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U.S. Submission On Land-Use, Land-Use Change, And Forestry

RESPONSE STATEMENT Jennifer Morgan Director, WWF Climate Change Campaign

The treatment of land-use change and forestry (LUCF) in the Kyoto Protocol will have a fundamental impact on the international climate change agreement's environmental effectiveness and integrity. Rules on definitions, accounting procedures and ecological impacts will determine if the use of LUCF provides a large loophole for industrial countries to expand forests, crops, and rangeland to cut carbon emissions rather than use clean energy to reduce emissions at the source.

WWF has been closely monitoring these negotiations, working with scientists to ensure that the environmental integrity of the Kyoto Protocol is upheld. We read with interest the US submission on these issues that was released earlier this week and look forward to working with the Administration to further develop their position on LUCF.

More specifically, WWF was pleased to see that the Administration recognizes the risks inherent to certain approaches and decided to move toward a more environmental approach to Article 3.3 of the Kyoto Protocol by using the Intergovernmental Panel on Climate Change (IPCC) definitions for afforestation and deforestation. We hope that the Administration will also support the IPCC definitions for reforestation, independent of decisions on Article 3.4. We also welcome the recognition that:

  1. A broad approach to Article 3.4 would have a large impact on the first commitment period target and therefore a "threshold" is needed.
  2. Land-use change and forestry activities would have a number of ancillary impacts on the environment that should be taken into account.

We look forward to working with the Administration to further flesh out the proposals in the rules of the Kyoto Protocol.

We remain concerned, however, regarding a number of issues in the U.S. submission including:

  • Credit for business-as-usual or "anyway tons" that would have happened independent of human action. These should be excluded, according to the Kyoto Protocol, from the crediting system of the Protocol. Inclusion would allow additional amounts of "hot air" into the system and make it unlikely that the Protocol would require much of a reduction of greenhouse gas emissions.
  • Credit for a very broad range of carbon sink activities. This would have the U.S. and other countries relying on uncertain carbon sink activities to meet a large portion of the U.S. Kyoto target. This approach will not stabilize atmospheric concentrations at safe levels due to the uncertainties and impermanence of land-use change and forestry approaches.
  • Perverse incentives to harvest old growth forests prior to the commitment period. These should be specifically addressed and excluded from the Protocol.
  • Lack of environmental safeguards in the Protocol. While it may be true that existing national environmental laws and regulations could address some of those issues, WWF is calling on the Administration to ensure that rules are included in the Protocol to ensure the protection of ecosystems in the carbon crediting system.
  • Lack of inclusion of all greenhouse gas emissions in the land-use system the U.S. is proposing.

These issues must be addressed to ensure the environmental integrity of the Protocol - that it does indeed reduce greenhouse gas emissions and ensures that ecosystems are not harmed by the Kyoto Protocol.