Climate 411

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

By Guest Author / Published: July 12, 2018
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.

Also posted in Aviation, Carbon Markets, International / Comments are closed

Sowing the seeds of a roadmap for agriculture

By Breanna Lujan / Published: May 16, 2018
Photo credit Dr Huynh Quang Tin

Low carbon rice production in Vietnam. Dr Huynh Quang Tin

At last November’s COP23 in Germany, Parties involved in the United Nations Framework Convention on Climate Change (UNFCCC) negotiations on agriculture celebrated a notable victory after agreeing to create the Koronivia Joint Work on Agriculture (KJWA). The KJWA marks a shift in focus from agricultural adaptation activities only, to a broader discussion of mitigation related activities. While COP23 Parties did not decide on the details of the KJWA, such as the “how” and the “when,” the outcome generated much needed momentum for the agriculture agenda of the UNFCCC.

In the lead up to the Bonn climate change negotiations that concluded last week, Parties and observers submitted their views on the “what”, “how”, and “when” of the KJWA. The Parties kept a very constructive – and even friendly – discourse in negotiation sessions, building off of last year’s positive COP23 outcome and increasing focus on implementation. The developing country group known as the G&77 + China, building off a New Zealand-led proposal, was very active in coordinating the creation of a roadmap for the KJWA. By the end of the first week, Parties agreed to draft conclusions outlining the roadmap.

Now with the UN secretariat for adoption, this roadmap provides an agenda of activities that includes workshops, topic submissions, and workshop reports every six months between now and the end of 2020. The series of workshops will cover the following topics:

  • How to implement the outcomes from the five in-session workshops on adaptation and resiliency held before last year’s COP decision;
  • Methods and approaches for assessing adaptation, adaptation co-benefits, and resilience;
  • Improved soil carbon, soil health, and soil fertility under grassland and cropland as well as integrated systems, including water management;
  • Improved nutrient use and manure management towards sustainable and resilient agricultural systems;
  • Improved livestock management systems, including agropastoral production systems and others; and
  • Socioeconomic and food security dimensions of climate change in the agriculture sector.

Submissions on topics for each workshop will be solicited prior to each session, followed by the preparation of a report after each workshop.

The first activity on the roadmap—submissions on implementing the outcomes of the five in-session workshops on adaptation and resiliency—is due on October 22, 2018. Considering that Parties in Bonn solicited external inputs for current and future discussions, organizations like the Environmental Defense Fund have the opportunity to help advance the KJWA roadmap. By providing technical assistance, content, and process inputs, EDF and other organizations will support the work of Parties under the KJWA and maintain momentum. It is imperative to use this time to determine what issues to focus on during this series of workshops and how to operationalize the outcomes.

As reflected by the nature of the KJWA itself, shifting focus to implementation and tangible actions to help actors in the agriculture sector respond to climate change is essential if we are to meet the climate goals laid out in the Paris Agreement.

Also posted in Agriculture, International, United Nations / Comments are closed

Five things you need to know about the U.S. Clean Car Standards

By Alice Henderson / Published: April 30, 2018

Cars on a dealer lot, waiting to be sold. Photo: Every Car Listed

America’s Clean Car Standards are one of our biggest success stories, yet the Trump Administration is preparing to dramatically weaken them.

News reports say the Trump Administration is also taking aim at state leadership on clean cars, by preparing to challenge California’s and 12 other states’ authority to maintain more protective standards.

Here’s what you need to know:

Read More »

Also posted in Cars and Pollution, Clean Air Act, Economics, Greenhouse Gas Emissions, News, Pruitt / Comments are closed

Proof that the Clean Power Plan’s strategy for cutting carbon pollution is the industry standard

By Charlie Jiang / Published: April 26, 2018

The public comment period is just about to close on EPA Administrator Scott Pruitt’s reckless attempt to repeal the Clean Power Plan, and thousands of Americans — including mayors, CEOs, energy experts, and citizens concerned about the threats Pruitt’s actions pose to our children’s health and future — have already spoken out in vigorous opposition to the misguided repeal effort.

There is a lot at stake. The Clean Power Plan would prevent 4,500 early deaths and 90,000 childhood asthma attacks each year. It would cut carbon pollution by 32 percent from 2005 levels, and would substantially reduce other harmful air pollutants from power plants.

By slashing air pollution and helping mitigate the threats of climate change, the Clean Power Plan would secure significant benefits to public health while growing the clean energy economy.

Yet, as Pruitt continues his misguided effort to turn back the clock on lifesaving climate protections, momentum is growing in states and the power sector to slash carbon pollution and usher in a clean energy future.

States and companies are moving away from carbon-intensive sources of electricity generation, and are increasing their use of cleaner technologies — deploying the same cost-effective strategies to cut carbon pollution that EPA relied upon when establishing emission reduction targets under the Clean Power Plan. Pruitt’s attempt to repeal the Clean Power Plan is putting this flexible approach to ambitious and low-cost emission reductions under attack.

Read More »

Also posted in Clean Air Act, Clean Power Plan, Economics, Energy, EPA litgation, Greenhouse Gas Emissions, News, Pruitt / Comments are closed

It’s up to us to protect the Clean Power Plan

By Martha Roberts / Published: April 23, 2018

This week is a crucial moment for climate progress.

EPA Administrator Scott Pruitt is moving ahead in his efforts to revoke the Clean Power Plan, one of our most important efforts to tackle the climate crisis. The Clean Power Plan provides our only national limit on carbon pollution from existing power plants — America’s largest stationary source of carbon pollution.

EPA’s public comment period for Pruitt’s plan to repeal Clean Power Plan will close this Thursday.

Americans have only a short time left to raise their voice to oppose this reckless rollback. You can make your voice heard here.

Here’s what’s at stake

The Clean Power Plan helps us achieve approximately 32 percent reductions in carbon pollution from existing power plants compared to 2005, while also substantially reducing other harmful pollution from power plants.

EPA estimates that the Clean Power Plan would prevent an estimated 90,000 childhood asthma attacks and as many as 4,500 early deaths each year once fully implemented. These public health benefits would be imperiled if Pruitt succeeds in repealing this vital protection.

Public health experts, business voices and local leaders oppose revoking the Clean Power Plan

The American Lung Association joined with seventeen other public health organizations to denounce the Clean Power Plan rollback, calling it “inconsistent with EPA’s core mission of protecting public health and the environment” and highlighting that “the health impacts of climate change demand immediate action.”

Apple Inc. recently urged Pruitt not to repeal the Clean Power Plan, noting it “gives domestic companies a competitive edge” and that based on Apple’s extensive experience as a large energy consumer “the Clean Power Plan provides achievable targets with no adverse impact on [electricity] reliability or resiliency.”

244 mayors from 48 states and territories, representing 52 million Americans, sent a letter to Pruitt stating:

“[W]e strongly oppose the repeal of the Clean Power Plan, which would put our citizens at risk and undermine our efforts to prepare for and protect against the worst impacts of climate change.”

In a recent poll, 70 percent of registered voters in America supported setting strict limits on carbon pollution produced by coal-fired power plants.

We’ve kept a list of quotes opposing the Clean Power Plan rollback, affirming a commitment to combating climate change, and supporting strong action to invest in clean energy solutions. It includes quotes from elected leaders, business leaders, consumer advocates, faith leaders, and more — you can read it in full here.

Even more climate progress is possible

More and more evidence shows that achieving the Clean Power Plan’s goals will be even cheaper than expected. Yet Pruitt’s proposal to repeal the Clean Power Plan is using underhanded accounting gimmicks to inflate his estimate of compliance costs.

If anything, lower than expected costs and the alarming pace of climate impacts mean the Clean Power Plan’s targets should be stronger.

Who benefits from a rollback? Pruitt’s political allies

Pruitt has been all over the news lately for his cozy relationships with lobbyists, lavish spending, and other self-aggrandizing abuses of his office. All these reports underscore that his first priority is not the well-being of the American public.

It’s no surprise to hear that organizations that helped fund Pruitt’s political ambitions received extensive contributions from Clean Power Plan opponents, including $25,000 from coal company Murray Energy just one month before the D.C. Circuit Court heard the Clean Power Plan oral argument.

Scott Pruitt built his political career by suing relentlessly to block EPA safeguards — including filing four separate lawsuits to oppose the Clean Power Plan. Pruitt’s proposal to repeal the Clean Power Plan would serve his political and financial backers at the expense of the health and safety of American families.

The time to speak up is now

The window for public input opposing this senseless decision will close this Thursday, April 26. Join with Americans across the country to voice your opposition by clicking here.

Also posted in Clean Power Plan, EPA litgation, News, Pruitt / Comments are closed

Administrator Pruitt opened the door to making Houston’s air toxics problem worse

By Tomas Carbonell / Published: April 10, 2018

Residents of Houston, Texas – our nation’s fourth largest city – have long been burdened with a serious air pollution problem.

Between 2013 and 2015, the Houston area reported unhealthy levels of ground-level ozone (“smog”) on an average of over 23 days each year. Last year, the American Lung Association ranked Houston as the sixteenth-most polluted city in the nation for year-round particle pollution.

The city’s massive industrial base – which includes two of the nation’s four largest petroleum refineries and more than 400 chemical manufacturing plants – spews a wide array of carcinogenic and toxic substances like benzene, 1,3-butadiene, and formaldehyde. The Environmental Protection Agency’s latest National Air Toxics Assessment, not surprisingly, found elevated cancer risks in many Houston neighborhoods as a result of these pollutants.

Recent records also show that pollution releases from these industrial facilities in the wake of Hurricane Harvey are also much higher than initially reported.

Yet EPA Administrator Scott Pruitt, rather than working to reduce this dangerous pollution, has opened the door to even greater risks to public health.

On January 25th, Pruitt’s EPA abruptly overturned a long-standing policy that was designed to prevent large industrial sources from increasing their emissions of hazardous air pollutants such as benzene. Under the new policy, many industrial facilities that are now subject to tough emission standards for “major” sources would be allowed to become subject to weaker emission standards, or even avoid federal emission limits altogether.

This dangerous new “Air Toxics Loophole” was issued without any opportunity for public comment, and with no consideration of its public health or air pollution impacts.

That’s why, we joined with six other public health and environmental organizations last month to file a legal challenge to the Air Toxics Loophole in a federal court of appeals

Today, we are releasing a white paper that takes a closer look at what the Air Toxics Loophole might mean for emissions of hazardous air pollutants in the Houston-Galveston area. We used EPA’s own enforcement and compliance database, EPA’s most recent National Emissions Inventory (NEI), and a careful review of federal permitting records to identify facilities that might be able to take advantage of the Air Toxics Loophole – and to estimate what the potential emissions impact might be.

The results aren’t pretty. In the Houston area alone, we identified 18 facilities that are potentially eligible to use the new Air Toxics Loophole. These facilities collectively emitted approximately 183 tons (366,000 pounds) of hazardous air pollutants in 2014. If all of these facilities exploited the Air Toxics Loophole to the maximum degree, we estimated that annual hazardous air pollution from these facilities would increase by almost two-and-a-half times – to a total of about 450 tons (900,000 pounds).

Many of these facilities are located in communities that are highly vulnerable to the harmful impacts of air pollution: half are located in areas where more than one in five people live in poverty and where people of color make up more than 30 percent of the population. On average, almost 20,000 people live within three miles of each facility in our dataset.

We aren’t the only ones to point out the potential risks of the Air Toxics Loophole. A report issued by the Environmental Integrity Project last month identified twelve additional facilities across the Midwest that could take advantage of the Air Toxics Loophole – and estimated that emissions from those facilities could more than quadruple to 540,000 pounds per year if they were to do so.

EPA’s own staff have pointed out the risks as well. Under the George W. Bush Administration, EPA floated – but never finalized – a proposal that was very similar to the Air Toxics Loophole. EPA received critical comments from state air regulators and EPA’s regional offices that raised the same concerns about the potential increases in toxic air pollution.

That Administrator Pruitt has decided to plow ahead again despite those warnings, and with no public input and no analysis of health impacts, is unconscionable. The results of our Houston analysis underscore how reckless that decision was.

Unfortunately, this isn’t the first time this EPA has denied the public an opportunity to participate in a major decision that will impact so many lives. Over the last year, EPA has taken a series of actions to roll back important safeguards, often at the demand of industry representatives, with no opportunity for the public to comment. Luckily, courts have been serving as an important backstop and are rejecting agency actions taken with disregard for required administrative procedures.

Let’s hope that the Air Toxics Loophole meets the same fate.

Photo: Manchester Ship Channel in Houston. Credit: Garth Lenz/International League of Conservation Photographers

Also posted in Clean Air Act, EPA litgation / Comments are closed