NGO Statements
Submission to the UK climate change committee enquiry into the EU ETS
This submission to the "EU Emissions Trading System: New Inquiry" shows that fundamental flaws in the design of the EU ETS have been exposed by (a) a series of fraud and cybercrime incidents; (b) the excessive use of carbon offsets by companies hoarding higher-value EU ETS permits received free of charge; and (c) the lack of a functioning regulatory possibility to adjust thesupply of EU ETS emission permits to a sharp economic downturn, and theresulting drop in emissions far below projected levels that were used to calculate permit allocation.
| Document | Size |
|---|---|
 FERN submission on the EU ETS to the energy and climate change committee.pdf | 372.59 KB |
Submission to UN consultation on new market-based mechanisms to enhance the cost-effectiveness of, and promote, mitigation actions
This submission concludes that the EU ETS and the Kyoto Protocol’s carbon trading schemes have been designed to fail: they assume the contribution of carbon permits and offset credits to limiting greenhouse gas emissions to a verifiable target to be the same, when in reality they are not because calculation of offsets depends on unverifiable hypothetical baselines from which offset volumes are calculated. The call for submissions on ‘establishing new market-based mechanisms’ suggests that these ill-conceived mixed permit-credit carbon trading schemes are to be extended to additional sectors, such as the forest and land use sector (where error margins are even bigger and risk of reversal of carbon savings is significant).
Linking trading schemes that operate in jurisdictions where enforcement capacity differs significantly, will provide further ground for trading in ‘subprime’ carbon derivatives, in particular given that much of the trading activity in carbon offsets is carried out over-the-counter.
| Document | Size |
|---|---|
| UN Markets submission_FERN_FOE-US.pdf | 245.95 KB |
FERN submission to a commodity futures trading commission study
FERN’s input into the Commodity Futures Trading Commission and interagency working group’s forthcoming study on the oversight of existing and prospective carbon markets. It concludes that the EU Emissions Trading Scheme and the Kyoto Protocol’s carbon trading schemes have been designed to fail and that it is difficult to see how subsequent regulation could remedy a situation where the challenge is not to remedy design flaws but where the design is the flaw.
| Document | Size |
|---|---|
| 2010 12 17 FERN Submission to CFTC on carbon markets.pdf | 52.94 KB |
FERN submission to UK Parliament
FERN submission to the UK Select Committee on Environment, spelling out FERN's vision on forest, climate, rights and carbon trading
| Document | Size |
|---|---|
 OPEN | 76.5 KB |
FERN letter to Council asking for exclusion forest credits in ETS
| Document | Size |
|---|---|
| OPEN | 134.66 KB |
FERN submission to the Eliasch Review on Avoided Deforestation
FERN submission to the Eliasch Review Questionnaire: Global Forests and Finance Flows.
| Document | Size |
|---|---|
| OPEN | 135.68 KB |
FERN's submission to the FSC regarding the Plantar certificate.
Also, see preliminary report by SILVA Ecossystem Consultants complements the FERN / SinksWatch submission to FSC.
| Documents | Size |
|---|---|
| Open | 496.78 KB |
| SILVA Ecosystem Consultants report | 136.81 KB |
Durban Declaration on Carbon Trading.
Representatives from people’s movements and organizations worldwide gathered in South Africa from 4-7 October 2004 to help forge a global people’s movement for action on climate change and to condemn the rapidly emerging market in carbon as a false solution to the problem.
| Documents | Size |
|---|---|
| Durban Declaration on Carbon Trading | 40.4 KB |
| Declaración de Durban sobre el Comercio de Carbono | 40.4 KB |
| Déclaration de Durban sur le commerce du carbone | 41.42 KB |
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