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1
This
letter
does
not
reflect
support
for
any
subsequent,
a
la
carte
additions
or
changes
to
that
package.
2
Busch
et
al.,
“Comparing
Climate
and
Cost
Impacts
of
Reference
Levels
for
Reducing
Emissions
from
Deforestation,”
Environmental
Research
Letters,
Vol.
4.
No.
4,
Oct.
2009.
3
In
general,
IETA
strongly
believes
that
a
firm
20-‐year
cut-‐off
date
for
crediting
is
unlikely
to
be
appropriate
for
REDD
activities
in
any
country,
regardless
of
how
the
baseline
is
set.
REDD
activities
require
a
relatively
long
lead-‐time
to
plan
and
implement,
and
time
is
needed
for
REDD
economic
incentives
to
help
bring
about
the
changes
in
land
and
resource
use
that
are
needed
to
reduce
forest
loss
and
permanently
change
land-‐use
behaviors.
In
addition,
REDD
activities
are
very
likely
to
require
additional,
if
diminished,
finance
to
ensure
the
permanence
of
land-‐use
changes
in
later
years
by
continuing
to
promote
activities
that
increase
sequestration
once
forest
ecosystems
have
stabilized.
P a g e
|
2
International
Emissions
Trading
Association
Geneva
–
Washington
–
Brussels
–
Toronto
www.ieta.org
IETA
Input
on
Provisions
to
Reduce
Tropical
Deforestation
in
Energy
and
Climate
Legislation
July
21,
2010
impact
on
the
effectiveness
of
the
REDD
program
overall.
Creditable
A/R/R
activities
are
crucial
to
successful
REDD
efforts;
they
enable
the
use
of
integrated
land
management
approaches
that
help
control
leakage
around
protected
forests
by
alleviating
the
pressures
to
deforest.
A/R/R
activities
are
fundamentally
different
from
traditional
REDD
projects,
since
they
sequester,
rather
than
avoid
emissions.
A/R/R
projects
have
substantially
higher
upfront
costs
–
for
preparing
land,
purchasing
and
planting
seeds,
and
maintaining
forests
during
maturation—
and
generate
offsets
only
as
trees
grow
slowly
over-‐time,
both
of
which
greatly
extend
the
payback
period
on
investment,
when
compared
with
REDD.
Graph
1
in
Annex
3
depicts
a
typical
project-‐level
A/R/R
carbon
stock
curve,
showing
that
sequestration
and,
thus,
crediting,
only
begins
to
take
off
at
year
5.
(Graphs
2-‐4,
taken
from
university
studies,
support
that
assertion.)
Graph
1
also
demonstrates
the
impact
on
crediting
that
will
occur
given
an
8-‐year
crediting
period.
This
graph
shows
that
the
vast
majority
of
emissions
sequestered
through
the
project
occur
in
later
years
and
will
thus
go
un-‐credited,
or
will
be
subsumed
in
a
national
scheme.
Given
the
uncertainty
surrounding
the
implementation
of
nested
crediting
during
the
early
years
of
the
program,
this
is
simply
not
a
situation
in
which
private
investors
will
provide
the
upfront
finance
needed
to
get
projects
up-‐and-‐running.
3. The
re-‐inclusion
of
project-‐based
crediting
for
"small
emitters"
is
an
important
step
in
the
right
direction,
but
IETA
believes
that
the
legislation
should
extend
a
limited
period
of
project-‐based
crediting
to
large
emitters
as
well.
Allowing
project-‐based
crediting
in
all
countries
for
a
limited
amount
of
time
would
kick-‐start
REDD
activities
and
protect
forests
in
the
near-‐term,
until
national
governments
can
build
the
necessary
capacity
to
do
so
and
gain
the
trust
of
much-‐needed
private
investors.
Projects
serve
two
essential
purposes.
First,
they
permit
local
communities
to
gain
direct
finance
for
REDD
activities,
giving
them
the
freedom
to
protect
their
homes
and
livelihoods
in
a
timely
manner
when
governments
are
unable
to
do
so
quickly
or
reliably,
which
is
the
current
situation
in
the
majority
of
forest
nations.
Second,
project-‐based
crediting
serves
as
a
hook
that
draws
much-‐needed
private
investment
to
REDD
initially,
hopefully
convincing
investors
to
maintain
and
deepen
investments
as
countries
move
to
national
baselines.
The
initial
period
of
project-‐based
crediting
should
serve
as
an
‘incubation
period’
that
acclimates
private
investors
to
the
REDD
space,
giving
them
time
to
become
comfortable
financing
activities
that
require
harmonized
public/private
approaches
in
unconventional
investment
situations,
where
their
investments
face
significant
sovereign
risk.
Existing
REDD
protocols
developed
in
conjunction
with
highly
respected
non-‐governmental
conservation
organizations
establish
additionality,
set
crediting
baselines
and
address
concerns
about
leakage,
permanence,
and
non-‐carbon
social
and
environmental
benefits.
Given
the
additional,
extensive
safeguards
for
project-‐based
activities
already
included
in
the
draft
legislation,
IETA
believes
that
restricting
an
initial
period
of
project-‐based
crediting
to
small
emitting
countries
is
arbitrary
and
unnecessarily
slows
REDD
efforts
by
P a g e
|
3
International
Emissions
Trading
Association
Geneva
–
Washington
–
Brussels
–
Toronto
www.ieta.org
IETA
Input
on
Provisions
to
Reduce
Tropical
Deforestation
in
Energy
and
Climate
Legislation
July
21,
2010
severely
limiting
the
flow
of
private
financing
in
large
emitters,
where
the
pressures
to
deforest
are
highest.
4. IETA
believes
that
reductions
in
illegal
deforestation
must
remain
eligible
to
receive
offset
credits,
at
the
project-‐based,
subnational,
and
national
levels.
While
precise
data
on
the
scope
of
illegal
forest
activities
is
not
available,
organizations
such
as
the
World
Bank
and
Chatham
House
estimate
that
between
50-‐80%
of
deforestation
is
illegal,
which
makes
it
clear
that
denying
funding
from
activities
to
halt
illegal
deforestation
would
completely
undermine
REDD
efforts.
Moreover,
concerns
about
the
possibility
of
crediting
illegal
actors
for
not
undertaking
illegal
activities,
which
would
clearly
create
a
situation
of
moral
hazard,
are
unfounded
and
reflect
misunderstandings
about
the
differences
between
planned
and
unplanned
deforestation
and
the
actors
that
would
be
eligible
to
act
as
project
participants
and
gain
direct
access
to
credits.
IETA
would
gladly
explain
these
differences
in
great
detail,
if
needed.
On
behalf
of
IETA’s
member
companies,
I
would
like
to
thank
you
for
your
attention
to
this
letter.
Please
do
not
hesitate
to
contact
me,
or
Kim
Carnahan
<carnahan@ieta.org>
in
our
Washington
D.C.
Office,
with
any
questions
that
you
may
have.
Sincerely,
Henry
Derwent
President
and
CEO,
IETA
IETA
Input
on
Provisions
to
Reduce
Tropical
Deforestation
in
Energy
and
Climate
Legislation
July
21,
2010
Annex
1:
IETA
Input
on
Provisions
to
Reduce
Tropical
Deforestation
in
Energy
and
Climate
Legislation
July
21,
2010
Annex
2:
Reference
Level/Crediting
Baseline
Design
Options
A
Sample
of
Proposals
from
Existing
Studies
Design
option
Reference
Description
“National
historical”
Santilli
et
al.(
2005)
Reference
rate
is
historical
for
all
countries.
Reference
period
set
to
the
average
deforestation
rate
of
the
last
10
years,
updated
every
3
years.
“Higher
than
historical
for
Mollicone
et
al.
(2007);
da
Reference
deforestation
rate
is
countries
with
low
Fonseca
et
al.
(2007)
0.3%
for
low-‐deforesation
deforestation
rates”
countries;
Baseline
is
historical
for
high
deforestation
countries.
“Weighted
average
of
Strassburg
et
al.
(2008)
Reference
rate
is
0.6*global
national
and
global”
average
rate+0.4*historical
rate
for
all
countries.
Different
scenarios
can
be
generated
by
differing
the
weights
put
on
historical
global
deforestation
and
national
deforestation.
“Flow
withholding
and
Cattaneo
et
al.
(2008)
Reference
rate
is
historical
for
all
stock
payment”
countries;
30%
“withholding”
on
flow
payments
to
pay
for
stock
payments.
“Uniform
fraction
of
at-‐risk
Ashton
et
al.
(2008)
Reference
level
is
1%
of
at-‐risk
stock”
forest
for
all
countries;
80%
of
total
forest
is
assumed
to
be
at-‐
risk
in
all
countries.
“Half
the
global
average”
Joint
Research
Center
Uses
historical
global
proposal
of
Archard
et
al.
deforestation
rates
to
set
(2005)
individual
country
baselines.
Countries
with
a
rate
of
deforestation
lower
than
half
the
global
average
use
that
as
a
national
baseline,
while
countries
with
higher
deforestation
rates
use
a
national
historical
baseline.
“Development
Adjustment
Coalition
for
Rainforest
In
order
to
take
into
account
Factor”
Nations
national
circumstances,
countries
P a g e
|
6
International
Emissions
Trading
Association
Geneva
–
Washington
–
Brussels
–
Toronto
www.ieta.org
IETA
Input
on
Provisions
to
Reduce
Tropical
Deforestation
in
Energy
and
Climate
Legislation
July
21,
2010
with
low
levels
of
GDP
per
capita
will
get
more
generous
baselines.
This
is
justified
because:
(i)
the
poorest
countries
are
presumably
at
an
earlier
stage
in
forest
transition,
and
therefore
deforestation
is
likely
to
accelerate
rather
than
slow
down
in
a
BAU
scenario
and
(ii)
the
capacity
to
implement
REDD
may
be
inversely
related
to
GDP
per
capita,
and
larger
transfers
are
needed.
“Economic
Models
of
Angelsen
and
Kaimowitz
Factors
including
population
National
Deforestation”
(1999)
density
and
growth,
forest
area,
economic
growth,
commodity
prices,
governance
variables,
and
location
(tropical
and
regional)
could
all
be
included
in
a
formula
for
setting
baselines.
“Corridor
Approach”
Schlamadinger
et
al.
(2005)
Increases
percentage
of
reductions
being
credited.
For
example,
a
reduction
in
deforestation
and
degredation
from
0.8%
to
0.7%
per
year
(or
the
equivalent
in
GHG
emissions)
gives
carbon
credits
worth
only
20%
of
the
estimated
emissions
reductions,
while
reductions
from
0.7%
to
0.6%
give
credits
equivalent
to
40%
of
the
estimated
reductions,
and
so
on.
IETA
Input
on
Provisions
to
Reduce
Tropical
Deforestation
in
Energy
and
Climate
Legislation
July
21,
2010
Annex
3
:
Graph
1
:
IETA
Depiction
of
Typical
Project-‐Level
A/R/R
Carbon
Stock
Curve
IETA
Input
on
Provisions
to
Reduce
Tropical
Deforestation
in
Energy
and
Climate
Legislation
July
21,
2010
Graph
2:
Study
from
University
of
Idaho,
Moscow
(March
2008)4
4
O’Laughlin,
J.
"Carbon
Sequestration
in
the
Forest
Sector."
Policy
Analysis
Group
Issue
Brief
No.
11.
University
of
Idaho,
College
of
Natural
Resources.
March
2008.
Sources
for
the
scientific
claims
and
data
for
the
figures
can
be
found
in
the
PAG
Issue
Brief
document
at
www.cnrhome.uidaho.edu/default.aspx?pid=106665.
P a g e
|
9
International
Emissions
Trading
Association
Geneva
–
Washington
–
Brussels
–
Toronto
www.ieta.org
IETA
Input
on
Provisions
to
Reduce
Tropical
Deforestation
in
Energy
and
Climate
Legislation
July
21,
2010
Graphs
3
and
4:
Study
from
University
of
Washington
(June
2003)5
5
Lippke,
B.,
J.P.
Garcia
and
C.
Manriquez.
"Executive
Summary:
The
impact
of
Forests
and
Forest
Management
on
Carbon
Storage."
Rural
Technology
Initiative,
College
of
Forest
Resources,
University
of
Washington.
June
2003.
P a g e
|
10
International
Emissions
Trading
Association
Geneva
–
Washington
–
Brussels
–
Toronto
www.ieta.org