EDF Talks Global Climate

Proposals on forest carbon may create more problems than they solve in Cancún talks

Jason Funk, Ph.D. is a Conservation Analyst and expert in forestry and land-use policy. He is writing from the U.N. climate negotiations in Cancún.

The tiny Polynesian island nation of Tuvalu and South Africa at the U.N. climate talks in Cancún this week proposed new forestry climate accounting schemes that would undo three years of tough negotiating to create fair rules for all forestry nations in the next phase of the Kyoto Protocol.

To be sure, the option that has been on the table for the past year, called “reference levels”, is a little convoluted. It allows Parties to estimate the amount of emissions future forestry-related activities would create, then measure the benefit of their efforts to reduce carbon emissions based on their expectations of what those emissions might have been.

Not exactly a system that inspires trust.

Tuvalu, South Africa proposals would undo recent progress, be too crude to work

But Tuvalu has proposed a plan that takes a step backward, when we need to move forward. Tuvalu would erase any progress made on key issues over the last two or more years: how to deal with catastrophic fires and pest outbreaks, how to account for wood products, and how to manage the ups and downs of harvest cycles in plantation forests. It took hours of deliberation to craft texts on these issues that could preserve environmental integrity while allowing Parties to get a handle on accounting for this sector.  The Tuvalu option would scrap this work and ask a technical group to start over from scratch.

The proposal from South Africa is problematic for a different reason: it partially accepts the reference levels approach, but asks Parties to average their reference levels with their recent forest emissions. The intention is to reduce the potential for gaming the system by tying the reference levels to a some real, quality-controlled data.  But the approach is too crude and arbitrary to work.  It would still allow countries that ARE gaming the system to earn the most rewards, while potentially punishing those that are doing a good job.  Furthermore, it doesn’t have a basis in science – it’s simply a political fix to try to limit the worst damage globally.   It doesn’t get the incentives right for individual countries.

Recommendations to improve forestry accounting

Time is short. The high-level ministers will negotiate this issue next week, and they want to reach a conclusion here in Cancún.  Clearly, the new proposals signal that the reference levels approach is still a problem, at least for a few countries.   If their comfort level doesn’t improve by next week, they could block a decision here, dragging these negotiations into next year.

So what can be done at this point?

If the proponents of the reference level approach want to see it move forward, they need to put pressure on the Annex I parties who are abusing its flexibility– namely, those who are including recent bioenergy mandates in their reference levels, which will lead to increased harvests of wood for fuel.  Also, some parties are selectively using advantageous reference years for their reference levels.

They should work for convergence on reference levels, by agreeing to revise them so that they are anchored in a historical average of net forest emissions of at least 10 years, to balance out random variations.

They could then use models to project the effects of past management on future forest conditions – a procedure that would deal with the fact that forests in many countries are aging and their growth is slowing down.

Most importantly, they should excise the effects of recent policies from their reference levels.   The best way to do this would be to have a policy cut-off date of 2005, the year the Kyoto Protocol came into force, instead of the current date of 2009.

These changes are technically achievable by all the Annex I parties, and they would give reassurance to their non-Annex I peers (as well as environmental NGOs).  The accounting changes would only impact a few hold-outs, who are using the current flexibility to their advantage.

Parties shouldn’t hesitate to put pressure on these hold-outs, because this is an agreement that affects us all.  We can’t afford to waste another year without progress on a climate agreement.

This is part of a series from EDF’s experts, who are blogging regularly from the U.N. climate conference in Cancún on EDF’s Climate Talks blog.

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United Nations urged to adopt EDF’s proposals to improve carbon accounting in forestry

Reporting from the U.N. pre-sessional climate talks in Bonn, Germany.

Leading up to next week’s round of international climate change negotiations in Bonn, Germany, a coalition that includes Environmental Defense Fund today presented to the United Nations its proposals to properly account for land management activities that add or remove carbon in the atmosphere.

Using the historical average baseline (HA in graph above) is the most transparent way to account for emissions from the forestry and land use sector. This chart shows how alternatives to the Historical Average can lead to a wide range of unaccounted emissions.

In an unusual – and promising – move, the countries invited the Climate Action Network (CAN), a group of more than 450 organizations worldwide including EDF, to present its preferred accounting rules for Land Use, Land Use Change and Forestry (LULUCF) at a one-day “pre-sessional” meeting before the official negotiations begin Monday.

Today EDF and CAN representatives got to formally introduce the approach we’ve been pushing for some time now: accounting rules for creating robust and scientifically-accurate reference “baselines”.   (If you want to get into the weeds, check out the presentation we made and the “Forest Management: Getting the Accounting Right” fact sheet we handed out at the workshop.)

Parties were eager to talk about the details with me and Miram Chaum, the two EDF representatives, and they used the presentation as a launchpad for the day’s discussions.  One delegate from Brazil said EDF’s technical work was a “very helpful contribution,” echoing comments throughout the day that showed countries are interested in hearing the environmental community’s concerns and solutions.

Forestry and land-use policy has become one of the biggest issues this year in international negotiations, and negotiators have been intensely debating how to account properly for activities in forests in developed countries that add or remove carbon in the atmosphere.

Part of that debate is focused on how to define sustainability.  The problem is that we don’t know what countries are going to do with their forests in the future.  They might have a long-term commitment to sustainability, or they might not.  Without a way for countries to clarify their long-term commitments, the environmental community is left in doubt about their intentions.

But in Copenhagen, most Parties made a long-term commitment through the Copenhagen Accord.  It would be helpful, at this stage, for countries to elaborate how forests are going to help them meet their long-term commitments under the Accord.  Until then, we don’t have much transparency about their commitment to sustainability.

What’s wrong with current LULUCF accounting proposals?

Our analysis shows regarding the impacts on the atmosphere that will be unaccounted by any party if the proposed accounting rules are accepted.  Party Proposed Reference Levels

  • Allow emissions to go unaccounted and are not an effective mechanism for guaranteeing accounting integrity and ambition.
  • Do not incentivize activities to reduce forest emissions using mitigation activities identified by the Intergovernmental Panel on Climate Change.
  • Create the largest accounting gap, and would allow these emissions to go unaccounted.

The upshot is that these rules could allow Annex I countries (developed countries) to violate their climate commitments and allow new emissions to occur without penalty.

And the amount is not small.  We found that this factor and the impact of other proposals submitted by Parties could lead to an unaccounted emissions increase of nearly 580 Mt CO2-e per year – that’s nearly the amount of the United Kingdom’s annual greenhouse gas emissions.

Under the United Nations Framework Convention on Climate Change, the Kyoto Protocol and the Copenhagen Accord, Parties have agreed to conserve and enhance sinks and reservoirs, and make deep cuts in global emissions.  When we look at the science, we can only conclude that any increase in net LULUCF emissions will undermine Annex I Parties’ efforts to meet their economy-wide post-2012 commitments to reduce greenhouse gas pollution.

How can we solve LULUCF accounting?

CAN’s basic principle is simple: a long-term average is the best benchmark for measure changes in net emissions.

Using alternatives to a long-term average presents two major problems:

  1. A projected reference level is designed to measure deviation from planned growth, and does not accurately reflect changes in emissions relative to the current state of the atmosphere.
  2. LULUCF rules will undermine economy-wide ambition if they fail to account for increased net emissions from forest management from historic levels.

A long-term average – at least 10 years – is a better option, because it offers a number of advantages:

  • It allows better characterization of uncertainty.
  • It smoothes effects of economic cycles or transitions.
  • It evens out effects of interannual variability.
  • It minimizes winners and losers: everyone is treated equally.
  • There’s no opportunity for choosing convenient years to maximize credits.
  • It serves as the best reflection of historical impacts on the atmosphere.

Can we say all this in five sentences?


  1. Historical average baselines are the best reflection of changes in emissions to the atmosphere.
  2. All other alternatives create an accounting ‘gap’.
  3. This gap is largest for proposed reference levels.
  4. The accounting gap would undermine Parties’ commitments to reduce greenhouse gases.
  5. The historical average must be at least 10 years long so that fluctuations are smoothed out and the real effects of activities can be determined.

You can read more about our work with and analysis of LULUCF and forestry policy on the EDF Climate Talks blog and EDF’s Forestry and Land Use Policy 101 [PDF].

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