
the clear recognition by the Committee on Climate Change and others
that the power sector must play a critical role in decarbonising
the UK economy.
It is particularly remarkable that the Government's
proposed approach to accounting for emissions under the Climate
Change Act is only valid for four more years. The consultation
fails to recognise that beyond 2012 there will no longer
be such a thing as a "UK cap" for the ETS sectors,[27]
making this method of accounting redundant.
March 2009
5 The Gold Standard is an independent, transparent,
internationally recognised benchmark for high-quality carbon offset
projects. It is restricted to renewable energy and end-use efficiency
projects, requires projects to follow a conservative interpretation
of the UNFCCC-additionality test and provides evidence by a UNFCCC-accredited
independent third party that they are making a real contribution
to sustainable development. See http://www.cdmgoldstandard.org/ Back
6
Stern Review, Part IV: Policy response for Mitigation, Chapter
16-Accelerating Technological Innovation, 30 October 2006. Back
7
Stern Review, Executive Summary, 30 October 2006 Back
8
M Wicks MP, former Energy Minister, Hansard, Energy Bill Committee,
26 February 2008, Col: 216 Back
9
M Wicks MP, former Energy Minister, Hansard, Energy Bill Committee,
26 February 2008, Col: 217 Back
10
"Building a low carbon economy-the UK's contribution to tackling
climate change" report from the Committee on Climate Change,
December 2008, http://hmccc.s3.amazonaws.com/pdf/TSO-ClimateChange.pdf Back
11
"Governments 'are embracing Green New Deal'" ENDS Europe,
24 February 2009. Article regarding a report by Deutsche
Bank "Global Climate Change Regulation Policy Developments:
July 2008-February 2009" February 2009 http://www.dbadvisors.com/deam/stat/globalResearch/climatechange_globalpolicydevelopments.pdf Back
12
At Kingsnorth, Longannet, Cockenzie, Tilbury, Filder's Ferry,
Ferrybridge and Blyth, and most recently Hunterston Back
13
"USCAP Blueprint for Legislative Action" USCAP, 15 January
2009, http://www.us-cap.org/blueprint/overview.asp Back
14
"Emissions from the EU ETS down 3% in 2008" Press
release from New Carbon Finance, 16 February 2009. This analysis
suggests that the largest cause of the reduction, taking into
account reduced economic output due to the recession, is the EU
ETS itself encouraging greater use of gas in power generation.
http://www.newcarbonfinance.com/download.php?n=20090216_PR_2008Emissions.pdf&f=fileName&t=NCF_downloads Back
15
In the UK alone a recent report by Point Carbon estimated that
the UK power sector could reap up to 15 billion during
phase II of the EU ETS (2008 to 2012). "EU ETS phase
II-the potential and scale of windfall profits in the power sector"
2008, Point Carbon, http://assets.panda.org/downloads/point_carbon_wwf_windfall_profits_mar08_final_report_1.pdf Back
16
Derogations are foreseen for the power sector in some CEE countries
who may receive 70% of their permits for free in 2013, falling
to 0% by 2020. Back
17
http://ec.europa.eu/environment/climat/emission/pdf/com_2008_16_en.pdf
(page 10)-Proposal for a Directive amending Directive 2003/87/EC
so as to improve and extend the greenhouse gas emissions allowance
trading system of the Community Back
18
"Revision of the Emissions Trading Directive-briefing for
UK MEPs" UK Government briefing, October 2008 Back
19
"Revision of the Emissions Trading Directive-briefing for
UK MEPs" UK Government briefing, October 2008 Back
20
www.pointcarbon.com accessed on 3 March 2009. Back
21
"Britain's big polluters accused of abusing EU's carbon trading
scheme" Terry Macalister, Guardian, 27 January 2009 Back
22
"ETS needs support if price weakness continues: Deutsche
Bank" Point Carbon, 23 February 2009. Back
23
"Obama budget sees allowances at $13.7/t" Point Carbon,
26 February 2009. Back
24
Schneider L. 2007. "Is the CDM fulfilling its environmental
objectives? An evaluation of the CDM and options for improvement"-a
report prepared by the Öko-Institut for WWF Back
25
Haya B. 2007. Letter to the members of the CDM Executive Board,
RE: Concerns about the large number of Chinese hydropower projects
currently undergoing CDM validation, 12 October 2007 (www.internationalrivers.org/en/china/china-other-projects/lettercdm-executive-board-non-additional-chinese-hydros) Back
26
http://www.defra.gov.uk/corporate/consult/carbon-accounting/consult-doc.pdf
-WWF's response to this consultation is enclosed with this submission
to the EAC inquiry. Back
27
Note by witness: Beyond 2012 the cap on EU ETS sector
emissions will be set at the EU level. Back
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