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Guest Post: LULUCF, loopholes and REDD

LULUCF (land-use, land use change and forestry) became a hot topic at the Bonn meeting in June 2010, when it became clear that rich countries were attempting to use LULUCF to “hide increased emissions while trying somehow to create the illusion they are stopping catastrophic climate change,” as CAN International put it.

At a pre-sessional workshop on “Forest Management Accounting” in Bonn on 30 July 2010, Lim Li Lin of Third World Network presented a statement (pdf file, 51 KB) outlining the problems with the proposed LULUCF draft. “The current LULUCF rules and draft proposals represent a serious threat to environmental integrity and are the most outrageous of many loopholes that need to be closed in the second commitment period,” Lin said.

New changes proposed in the LULUCF text present another threat in addition to the “logging loophole” for rich countries. In the most recent text (FCCC/KP/AWG/2010/6/Add.2, 29 April 2010) is a request for the Subsidiary Body for Scientific and Technological Advice (SBSTA) to start a work programme that would look at expanding the clean development mechanism to include, “revegetation, forest management, cropland management, grazing land management, wetland management, soil carbon management in agriculture and other sustainable land management activities)”.

The new LULUCF text could, in other words, allow carbon credits from tropical forests to be pushed through the LULUCF negotiations, in effect bypassing the REDD negotiations.

“If this proceeds,” says Almuth Ernsting of the UK-based NGO Biofuelwatch,

“we can expect possibly unlimited carbon credits for forests, for industrial logging (forest management – without even the word ‘sustainable’), for crop and tree plantations of all types, for GM monocultures (with no-till being largely about herbicide-resistant GM crops and ploughing replaced with more agrotoxins), and, very likely, for biochar. CDM funding for all types of plantations would grow exponentially.”

Ernsting recently sent the following “guest article” to REDD-Monitor:

Forests, farmlands and soils in the CDM?

There may have been no agreement as yet that forests will be included into the Clean Development Mechanism under REDD as yet – but that and more is currently on the table at the UN climate talks in Bonn. Proposals to include all kinds of ‘carbon sinks’ into the Clean Development Mechanism (CDM), from forests, to ‘revegetation’, to agricultural soils, were tabled in Copenhagen and have been taken over to this year’s negotiations. They are being discussed, not under REDD or agriculture, nor under the debate about CDM reform (a misnomer for CDM expansion), but instead under as part of the debate about Land Use, Land Use Change and Forestry. This debate is supposed to be about rich or Annex I countries’ accounting for their own emissions from forests and agricultural lands at home. Indeed, there are major concerns about the loopholes proposed in that respect: Rich countries would effectively be allowed to draw a circle around an area of forest on a map, and designate that as an offset for fossil fuel emissions, even if that forest is being devastated by beetles or fire, followed by clearcutting whatever trees remain. Even wooden furniture and houses could be classed as ‘carbon sinks’ and claimed as an offset for coal power stations.
Yet the debate is by no means confined to dubious emissions accounting, or what will happen in Annex I countries – there could be a much more direct impact on Southern countries, too. There is also a push to “instruct the SBSTA (Subsidiary Body for Scientific and Technological Advice) to initiate a work programme to consider and, as appropriate, develop and recommend modalities and procedures for possible additional land use, land-use change and forestry activities under the clean development mechanism”, with a view towards a decision at a COP (Conference of Parties). Before the Kyoto Protocol came into force, it was decided that no more than 1% of CDM credits could come from so-called ‘carbon sinks’, and only from so-called ‘afforestation and reforestation’. Monoculture tree plantations, which even include oil palm and jatropha plantations, are falsely classed as forests under CDM rules. The ‘concession’ for ‘afforestation and reforestation’, though small in terms of overall CDM credits, has had, as was predicted, serious consequences for communities, forests and grasslands, not least by lending legitimacy to a much greater number of unregulated plantation ‘carbon offsets’ .
If current proposals are adopted, and a working programme for more forests and land use in the CDM is established, there will be a strong push for unlimited CDM credits for monoculture plantation of all types, as well as for industrial logging, falsely referred to as ‘forest management’. Soya, oil palm and jatropha plantations can, under current CDM rules, already attract carbon credits for the production of agrofuels, but companies will be able to cash in on far more money if soil carbon, cropland management and ‘revegetation’ (planting just about anything that grows anywhere) is also included. Previous limits were set largely because of the major uncertainties over the relationship between soils, plants and the climate and because trees can be quickly cut down, crops harvested and untilled soils can be ploughed. New studies show more, not less, uncertainty. What has changed, however, is that there are now even stronger calls for doing away with such concerns. Proposals from the current US Climate Bill*, for a mind-boggling range of creative accounting mechanisms have been lifted straight into UN proposals, allowing crops and trees plantations, as well as short-term farming practices to be classed as ‘permanent carbon sequestration’. Apart from funding tree and crop plantations as such, here are some of the other examples in the draft UN text:

  • Forest management, a term which can apply to any type of industrial logging;

  • Crop management: A large range of techniques linked to industrial agriculture and very often involving GM crops could fall under this, as well as practices supposed to reduce nitrous oxide emissions while perpetuating the use of fossil-fuel-based fertilisers. Much of this overlaps with ‘soil carbon management’.

  • Soil carbon: Apart from forests, soil carbon is widely seen as offering the biggest ’potential’ for attracting carbon credits to the agriculture and forestry sectors. Two main practices are promoted under this:

      a) No-till: This usually involves using large quantities of herbicides and other agro-chemicals applied to kill weeds rather than ploughing the soil. It is commonly used for monocultures of herbicide-resistant GM crops and associated with the displacement and eviction of hundreds of thousands of small farmers and with widespread pesticide poisoning. No-till GM soya has led to much faster deforestation for example in the Chaco forest in Argentina and Peru. The impact on soil carbon is not clear and there is evidence that it can lead to more nitrous oxide emissions. No-till carbon offsets have been strongly promoted, amongst others, by the Food and Agriculture Organisation.
      b) Biochar: Biochar is fine-grained charcoal applied to soils. It is supposed to make soils more fertile and store carbon long-term in soils, but there is very little evidence for either claim and the tiny number of published field studies shows that what happens when large amounts of charcoal are added to real fields can be very different from what laboratory suggests ‘should happen’. Perhaps most worryingly, there are high-level warnings that biochar carbon offsets could lead to more plantation expansion and biodiversity losses. Biochar carbon offsets are being promoted primarily by the lobby group International Biochar Initiative and by the Secretariat of the UN Convention to Combat Desertification.

Whatever happens at the UN level regarding cropland and soil carbon, the Global Research Alliance on Agricultural Greenhouse Gases (GRA), as well some member states, are prepared to push ahead regardless with carbon trading in soils and agriculture. The GRA was set up at the Copenhagen climate conference in December 2009 as a multilateral organisation with a clear purpose of developing new methodologies for agriculture and soils in carbon trading, something the Canadian government for example has made clear. There are clear parallels to REDD being pursued both inside and outside of UNFCCC.


* ^ This was written in June 2010, before the US climate bill died.

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  1. I´m from Venezuela and of course “hidden” negotiations and unclear procedures worries me related to our forests. Undoubtely, most rich and most poluters countries have to make climate change mitigation achievable. Now, regarding Tropical Forests, I just want to ask some questions:

    1) ¿Isn´t a good thing to improve logging by reducing its impact?; A great proportion of people emphasizes the creation of more protected areas. Fine, but what are we going to do with logged forests? ¿Do we leave them to hunters and to an unavoidable fate of total lost? or can we improve our knowledge about them?
    2) ¿Isn´t true that at least 15% of emissions comes from deforestation and degradation?
    3) ¿Isn´t true that deforestation (usually a highly valuated right in developing countries) affects biodiversity?
    4) ¿Isn´t a good thing to create new forms of forest management? Carbon should be part of this. Of course, communities needs, biodiversity also should be included.

    I agree with global concern about the precautions and constraints about REDD and REDD+. However, I think that if we promote a multi-stakeholder involvement in this type of projects, we could highlight the underestimated value of tropical forests ecosystems services. This would make these areas more economically competitive against other land uses. LULUCF should be applied equaly in all case and Annex I countries must respect the agreements.

  2. @Emilio Vilanova – Thanks. Here are some answers:

    1. Yes it would be a good thing to improve logging by reducing its impact. However, for several decades the logging industry has promoted the myth of “sustainable forest management” to expand destructive logging operations in old-growth forests. That’s why many people are worried that REDD could end up providing a subsidy to the logging industry and helping to increase the destruction yet further. Here’s a link to more posts on REDD-Monitor about “sustainable forest management“.

    2. Take a look at this post “20% of CO2 emissions from deforestation? Make that 12%” for a discussion about emissions from deforestation.

    3. Yes, deforestation affects biodiversity.

    4. I’m not sure that new forms of forest management are what is needed. Indigenous Peoples and local communities have been managing forests for a very long period of time. I’m also not sure that managing forests for carbon makes sense either. The graph in the post linked above illustrates the problem: emissions from fossil fuels have increased dramatically since 1980. Unless we address that problem, the risk of runaway climate change would be very high – and therefore a serious risk of large areas of the Amazon going up in smoke.

  3. There’s more on LULUCF accounting on Climate Action Network’s blog: “Minding the LULUCF forest accounting gap“. Click on the graph for a larger version:

    Annex I countries overall are planning to increase net emissions in the second commitment period without accounting for them.

    The solid line in the figure above shows historical aggregate net annual emissions and removals for Annex I Parties from
    1990-2008. The average of these emissions, shown as the heavy dashed line, provides a robust baseline with environmental integrity against which to measure future emissions from managing forests.

    Instead, developed countries are proposing to use baselines that will allow them to avoid accounting for emissions from accelerated harvest rates and emissions (the light dashed line in the figure below). The gap between these two lines represents the hundreds of megatonnes of emissions that could be released into the atmosphere
    and for which Parties would not be debited.

  4. “Give LULUCF and REDD a chance to work”

    Both the REDD and LULUCF initiatives under the Convention ie COP-16 must be given opportunity to develop a framework which can be deployed effectively in developing region.

    At the initial framework stages, there are of course certain vagueness about it but this cannot be translated into actions taken to boycott pro-active attempt by the global body to achieve true objectives as framed by the Kyoto Protocols.

    Discussions are in progress to define them, and if need be, redefine the ramification and scope of REDD and LULUCF implementation. Hence, the need to work together to make it a participative success for the global community.

    Jeong Chun Phuoc
    Expert Consultant at a major law firm and a pioneer advocate in Competitive Legal Intelligence(CLI)
    and a Reader in Syariah Competitive Legal Intelligence(sCLI)
    He can be reached at

    **The above professional analysis is the writer’s personal view and in no way represent the view/position of the research institutes/thinktanks/organisations to which he is currently attached to.