EDF Talks Global Climate

CDM design flaws can taint CORSIA, but supply from small developing countries could provide real emissions reductions

Aruba’s Vader Piet Wind Park

Aruba’s Vader Piet Wind Park. Credit: Miles Grant

By Kristin Qui, Environmental Defense Fund Tom Graff Fellow, International Carbon Markets

Last month, the 36 countries that make up the Council of the UN’s International Civil Aviation Organization (ICAO) adopted the set of rules that will guide the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). Known as the Standards and Recommended Practices (SARPs), these rules constitute a significant step to get CORSIA up and running, and contribute to ICAO’s goal of capping net emissions from international aviation at 2020 levels.

However, much work remains to be done at ICAO between now and the end of 2018. The Council has not yet adopted some key elements, including details on CORSIA eligible emissions units, sustainable aviation fuels and criteria for both. Furthermore, the Council has yet to establish the Technical Advisory Body (TAB) that will make recommendations to the Council on which emissions units airlines can use. A transparent TAB, with broad stakeholder participation, is necessary to provide recommendations on high-quality units that represent real emissions reductions in CORSIA.

One mechanism under consideration to satisfy CORSIA demand for emissions units is the Clean Development Mechanism (CDM) established by the Kyoto Protocol 20 years ago. The purpose of the CDM, as specified by Article 12 of the Kyoto Protocol, is to assist rich countries in complying with their Kyoto emission reduction commitments by using emissions reductions credits from projects in developing countries, and to help the latter achieve sustainable development and contribute to the ultimate objective of the Convention, i.e., averting dangerous interference with the climate system. However, the CDM has run into a number of obstacles. In fact, several studies, including a new EDF analysis, finds that in many cases, the CDM’s methodologies and design don’t address additionality, don’t provide real and credible baselines and don’t avoid double counting. Below are some of the biggest issues with the CDM:

  1. Lack of additionality: Some CDM projects have been found to be non-additional, meaning that those projects would have happened in the absence of the CDM and its finance from the sale of CERs. Thus, under the CDM’s current design, countries can earn credits from projects for which they did not require CDM financing. This is quite alarming in a landscape where many smaller developing countries have trouble accessing the necessary climate finance to cope with the harsh impacts of climate change.
  2. Crowding out small countries: The majority of CDM projects originate in large developing countries, e.g. 85% of issued Certified Emissions Reductions (CERs) occurs in China, India and Brazil, effectively crowding out smaller countries in need of finance for low carbon development. Even further, EDF’s analysis shows that one large developing country has a potential supply of about 10 times the demand of CORSIA, when projecting the maximum potential CDM supply out to 2030.
  3. Accounting issues: Other projects like HFC-23 destruction projects have been flagged for baseline inflation, meaning that project proponents overstated the number of reductions resulting from a given project. The atmosphere therefore sees less emissions reductions than the CDM project promises, setting back mitigation progress. Using such credits to offset an increase in emissions under CORSIA means that airlines would not be meeting their goals of carbon neutral growth from 2020.
  4. Lack of Transparency: Lack of transparency in the CDM Executive Board decision-making, communication and publishing of CDM data makes it challenging to understand the CDM project cycle. Shockingly, there is no way to tell when CERs have been used by an entity to offset an emissions increase.
  5. Lack of legal basis for using CERs in CORSIA: The future of the CDM is legally uncertain. The Kyoto Protocol establishes the CDM only for the twin purposes of helping non-Annex I Parties (developing countries) with sustainable development and Annex I Parties (developed countries) to meet their Kyoto emissions reduction commitments. The Protocol does not establish the use of CDM CERs for CORSIA or the Paris Agreement. Thus, the CDM Executive board has no legal authority to issue CERs after 2020, and may not have authority to issue CERs now. To use CERs in CORSIA, ICAO and the Conference of the Parties serving as the meeting of the Parties to the Kyoto Protocol must take the necessary legal decisions.
  6. Fraud: Recent analyses have demonstrated that a significant number of CERs may be fraudulent. In particular, large dams in Brazil were registered as CDM projects based on assertions that the projects depended on carbon finance for their future construction and operation. However, investors have successfully prosecuted lawsuits demonstrating that their funds disappeared in the Lava Jato corruption scandal, and the dams were built anyway. Airlines face big reputational risks if the units they use to meet CORSIA requirements are fraudulent in any way.

Some CDM projects could deliver environmental benefits

A recent analysis by EDF shows that CDM activities in small island developing states (SIDS), least developed countries (LDCs) and other African countries are more vulnerable to discontinuation without support from market mechanisms, meaning that such activities are more likely to be additional. Because of these reasons, and to improve access to market mechanisms for smaller developing countries that were effectively denied access by larger countries, rules for post-2020 use of CERs should focus on a particular subset of CDM activities. EDF’s analysis concludes that the highest likelihood of delivering environmental benefits from CDM activities, would arise from limiting use of CERs to those originating from activities in SIDS and LDCs, provided that they satisfy quality and accounting standards, including the need to avoid double counting.

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States Should Welcome REDD+ into International Aviation Carbon Offset Program

Sectoral scale REDD+ programs meet or exceed proposed CORSIA offset


Source: pixabay.com

Two important climate change initiatives are advancing and their future success looks more and more intertwined. The Carbon Offset Reduction Scheme for International Aviation (CORSIA) of the UN’s International Civil Aviation Organization’s (ICAO) is approaching the end of a policy-making phase to finalize environmental criteria for offset programs – which will be necessary for airlines to meet the international aviation sector’s climate commitments. At the same time, many countries striving to conserve their tropical forests are looking for sources of funding for large-scale programs for Reducing Emissions from Deforestation and Degradation (REDD+).

ICAO recently hosted a seminar in Montreal on carbon markets. The seminar occurred as ICAO Member States are considering draft Standards and Recommended Practices (SARPs) for implementing CORSIA, including environmental integrity criteria for offset programs and emissions credits. With some countries having submitted their observations on the proposals this week, and more slated to do so by April 20th following a series of regional seminars on CORSIA, the 36-member ICAO Council aims to finalize and adopt the SARPs this June. ICAO’s CORSIA Resolution directs the Council to establish, with the technical contribution of ICAO’s Committee on Aviation Environmental Protection (CAEP), a standing technical advisory body to make recommendations to the Council on the eligible emissions units for use by the CORSIA. While the Council is establishing this body, proponents of different programs like the Clean Development Mechanism (CDM) and REDD+ will be informing decision makers about their ability to supply high-integrity offsets.

Why REDD+ is a great solution for CORSIA

REDD+ is the only sectoral set of policy approaches to be featured in the Paris Agreement, which will govern global climate action starting in 2021. REDD+ received special recognition by the world’s climate policy makers, for two reasons. First, dramatic reductions in emissions from deforestation can play a key role in the battle to avert dangerous climate shifts. Second, the world’s nations have set out a multilaterally agreed framework for measuring these reductions, ensuring that forest protection proceeds with environmental/biological and social safeguards, providing basic guidance for market-based transfers of these reductions, and ensuring environmental integrity through accounting and transparency. The UNFCCC’s 2013 Warsaw Framework for REDD+ and related UNFCCC Decisions set a precedent for these programs to proceed at jurisdictional or national rather than simply project scale in order to develop and enforce policies to address deforestation at a large scale, prevent leakage of deforestation, and avoid double claiming of emissions reductions.

Parallel to the development of the Warsaw Framework for REDD+, the World Bank, nine donor governments and TNC created the Forest Carbon Partnership Facility (FCPF) to help tropical forest countries prepare plans to reduce deforestation nationwide, and to pilot results-based payments for those reductions. These countries are succeeding in reducing emissions from deforestation – and payments for their results could be issued by the end of 2018.

The guidance provided by Warsaw Framework for REDD+ and the upcoming results of the FCPF are two important reasons why REDD+ should be a source of offsets for CORSIA. As the FCPF is demonstrating, REDD+ that meets the UN’s multilaterally agreed Warsaw Framework is achieving real results, and deserves to be a source of offsets for CORSIA.

A recent analysis of REDD+ by Climate Advisers demonstrates how REDD+ programs implemented under the Warsaw Framework meet CORSIA’s draft Emissions Unit Eligibility Criteria. Another just released study by Climate Advisers discusses why REDD+ is a good option for airlines needing to meet their CORSIA obligations.

What are other potential offset suppliers for CORSIA?

During an ICAO seminar held in February in Montreal, potential offset suppliers gave short presentations of their programs to an audience of about 200 people. Reviewing the workshop program, one can’t help but notice a big focus on the CDM. The CDM’s existence is not guaranteed in the new post-2020 climate regime for many reasons. But one prominent factor is the risk that if the CDM actually did achieve real reductions, those reductions could be claimed both by the host country in the context of the Paris Agreement, and by an airline in CORSIA. That would negate the climate benefit of CORSIA. Flawed CDM credits should not be allowed to crowd quality REDD+ credits out in CORSIA.

But can REDD+ actually supply CORSIA? EDF researched this question and found that the answer is yes – even when doing proper accounting to ensure no double counting. Another interesting finding is that if REDD+ is used, many emerging markets could see net economic benefits. See, for examples, analyses by Climate Advisers of net benefits for Colombia, Ethiopia, Indonesia, and Peru.

Making a match of REDD+ and CORSIA

Evaluating CORSIA’s draft Emissions Units Criteria, REDD+– under the Warsaw Framework for REDD+ or the FCPF– meets or exceeds them. Sourcing offsets from REDD+ offers more than just environmental benefits. In addition to generating significant potential supply of emissions reductions, REDD+ activities can also generate significant economic and social co-benefits, in addition to offering higher regulatory certainty than other mechanisms. CORSIA policy makers would be well advised to acquaint themselves with REDD+ – the only sectoral program for the new Paris climate regime agreed upon by 193 countries.

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Carbon Credit Shell Game: the Clean Development Mechanism in New Climate Accords

Belo Monte Dam under construction on the Xingu River in the state of Pará, Brazil in 2013 | Photo credit: Letícia Leite-ISA

In the middle of terrifying weather headlines – mega-forest fires in California, serial super-hurricanes slamming the Caribbean, heat waves in the Arctic – it’s more important than ever to achieve large-scale reductions in carbon pollution, fast.

Two new international accords are starting to move industry and governments in the right direction – the UN Paris Agreement, and the International Civil Aviation Organization’s (ICAO) Carbon Offsetting and Reduction System (CORSIA), which this week launches a series of regional seminars to inform aviation stakeholders about the system’s implementation procedures. President Trump’s refusal to face the climate challenge has really only mobilized everybody else to move ahead.

But other dangers lurk. A shadowy lobby is pushing hard to revive the Clean Development Mechanism (CDM) – a relic of an outdated, failed attempt at climate action.

Contrived under the Kyoto Protocol, the CDM was supposed to let industrialized countries buy carbon credits from emissions-reductions projects in developing countries. These credits were supposed to represent real, verifiable emissions reductions that wouldn’t have happened without the CDM projects. The last part part—“additionality” — is key. Otherwise, developed-world power companies and cement factories just pollute more without actually making any real emissions reductions anywhere.

Twenty-one years and almost 3 billion tons CO₂e of purported “offsets” later, we know it didn’t work. Fully 85% of CDM projects are “unlikely to be additional,” says the most comprehensive, up-to-date study of the CDM. (It’s only “unlikely” because it’s typically very hard to tell what would have happened if the projects didn’t get done). The corruption has become systemic, especially in the biggest CDM countries – China, India and Brazil – where 90% of the credits come from. A US State Department analysis of wind power projects in India that could generate as much as 500 million tons of CO₂e credits found that project developers routinely keep double books. They do one term sheet showing the project is viable to get financing, and another term sheet for the CDM, showing that the project is inviable without CDM credit, i.e., is “additional”. A project that needed carbon credit to work would be far too risky for a bank to finance, investors said.

Brazil is a major offender. Its biggest CDM player, state power company Eletrobrás, told the CDM Executive Board that its Amazon mega-hydroelectric dams needed CDM credit to attract investors. At the same time, it told investors that the dams were fully viable on their own. We know this in part because the same dams (all registered, validated, and generating CDM carbon credit) are under investigation in the gigantic, Brazil-wide corruption investigations nicknamed “Lava Jato” (Car Wash). They are also prime exhibits in a lawsuit for fraud in US federal court brought by investors in Eletrobrás stock. The dams are, of course, socio-environmental nightmares too.

In short, there are excellent reasons why the EU Emissions Trading System no longer accepts CDM from Brazil, China and India, as well as whole categories of projects, and why California’s carbon market categorically rejects international credits from anything resembling the CDM. This in turn is part of the reason that CDM credits have effectively zero value in the market. They will go on having zero market value unless the CDM lobby (led by Brazil) in the Paris Agreement and CORSIA succeeds in foisting them onto the new markets.

If they get away with it, both the new, promising agreements to lower atmospheric carbon will be irrevocably tainted.

Environmentalists and government negotiators should keep fake CDM carbon credits from high-emissions emerging economies out of Paris and CORSIA, at risk of increasing rather than decreasing GHG pollution. There are much better – real – ways to control emissions, which I’ll be addressing in a future post.

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ICAO’s market-based measure could cover 80% of aviation emissions growth in mandatory phase

icao-logo The International Civil Aviation Organization (ICAO), the UN agency charged with setting standards for international flights, has set a goal of “carbon neutral growth from 2020” – i.e. capping net emissions at year-2020 levels. The ICAO Assembly today adopted a global market-based measure that lets airlines purchase high-quality emission reductions to offset the carbon growth above the cap.

Analysis of high-quality data on aviation emissions projections demonstrates the ICAO market-based measure is a critical step forward for climate action, and could prevent nearly 2.5 billion tonnes of CO2 emissions into the atmosphere over the first 15 years of the program. Here’s how.

The market-based measure provides that:

  • from 2021-2023, nations would opt in to a voluntary pilot phase;
  • from 2024-2026, nations would opt in voluntarily to another phase;
  • from 2027-2035, all nations would be required to participate, with some exceptions;
  • least developed countries, land-locked developing countries, and small island developing countries would all be exempt throughout (although these states could opt in at any time if they so choose).

What this means for ICAO’s commitment to “carbon neutral growth from 2020” depends on how many more countries decide voluntarily to opt in.

EDF has developed an interactive tool to allow users to estimate how many emissions would be covered of the billion-tonne gap between projected emissions and the 2020 cap, if various countries opt in to the MBM.

The tool provides unique calculations of the aviation sector’s emissions growth based on projections from ICAO, industry and analysts. The focus on emissions provides a direct estimate of the aviation sector’s contribution to climate change that complements analyses based on aviation’s traffic growth, measured in revenue tonne kilometers (RTKs).

Here’s the snapshot of the tool as of the adoption of the market-based measure on October 6. With Qatar and Burkina Faso becoming the 64th and 65th countries to signal their intent to participate in the MBM from the start, 65% of emissions growth above 2020 would be covered in Pilot + Phase 1, and nearly 80% (79%) of these emissions would be covered during Phase 2 of the program (2027-2035). Importantly, 77% of anticipated emissions growth above 2020 would be covered over the first fifteen years of the program.


The tool shows the importance of commitments to early participation by the Asia-Pacific aviation powerhouse states of Singapore, Japan, Korea, and Australia; the Middle Eastern aviation dynamos of United Arab Emirates and Qatar; Latin American states like Mexico, Costa Rica, Guatemala; and leading African states such as Kenya.

It also shows that as exempted states increase in their importance as aviation powers, participation by at least some of them will be significant for boosting overall coverage toward the goal of carbon-neutral growth from 2020. Consequently, it will be important for today’s leading aviation countries to help build MBM capacity in the anticipated aviation leaders of tomorrow.

A number of countries that are exempt under the resolution's formulas, including leading voices from the front lines of climate impacts – Burkina Faso, Marshall Islands, Papua New Guinea, Costa Rica, Guatemala, and Kenya – have announced their intent to participate, and more are expected to join.

After nearly two decades of effort, ICAO is providing global leadership, with both developed and developing countries taking the lead. Hand in hand with this week’s announcement about ratification of the Paris Agreement, that’s good news indeed.

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Why aviation’s carbon must be capped, and how to do it

Airplanes on a flooded runway at Don Muang International Airport on Nov 19, 2011 in Bangkok, Thailand. Image: 1000 Words / Shutterstock.com

Government negotiators met in Montreal last week to seek agreement on a global cap on carbon pollution from international aviation. Bilateral negotiations are continuing, and text of a draft resolution is expected to be considered at the triennial meeting of the UN’s International Civil Aviation Organization (ICAO) in early October.

In anticipation of these meetings, Carbon & Climate Law Review (CCLR), a broadly-read journal catering to climate insiders, just released a special issue on international aviation. Experts illustrate the need for and feasibility of a strong market-based measure. Here are some highlights from the special issue:

Aviation’s impact on climate is understated

Aviation’s total global warming impacts are more than double those estimated from its carbon dioxide (CO2) emissions, or equivalent to roughly 5% of total radiative forcing from CO2. Nitrogen oxide emissions and aviation’s impacts on clouds add significantly to the warming effect of carbon dioxide. Without new policies, aviation emissions could compromise the goal of the 2015 Paris Agreement to limit the increase in global temperatures to 1.5 – 2 degrees Celsius above pre-industrial levels.

Climate change increases risks to aviation safety, infrastructure, and operations

Aviation pollution causes harm to the climate, but a warming climate also creates challenges for aviation safety and operations.

According to industry experts, in high temperatures, planes can’t carry as much. Airports risk damage to runways from storm surge and rising sea levels. Passengers and crew may be exposed to more turbulence. New electronics, sensing, and communication technology may be needed to reduce the risk of exposure to severe weather.

The solution: a market-based measure

To contain aviation’s impacts on climate change, experts from industry, policy, and law call for a market-based measure to cap emissions from international flights.

A market-based measure can be established and enforced under existing law

Legal experts recommend that an MBM can be established as a set of “standard” under the existing Chicago Convention, the foundational treaty for international aviation. Compliance with existing standards is good but not perfect. The experts show how market entry conditions, domestic transportation statutes, and conditions imposed by aviation financial services and trade associations can be used to bolster compliance.

A market-based measure should provide broad coverage and deliver co-benefits

Expert contributors to the issue recommend that the coverage of the MBM be broad. They caution that exemptions from a market-based measure could distort the market and disproportionately benefit the wealthiest individuals in those countries.

Other contributors show that policies to reduce emissions from deforestation and forest degradation (REDD+) can help meet international aviation’s demand for emissions offsets, even after taking into account existing commitments and demand for offsets. Further, a “keep what you save” policy that allows air carriers to use their own fuel use reductions to reduce offsetting obligations could help resolve current debates over allocating offsetting obligations between air carriers.

This fall’s ICAO General Assembly is a critical moment for countries, and the aviation industry, to demonstrate leadership in providing safe international air travel while minimizing risks to the climate.

If countries don’t agree to the market-based measure in October, the world may have to wait until ICAO’s next General Assembly in 2019. With rapid growth of aviation pollution, that’s a delayed take-off that none of us can afford.

Click “read more” to see key takeaways from each article of the special issue of CCLR. The journal’s publisher, Lexxion, has made the special issue free to access through October 7, 2016.

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Can airlines help reduce deforestation?


The global airline industry could become an ally in combating deforestation, as countries are set to vote at the September 2016 meeting of the International Civil Aviation Organization (ICAO) on whether airlines can use REDD+ credits to offset their emissions. Image Source: Flickr, Marinelson Almeida

A window of opportunity may be opening to secure sustainable financing – from an unusual source – to support national, state, and provincial-level efforts to Reduce Emissions from Deforestation and forest Degradation (REDD+).

The global airline industry is seeking international agreement on a program to cap the carbon dioxide emissions of flights between countries, and let airlines use a Market-Based Measure (MBM) to offset emissions above the cap. When the 191 governments that comprise the UN’s International Civil Aviation Organization (ICAO) vote on the MBM at the end of September, that may decide whether airlines can use REDD+ to offset their emissions above 2020 levels.

Why does ICAO need REDD+?

In 2013, ICAO member states adopted a goal of “carbon neutral growth from 2020” – i.e., capping the net emissions of international flights at 2020 levels. International aviation’s emissions, however, are forecasted to rise dramatically, as tens of thousands of new large aircraft take to the skies in coming decades.

Even after international aviation makes improvements in operational and technological efficiency, the sector will still likely face an “emissions gap” of 7.8 billion tonnes (or 7.8 Gt CO2) over the period of 2020-2040. National and jurisdictional level REDD+ projects that meet the environmental and social safeguards agreed under the United Nations Framework Convention on Climate Change (UNFCCC) are anticipated to be able to supply offsets enabling aviation to cover a significant portion of the expected gap, even while ensuring that these reductions are not also claimed against national emission reduction commitments.


The international aviation sector will still likely face an “emissions gap” of 7.8 billion tonnes over the period of 2020-2040 between their goal of carbon-neutral growth from 2020 and their projected emissions – even after international aviation makes improvements in operational and technological efficiency. Image source: Flightpath 1.5

Getting the right REDD+ into ICAO: REDD+ programs that meet UNFCCC requirements

The December 2015 Paris Agreement on climate change, adopted by the 197 Parties to the UNFCCC, gave special recognition to the key role that REDD+ can play in mitigating climate change.

The Paris Agreement, the UNFCCC’s 2013 Warsaw Framework on REDD+, and related UNFCCC Decisions provide that REDD+ programs must be created at national, or – temporarily – subnational (e.g. state and province) level. This is important because national and subnational REDD+ programs (collectively known as jurisdictional REDD+ or “JREDD+” programs) can create and enforce policies to address deforestation at a large scale.

For example, without jurisdictional REDD+, there’s a risk that forest protection in one project area could displace deforestation to other areas; this is avoided when REDD+ projects are “nested” in a national or jurisdictional-level program. According to guidance by the UNFCCC, JREDD+ programs’ results must be recognized by national REDD+ Focal Points and submitted to the REDD Information hub in order to ensure that emissions reductions are not claimed more than once.

ICAO’s timeline

In March and April, ICAO convened a set of regional dialogues to give governments, industry, and civil society stakeholders the opportunity to discuss MBM design options and potential sources of offsets. ICAO will convene a high-level ministerial meeting May 11-13 at ICAO headquarters in Montreal, Canada, to review a draft text. Additional meetings will be held throughout the summer and the final, and most important ICAO Assembly, where the MBM will be finalized, is to be held in Montreal from 27 September to 7 October 2016.

Seizing the opportunity

REDD+ countries interested in sustainable financing for their national and jurisdictional REDD+ programs should be aware of the potential for a new ICAO market based mechanism to provide such financing. In order to seize this opportunity, REDD+ policy makers and aviation counterparts need to collaborate to ensure an ICAO market based mechanism inclusive of REDD+ and with environmental integrity.

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