Why Brazil’s ridiculous “Forests in exhaustion” proposal must be rejected from the Clean Development Mechanism

Forests in exhaustion is one of the more absurd proposals to emerge from the UN negotiations on climate change. The proposal came from Brazil during 2008 and it was discussed during the Conference of Parties to the Kyoto Protocol held in Poznan in December 2008. It amounts to nothing more than a subsidy for industrial tree plantations.

Under current clean development mechanism rules, plantations are potentially eligible for CDM credits if the plantation was established on non-forested land after 1 January 1990. So far, only 22 of these “Afforestation/Reforestation” projects have been approved under the CDM. The “forests in exhaustion” is intended to include plantations established before 1 January 1990.

The problems with this proposal are many. Perhaps most obvious is that the “forests” are in fact industrial tree plantations. “Forests in exhaustion” would allow companies to use existing plantations to qualify for CDM credits. Proving additionality becomes not only impossible (as it already is, since it involves predicting the future and comparing it to counterfactual – or “what if” – stories) but also irrelevant. A company just has to prove that the plantation was established before 1990 and argue that unless it receives CDM credits it will abandon the plantation.

During the 33rd session of the Subsidiary Body for Scientific and Technological Advice that took place in Cancun between 30 November and 4 December 2010, the UNFCCC requested submissions on the “Implications of the inclusion of reforestation of lands with forest in exhaustion as afforestation and reforestation clean development mechanism project activities.”

The following submissions from NGOs were submitted:

• Global Forest Coalition (pdf file, 1.3 MB)
• Global Witness on behalf of the Ecosystems Climate Alliance and CDM Watch (pdf file, 520.2 KB)
• Carbon Trade Watch and World Rainforest Movement (pdf file, 337.3 KB)
• Timberwatch Coalition (pdf file, 3.2 MB)

All are opposed to the proposal.

The submission from the Global Forest Coalition is signed by 64 national and international NGOs and Indigenous Peoples’ organisations. It calls for an exclusion of financial support for monoculture tree plantations through climate change-related programmes. The submission lists the many social and environmental impacts of industrial tree plantations.

The submission from Global Witness, the Ecosystem Climate Alliance and CDM Watch includes an explanation of what Forests in Exhaustion refers to followed by why it should be opposed. The explanation is posted below. (This explanation is about as clear as is possible on such a confusing subject – although it would be even clearer if it did not write about land covered with industrial tree plantations as “forested”.)

In their submission, Carbon Trade Watch and World Rainforest Movement focus on four concerns with the proposal (posted below). The submission includes a very useful list of relevant publications by Carbon Trade Watch and World Rainforest Movement.

The Timberwatch Coalition submission is a recent report about the potential impacts of a carbon plantation project currently being established in Tanzania.

Global Witness on behalf of the ECOSYSTEMS CLIMATE ALLIANCE and CDM WATCH
 
Response to call for submissions on the inclusion of reforestation of lands with forest in exhaustion as afforestation and reforestation CDM project activities
 
28 March 2011
 
[ . . . ]
 
II. Defining “forests in exhaustion”
 
Brazil’s “forests in exhaustion” proposal is an attempt to expand the existing CDM rules to incorporate replanting of tree plantations after their harvest as a reforestation activity. The proposal makes no distinction between whether land was forested or not before 1990.
 

According to the proposal, a “forest in exhaustion” is defined as:
 
“[A]n area of land that contained forest – established through planting, seeding and/or the human-induced promotion of natural seed sources – on 31 December 1989 and/or at the starting date of the project activity. If the land at the starting date of the project activity is forest then, in the absence of the project activity, it would be converted to non-forested land through final harvesting within [5] years of the proposed starting date of the project activity. If the land at the starting date of the project activity is non-forested land then, in the absence of the project activity, it is expected to remain as non-forested land.”
FCCC/KP/CMP/2009/16, Annex I (at page 27)

 
This definition has caused considerable confusion amongst the Parties. The reason for the confusion, perhaps, is that the definition tries in a rather complicated way to describe two separate issues, namely (a) the types of land that potentially qualify for this type of CDM project (“where” the CDM projects might be located) and (b) when that land qualifies as a “forest in exhaustion” (“when” the land is eligible for a CDM project of this type).
 
When and where “forests in exhaustion” projects may be undertaken
 
The first part of the “forests in exhaustion” definition attempts to describe the type of land that is potentially eligible for a CDM reforestation project. In particular, it expands the application of the CDM rules so that reforestation projects may potentially be undertaken on:
 

(i) Land that was un-forested on 31 December 1989 (this is the scenario already covered by the existing rules); or

(ii) Land that was “forested” on 31 December 1989, provided that on that date those forests are of either the following types:
a. Forests established through planting and seeding (i.e. tree plantations); or

b. Forests established through human induced promotion of natural seed sources (includes tree plantations, as well as potentially natural forests subject to logging and forest management).

 
When this land is considered “exhausted” and therefore potentially eligible for a Reforestation activity
 
The second part of the “forests in exhaustion” definition describes when land is considered “exhausted” and hence eligible for commencement of a CDM reforestation project. Forests are considered “exhausted” if either:
 

(i) The land was forested on 1 January 1990, but is now no longer forested; or

(ii) The land is currently forested, but after the next logging cycle, if all the trees are cleared, the land is not expected to regenerate naturally within [5] years.[5]

 
III. Justification for the proposal
 
According to statements made by Brazil in the UNFCCC, the “forests in exhaustion” proposal is intended to provide financial support to maintain tree plantations established before 1 January 1990. Under existing CDM rules, plantations established after 1 January 1990 on non-forested land are potentially entitled to CDM credits, while tree plantations established prior to this date miss out.
 
The rationale for the “forests in exhaustion” proposal is that without additional financial support, tree plantations that are unable to regenerate naturally due to repeated tree planting and harvesting would otherwise be abandoned when they become commercially unviable. The proposal is intended to allow Parties to claim CDM credits for re-establishing commercial plantations on such degraded land.
 
To date, only 14 Afforestation/Reforestation projects have been approved under the CDM. The introduction of “forests in exhaustion” is hoped to result in increased numbers of potential reforestation projects. However, it should be made clear this proposal would primarily benefit large, existing plantations instead of small operations on agricultural land which the current CDM definitions were designed to encourage. Least developed countries will not benefit as they have few plantations.[6] Further, the agreement reached in Cancun to establish a REDD+ mechanism addresses many of Brazil’s original concerns, making the “forests in exhaustion” proposal redundant.
 

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Footnotes:
[5] ^^ The reference to “[5] years” is in square brackets to indicate that the exact time period is still subject to negotiation.

[6] ^^ The majority of plantations in 1990 were located in Asia and the Pacific region (79%), then Latin America and the Caribbean (13%) and finally Africa (8%). Country-specific statistics from 1990 reveal that China had the largest area of land under plantation at 31.8 million ha; followed by India at 13.2 million ha; Indonesia, 6.4 million ha; Brazil, 4.9 million ha; Viet Nam and the Democratic People’s Republic of Korea at 1.5 million ha each. Source; Food and Agricultural Organisation: FAO State of the Worlds Forests 1995: www.fao.org

 

From: Carbon Trade Watch and the World Rainforest Movement
Ref: Submission about implications of reforestation of lands with forests in exhaustion as afforestation and reforestation clean development mechanism project activities
 
[ . . . ]
 
We are extremely concerned about the Board’s definition of ‘forests in exhaustion’ and what would supposedly happen to these ‘forests’, according to Annex 1 of the document FCCC/KP/CMP/2009/16, as well as about the proposal to include as a possible CDM activity reforestation activities on lands that did not contain or contained ‘forests in exhaustion’ on 31 December 1989.
 
Hereby follow our main points of concern:
 
1. According to your description of ‘forests in exhaustion’ these supposed ‘forests’ can include industrial tree monocultures. In our supportive work to local communities that are affected by these monocultures, we learned that these tree monocultures have nothing to do with forests. The only similarity is that both contain trees. However, while forests offer a huge range of nutritional, water, medicine, spiritual and other benefits to forest peoples, industrial tree plantations are being called “green deserts” by local communities for the fact they do not offer any benefit, and life is totally absent inside the identical rows of trees of these monocultures which have only one purpose: supplying wood to industry. The fact that even the FAO still considers industrial tree plantations as forests, has had dramatic consequences for thousands of communities in the South and has favored Industry interests. However, over the past years, many academics, state officials, representatives of different social and environmental organizations, etc. have opposed against the FAO definition. The fact that UNFCCC opts for maintaining the FAO definition is disturbing and tends to perpetuate and create new conflicts all over the world between expanding plantation companies and local communities.
 
2. This new proposal permits tree plantation companies to present a CDM project for any of their plantations, be these existing or new plantations. What we have learned from the practice is that the companies that started their plantations long before 1989 always have counted with sufficient financial support and resources to maintain their activities until now and the main proof is that the major companies always have been replanting their areas. Especially in the global South where this activity is extremely profitable, which has led to a process that Northern tree plantation companies are in a process of transferring their activities to the Global South where they can make more profits. It is therefore that this activity can not be considered as ‘additional’, on the contrary, it is clear that what the industry is aiming at is another subsidy for an already very profitable sector.
 
3. Industrial tree monocultures of eucalyptus, pine, oil palm and rubber trees cause many negative impacts, in spite of a discourse of industry that it is a ‘sustainable and renewable’ sector. The attached studies (1) show very clearly that these plantations have severe impacts on the land distribution, expelling people directly and indirectly from their land. Large scale plantations have huge impacts on water resources availability and quality and several scientific studies on the issue are also publicly available. Plantation companies need to apply pesticides that affect soil, biodiversity and the workers. This type of agricultural activity creates 10 to 15 times fewer jobs if compared with small-scale agricultural production and the majority of jobs are dangerous and relatively badly paid. Women are relatively most impacted by industrial tree monocultures. And also, the expansion of these monocultures continues to be one of the important direct and indirect drivers of deforestation, which means in fact the emission of even more carbon to the atmosphere.
 
4. And finally, but of extreme importance: be it plantations or be it forests, not one of these planted trees areas are able to guarantee a structural and long-lasting contribution to mitigate global warming, because, among other reasons, the carbon emissions resulting from deforestation may be chemically identical to those coming from the burning of fossil fuels, but the two are climatologically different. Carbon released from deforestation does not increase the total amount of carbon being exchanged among the atmosphere, the oceans, soils, forests, and so on. Carbon released from fossil fuels, on the other hand, does increase this above-ground carbon pool.”

 

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CORRECTION – 13 May 2011: 22 “Afforestation/Reforestation” projects have been approved under the CDM and not 14 as previously stated: http://cdm.unfccc.int. (As the number of CDM projects will no doubt change, here’s a screenshot of registered afforestation/reforestation projects.)