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Climate Action Network Australia
c - October 2000
This position is supported by the following Climate Action Network Australia (CANA) member groups:
- Aidwatch
- Australian Conservation Foundation
- Australian Reproductive Health Alliance
- Centre for Education Research in Environmental Strategies
- Community Anti-Nuclear Network of Western Australia
- Conservation Council of the South East Region and Canberra
- Conservation Council of South Australia
- Environment Centre of the Northern Territory
- Environment Victoria
- Friends of the Earth
- Greenpeace Australia
- Nature Conservation Council of New South Wales
- Queensland Conservation Council
- Rainforest Information Centre
- Tasmanian Conservation Trust
- Tasmanian Environment Centre
- World Wide Fund for Nature
This paper outlines the Australian Government's stance and the CANA position on the main issues to be resolved at the Conference of the Parties 6 in The Hague in November.
Australia can play an important role in ensuring that the Kyoto Protocol's rules are strong and environmentally sound. Weak rules will allow more greenhouse gas pollution and may have other detrimental environmental impacts and lost investment from an uncertain market place.
CANA members have concerns with the Australian Government's position and we have proposed an alternative stance that the Australian Government should take on each of these issues.
The Big Picture
The Kyoto Protocol treaty may be ineffective if loopholes in the rules allow additional pollution to go into the atmosphere, while providing Governments with a cover to hide that additional pollution.
CANA members are concerned that the Australian Government has been identified as one of the nations looking for a large number of loopholes in the treaty rules. Following the most recent key meeting to prepare for COP6, international environment organisations Greenpeace and WWF both identified Australia as one of a group of four nations that have been the worst in this regard.
1. Emissions trading
The right for Parties to the Protocol to buy and sell 'rights to pollute' - countries that have gone over their target would buy the right to pollute from countries that were under their target.
Australian Government position
The Australian Government is "in favor of adopting rules…which are uncapped, open, market-based, comprehensive and which minimise cost. The Kyoto mechanisms would allow Australia, as a likely net purchaser of carbon credits, to have access to low-cost carbon credits in other countries…" (Treaties Committee submission 2000)
CANA position
CANA opposes the Government's current position on the design of emissions trading because:
- Australia's target should be largely met through the reform of domestic electricity and transport systems and through the reduction of landclearing. These positive and essential steps will not occur if Australia simply buys the right to pollute at business as usual rates.
- By not capping the amount of permits a country can sell, the Government is supporting the "Hot Air" problem. This term refers to a specific situation that has arisen because Russia and Eastern Europe were given pollution targets way above current levels of emissions and above what they are likely to need. These permits to pollute which will be available for sale will have been earned through diplomacy rather than actual emission reductions. It is estimated that 150 mega tonnes per year of "hot air" permits would be available for countries to buy rather than take action to reduce emissions.
- We remain unconvinced that an international emissions trading scheme run without tight regulation will work for the atmosphere. There needs to be tight monitoring and verification of trades, and of the benefit of those transactions to the atmosphere.
2. Joint Implementation
Developed (or Annex 1) countries can choose to invest in an emission reduction project in another (Annex 1) country to gain a credit that can be used at home to offset domestic pollution.
Australian Government position
Australia wants no limits on the types or number of activities that can be undertaken under Joint Implementation (JI) arrangements. The Government believes that as long as the two host Governments are happy with the project, the project should be allowed. Therefore they also believe there is no need for any specific institution to oversee the projects around the world and that monitoring can be carried out by the project developers. The Government has failed to support public participation and transparency that would allow the community to comment on proposed JI activities.
CANA position
CANA members are extremely concerned about some of the early JI style carbon sink projects that have been occurring in Australia. In particular certain sinks projects have involved the clearing of native vegetation. The management of these projects has failed to provide open access to information or seek local advice about issues such as water.
One of the reasons that CANA is opposed to the use of sinks in JI during the first commitment period, is because of a fear that Australia will become a monoculture dumping ground for high polluting nations. We also remain unconvinced that verification and compliance rules proposed by the Australian Government are thorough enough to ensure that native vegetation is not cleared for sinks.
We believe the JI rules must include strong public participation provisions so that the community can provide views and advice on proposals.
3. Clean Development Mechanism
A program that allows nations with targets to purchase a right to pollute over their target, by investing in projects in developing nations, without targets
Australian Government position
The Government's submission to the FCCC argues that "the modalities and procedures (for the CDM) should be simple and stimulate business participation". Australia does not support the banning of environmentally unsound projects in the CDM - such as sinks, large scale hydro, nuclear or fossil fuel developments. The Government believes that the project types need to be decided by the host countries themselves, consistent with their own definitions of sustainable development priorities.
Australia is also in favour of limiting the information available to the public about CDM projects - "the call for transparency in relation to costs, risks and liabilities incurred by Parties is likely to impede CDM projects and business participation especially if largely commercial-in-confidence information is sought" (Australian submission to the FCCC, 2000)
CANA position
A successful CDM could promote sustainable technologies and generate benefits for the atmosphere. However, the CDM is a mechanism that allows nations to pollute above their Kyoto targets. Given Australia's target of 8% above 1990 emission levels, CANA believes it is inappropriate for Australia to purchase CDM credits.
Given the potential for this program to see all industrialised nations simply buy the right to pollute by investing in environmentally dubious projects, CANA believes there needs to be extremely tight restrictions on the types of activities that are eligible for CDM credits. This would include only renewable energy and energy efficiency technology that allows developing nations a clean alternative to following a fossil fuel or nuclear driven development path.
Carbon sinks should not be allowed in the CDM. The fact that non-Annex I (developing nations) Parties have no emission reduction commitments under the Protocol poses fundamental problems for the types of project that might reasonably be included in the CDM. This is especially true of sinks projects. A developing country might legally clear the bulk of its forests without being penalised for the released greenhouse gases, and still be able to offer credits for other sinks-related CDM projects.
Clean coal and nuclear projects must also be ruled as ineligible for CDM credits, as the inclusion of these polluting technologies may provide incentive for developed nations to "dump" their redundant fuels and technologies into developing economies.
CDM projects should be ecologically sustainable, provide social benefits and ensure there is consultation and participation with local and indigenous communities.
4. Compliance
This system will determine the penalties for a nation that goes above its target. The compliance system's strength will make the difference between the treaty being an international law that really drives change and one that is just a well meaning but ineffective statement of what should be.
Australian Government position
The Australian Government has been actively trying to weaken the Kyoto Protocol compliance system during talks about its design. Australia is opposed to
- financial penalties and the issuing of cautions
- allowing another nation to raise questions about another's record of meeting their target
- any binding consequences for non-compliance, and
- a firm starting date for the compliance system to begin
Australia has not actually proposed a system for compliance, but simply opposed many of the proposals put forward by other nations
CANA position
The Kyoto Protocol needs a strong compliance system that ensures there is a strong incentive for nations to meet their targets and maintain rigorous verification and record keeping.
A compliance system should have both remedial and punitive components. Remedial responses are designed to enable a Party, through its own efforts, to avert impending non-compliance or quickly restore itself to compliance. Punitive responses are also necessary to pressure recalcitrant Parties that fail to avert non-compliance in a timely manner to change their behavior.
Borrowing emission allocations from the next commitment period should not be allowed.
5. Article 3.3 - Kyoto sinks
Article 3.3 of the Kyoto Protocol allows for certain sink activities undertaken inside Australia to be counted in the commitment period. These activities have been limited to afforestation, reforestation and deforestation (ARD).
Australian Government position
The definition of a forest is central to what is included under ARD. The Australian Government has proposed that there be a biome-based definition, but that each country decides which vegetation fits within which definition.
The emissions from deforestation will be counted when the proportion of canopy cover per hectares on a given area of forested land is reduced by 30% or more as a direct result of human activity.
Reforestation credits are for the establishment of forests on lands which have historically contained forests but which have been converted to some other use. Prior to reforestation, the land must have been under some non-forest use for a period of not less than 5 years.
Reforestation credits can be awarded for direct planting, artificial seeding, site preparation (fire or mechanical) and protective fencing.
Afforestation credits can be gained for new forests on lands that have historically not contained forests.
CANA position
CANA believes that the Article 3.3 sinks rules must comply with the Convention on Biological Diversity.
CANA supports a biome-based for deciding approach to which forests are caught by ARD, but we propose that this be decided by the Conference of the Parties and not by nations. This will ensure international standards and prevent nations picking and choosing the forests based on some political criteria.
CANA supports the deforestation approach, but suggests a wording change:
- Deforestation includes the conversion of forests to a different land cover or the reduction of canopy cover by more than 20% of its previous level, be counted as deforestation.
CANA is opposed to the logging of native forests and believes this definition of deforestation must account for the conversion of any mature native forest to a plantation. Regular forestry activities need not be covered by this deforestation definition if there is a continuous cycle sustainable plantation arrangement, however this initial change of cover from a mature native forest to a plantation must be accounted for.
CANA does not support the reforestation definition and believe that the land must have been under some non-forest use for the entire period since 1990. We believe this is the safest way to prevent a perverse incentive to clear land to get reforestation credits.
CANA supports only direct planting as an eligible reforestation and afforestation activity.
Reforestation and afforestation credits are only available for plantings that are intended to be permanent and have a legal covenant that states this as the intention of the project. Reforestation and afforestation credits should only be available for plantings that enhance local biodiversity and are not detrimental to water sources.
Afforestation and reforestation credits must not be available for the establishment of forests on any native non-forest vegetation, such as native grasslands.
6. Article 3.4 - Additional sinks
Allows nations to count a range of other land use and forestry sink project categories in their commitment years, but not the starting year. These "Additional Activities" would provide nations with a substantial new sink that would allow for emissions to increase.
Australian Government position
While the Australian Government has specifically proposed the inclusion of one additional activity sink, revegetation, it is states that it will also bring forward proposals to include agricultural soils and forest management. The Government believes that Article 3.4 sinks should be able to be used by nations to meet their targets in the first commitment period.
CANA position
No "additional activities" relating to agricultural soils and other land use change and forestry activities should be included in the assigned amounts of Annex I Parties in the first commitment period.
CANA recognises there may be scope for inclusion of these activities in the next commitment period.
This will however only be an option if there is a verifiable and transparent baseline set for the emissions from these activities for the starting year, so that any improvements are being put into an accurate perspective.
Even if this is achieved CANA is concerned that there will remain significant problems of double counting and leakage potentially associated with many of these activities. The ability to adequately monitor broadly defined activities and to distinguish between direct human-induced and other effects also makes these activities problematic.
Climate Action Network Australia
www.climateaustralia.org
Contact Anna Reynolds on 0419 547 217 for more information
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