Letter from Fern

26 September 2000

To:  Environment Ministers and Heads of Delegation

c.c. THE SINKS EXPERT GROUP OF THE EU

RE: EU SUBMISSION ON TEXTUAL PROPOSALS ON ARTICLES 3.3, 3.4, 3.7 OF THE KYOTO PROTOCOL

The definitions proposed must focus on the ecosystem approach as defined in the Convention on Biological Diversity (CBD).

The UN-ECE/FAO based definition of forests favoured in the draft EU submission does not reflect the shortcomings raised during the presentation of the IPCC special report on Land Use, Land-use Change and Forestry at the pre-SBSTA 12 sessions in Bonn about use of this definition in the Climate Change context. Authors of the special report highlighted that the FAO definition of forests based on a 10% forest cover was not developed with carbon accounting in mind, and is therefore not suitable for Article 3.3: “Definitions of ARD that are based only on canopy cover may allow activities that lead to significant carbon fluxes to remain unaccounted….If a low threshold is set (e.g. 10-percent canopy cover), dense forests could be heavily degraded and significant amounts of carbon released and the actions would not be designated as deforestation.[1]”  The report further states (pg. 56): “ Definitions that are based strictly on a canopy cover threshold may lead to an interpretation of conventional harvest / regeneration cycles as deforestation followed by reforestation. Such interpretations lead to significantly greater areas of forest being included within lands under Article 3.3”.

Not the least, to ensure consistency with the Council resolution of June 22/2000 voicing “serious concerns about the scale and the scientific and other uncertainties and risks associated with sinks”, we would urge the EU to reconsider its draft submission in favour of a definition reflecting the ecosystem-based approach of the CBD.

In the Underlying Causes of Deforestation and Forest Degradation initiative of the Intergovernmental Forum on Forests it was noted that ' lack of a coherent current definition of forests incorporating an ecosystem approach has lead to a severe underestimation of the problem of forest degradation in some countries.' (Addressing the Underlying Causes of Deforestation and Forest Degradation, Case Studies, Analysis and Recommendations (available from Fern).

Ensuring this will mean that credit cannot be gained for activities which favour forest degradation. For example, using the UN-ECE/FAO 10% definition, conversion of land with 80% cover to land with 15% cover would not be definable as deforestation even though significant amounts of carbon would be released.

We endorse the Greenpeace and WWF comments on the draft EU submission, particularly the call for consistency with existing conventions, in particular the approaches of the Convention on Biological Diversity (and in this context current references to national forest plans, the EU forest strategy etc. are superfluous)).

The credibility of the Kyoto Protocol is dependant on tight definitions that do not allow for practices that will promote conversion and degradation of existing forests. Poor projects which earn credits for business as usual practices will jeopardize the environmental integrity of the protocol and genuine efforts to stave off the threats of climate change.

The current EU position against the inclusion of forest sinks in the CDM must be maintained.

Yours sincerely,

Sofia Ryder

Jutta Kill