I am sorry for the ambigous definition last night. Sometimes short is not
complete. I agree with the fact solid solutions in shift of energy use is
needed. But this
also takes money, and investment. I still don't find using a temporary amount
of sink, as part of the agreement -- a wrong approach, as long as it is used
in a small portion -- a cushion. If it led to long term solution, an means to
end
doesn't seem so far stretched.
Appeal about Sinks in Land-Use, Land-Use Change and Forestry (LULUCF) in
the Kyoto Protocol for Global-warming Prevention
Green Friends (Japanese Forest NGO)
We, the Japanese forest NGO Green Friends submitted two appeals at SB13,
September 2000, Lyon.But some points we have recommended are not enough
satisfied yet. So we submit this appeal about sinks in LULUCF, which is
an important subject having a large influence on the success or failure
of the Kyoto Protocol for global-warming prevention. We strongly request
the following points in order that the treaty may become truly effective.
Summary:
1. First of all, as a matter of course it should be ensured that
harvest-regeneration cycle is excluded from the accounting as sinks by
the additional human-induced activities under Article 3.4 in the Kyoto
Protocol (As to Article 3.3, regeneration after felling was excluded
from the definition of "Regeneration" in the draft decision in
FCCC/SABSTA/2000/12). The CO2 credit for harvest-regeneration may induce
much improper felling and decline in wood price due to excess felling,
which make sustainable forest management difficult. If
harvest-regeneration cycle is included in the accounting as sinks under
Article 3.4 in the Kyoto Protocol, all the regenerated forests including
regenerated before 1990 may be accounted for as sinks after the first
commitment period of 2008-2013, and the treaty may lose its significance.
2. The effect of the additional human-induced activities accounted for
under Article 3.4 of the Kyoto Protocol, should be evaluated comparing
with the case without the admitted additional activity as the baseline.
3. Accounting duration should not be defined as only the commitment
period. The trends before the commitment period and after the
commitment period should be taken into account, in order to prevent
pretended decrease in forest destruction and pretended increase in
afforestation only in the commitment period, preceded and/or followed
by inverse trend to them. For a simple example, accounting using
average in 20 years including the years before and after the commitment
periods may be preferable. 4. Forest growth inventories often have
many imprecise factors and are often biased toward overestimating sinks.
So in the evaluation of the effect of additional human-induced
activities, enough consideration should be paid to these uncertainties
and over estimating tendencies.
5. As most of the sinks in LULUCF are sequestrations which merely delay
CO2 emission as described in the draft decision (c) in FCCC/SABSTA/2000/12,
there are problems in permitting net greenhouse gas emissions from
fossil fuels and other sources instead of LULUCF sequestrations. So the
CO2 credit for the sinks in LULUCF should be admitted only in minimal
ranges.
6. The carbon storage in soil organic matters may often show the
tentative increases after logging but decrease after that, so
unconsidered accounting of it may bring overshoot accounting of
increases in sinks. So such temporal increases in soil carbon should
not be accounted for as the carbon stock increases and should be
considered as emission, though the greenhouse gas emissions from soils
by artificial impacts such as reported by Canada should be accounted
for.
7. Forest fire should be accounted for as CO2 emission even in the case
where it was regenerated after it. Because if not so, much greenhouse-gas
emissions by forest fires become unaccounted for, and furthermore if
some additional activities at the sites after forest fires are admitted
to be accounted for, even CO2 credit may occur in the results of
forest fires, which is clearly improper. Considerable parts of climatic
damages, and pest and disease damages should also be accounted for as
CO2 debit under Article 3.4, because large parts of these damages are
brought by combined influences of human-induced activities such as air
pollutants, acid deposits and climatic changes, as described in item 8.
of this appeal.
8. As to "additional human-induced activities" under Article 3.4 of the
Kyoto Protocol, human-induced negative effects including acid deposits,
air pollution, and climate changes, such as the decline of forests and
vegetation, increases in climatic damages or pest and disease damages,
and so on, should be taken into account and considered as the
"human-induced activities". Asymmetrical accounting that accounts for
only the activities increasing sinks without accounting for these
negative activities, is not permissible, though the effect of CO2
fertilization should not be accounted for, from the below reasons.
9. As to Article 3.7 of the Kyoto Protocol, parties to which the final
sentence of Article 3.7 applies, should not be exempted from accounting
of forest destruction after 1990, because the incentive to decrease
forest destruction is important, and these forest destruction emits
greenhouse gases.
10. As to the CO2 credit for projects including CDM (clean development
mechanisms) under Article 6.1, 12.2, 12.3 and so on of the Kyoto
Protocol, considering uncertainty and the risks of forest sequestration,
in future especially in developing countries enough, discounted
accounting should be done with so low a rate (such as 1/1000 to 1/100)
as the CO2-elimination cost of the projects may not become so different
from the cost of domestic elimination in developed countries, and a
proper low-amount ceiling of the credit for CDM should be set. In order
to bring proper incentives to the tropical forest conservation, to
prevent too much dependence on CDM in LULUCF which are very uncertain,
and to reserve the elimination amount of the developing countries
itself by the forest management, a proper low-amount ceiling of the
credit from CDM and very low discount rate should be set to CDM in
LULUCF.
11. It is necessary to be assured that the projects including CDM do
not exert any undesirable influences on the natural ecosystems,
societies and economies of the developing countries, as the conditions
of certification. For example, improper plantations that damage natural
ecosystems or the living of people, should not be allowed nor
accounted for.
1. First of all, as a matter of course it should be ensured that
harvest-regeneration cycle is excluded from the accounting as sinks by
the additional human-induced activities under Article 3.4 in the Kyoto
Protocol (As to Article 3.3, regeneration after felling was excluded
from the definition of "Regeneration" in the draft decision in
FCCC/SABSTA/2000/12). The CO2 credit for harvest-regeneration may
induce much improper felling and decline in wood price due to excess
felling, which make sustainable forest management difficult. If
harvest-regeneration cycle is included in the accounting as sinks under
Article 3.4 in the Kyoto Protocol, all the regenerated forests
including regenerated before 1990 may be accounted for as sinks after
the first commitment period of 2008-2013, and the treaty may lose its
significance.
If harvest-regeneration cycle is included in the accounting as sink,
the following impropriety may occur. Felling of precious natural
forests, compelling increases in felling of natural forests and/or
conversion to artificial forests, excessive logging, unnecessary
felling, running-in felling-regeneration during the commitment period,
pretended decreases in deforestation only during the commitment period
and increases after that due to unsuccessful improper regeneration, and
so on, may occur. Some of natural regeneration after felling may
result in degradation of the forests, and it is improper to admit CO2
credit for forest degradation. Furthermore, increase in wood harvest
may bring decline in wood prices, and then sustainable forest
management may become difficult.
And the sequestration in forests is not equivalent to the emission from
fossil fuels and so on. For example, harvest-regeneration cycle does
not increase carbon stock in forests generally, and so it seems to be
improper to allow greenhouse-gas emissions in exchange for
harvest-regeneration.
Harvest-regeneration cycle usually brings much organic residues on the
forest floor and into the soil, and they are emitted as CO2 in some
duration, and in temperature regions during some years after the
regeneration when the crown cover rate is low, the CO2 absorption amount
by the regenerated forests is relatively small. These negative factors
in harvest-regeneration cycle may not be properly evaluated under the
proposed accounting system.
And including harvest-regeneration cycle into accounting as
sink under Article 3.4 (in this case all the regenerated forests after
felling including regenerated before 1990 are included into accounting
after the first commitment period), may bring too much CO2 credit,
especially in the case when the activity-based accounting is adopted.
If a large amount of CO2 credit for harvest-regeneration cycle can be
admitted under Article 3.4, so much amount of greenhouse gases as to
come up to an amount similar to the reduction commitment amount of all
the Annex I signatory countries, may be permitted to be emitted as the
exchange for the harvest-regeneration cycle, and the Kyoto Protocol may
lose most of its significance. Even if the admitted credit is
relatively a small amount in the first commitment period, the credit in
the second and subsequent period it will become much larger amount and
bring dangerous results. Such results go against the draft decision in
FCCC/SABSTA/2000/12 that any LULUCF activity 'must not change the
global effect of the Kyoto Protocol'. So it is surely thought that
harvest-regeneration cycle is excluded from the accounting as sinks,
and it should be ensured.
The Japanese government insists that incentives to harvest-regeneration
cycle are important, for example in the report on LULUCF submitted to
UNFCCC dated 1 August. But as described above, it is not true and is
improper.
Adoption of the "IPCC Definition" in Article 3.3 for the countries such
as Canada in which decreases in forest area is large, however, may
result in large amounts of CO2 emission being accounted for, and may
make it extremely difficult to achieve the reduction commitment.
Therefore some mitigation measures may need to be considered and
adopted for such cases, on condition that harvest-regeneration cycle is
excluded from the accounting as sinks under Article 3.4.
2. The effect of the additional human-induced activities accounted for
under Article 3.4 of the Kyoto Protocol, should be evaluated comparing
with the case without the admitted additional activity as the baseline.
The carbon credit for the additional human-induced activities under
Article 3.4 should be given for the effect of the additional activity,
instead of for the whole carbon absorption of the forest subjected to
the activity, as a matter of course. So the effect of the additional
human-induced activities should be evaluated by subtracting the
baseline absorption amount in the case without the admitted additional
activity from the actual absorption amount of the forest. The
accounting of the whole carbon absorption of the forest subjected to
the activity, brings tremendous overestimation of the sinks and must
not be admitted.
3. Accounting duration should not be defined as only the commitment
period. The trends before the commitment period and after the
commitment period should be taken into account, in order to prevent
pretended decrease in forest destruction and pretended increase in
afforestation only in the commitment period, preceded and/or followed
by inverse trend to them. For a simple example, accounting using
average in 20 years including the years before and after the commitment
periods may be preferable.
4. Forest growth inventories often have many imprecise factors and are
often biased toward overestimating sinks. So in the evaluation of the
effect of additional human-induced activities, enough consideration
should be given to these uncertainties and over estimating tendencies.
Forest inventories conducted by the government are often based on
calculated prospective growth in many areas, and tree deaths and
decline are not often evaluated enough. Changes in wood density are
seldom evaluated. These imprecise factors often bring overestimation of
sinks. The estimation of the CO2 emission from soil and storage in
soil is especially imprecise. Some countries including Japan are even
lacking the consequently measured previous forest growth data, and so
it is quite difficult to evaluate the baseline for the additional
human-induced activities.
5. As most of the sinks in LULUCF are sequestrations which merely delay
CO2 emission as described in the draft decision (c) in FCCC/SABSTA/2000/12,
there are problems in permitting net greenhouse gas emissions from
fossil fuels and other sources instead of LULUCF sequestrations. So the
CO2 credit for the sinks in LULUCF should be admitted only in minimal
ranges.
Even if the sequestrations in LULUCF are increased, the increased
sequestrations cannot necessarily continue or be maintained every year
in future. On the contrary, it is very likely that remaining lands
useable for sequestrations will decrease and sequestrations will
decrease in the future (then it becomes impossible to make the CO2
accounts balance), and even it is possible that much sequestrated CO2
will be emitted by a large-scale windfall or forest fire. Therefore
while the effort to reduce forest destruction is of course important,
we do not believe such an accounting method in which the amounts stored
in forests are permitted to be emitted now is proper.
If all the human-induced activities exampled in the IPCC special report
on LULUCF are permitted to be taken into account as the "additional
human-induced activities" under Article 3.4 of the Kyoto Protocol,
emission amounts so much as to offset the reduction commitments of all
the Annex I signatory countries may be exempted from reduction. If such
a result is allowed to occur, the significance of the treaty for
prevention of global-warming will be greatly diminished.
The "additional human-induced activities" under Article 3.4 of the
Kyoto Protocol are not necessarily conducted for purposes of preventing
global-warming and in many cases may be conducted for other purposes.
So with regard to the additional human-induced activities under Article
3.4 of the Kyoto Protocol, the significance of incentives to reduction
of greenhouse gases may be minute and it may rather have an aspect of
merely evading reduction.
In the draft decision (c) in FCCC/SABSTA/2000/12, it is described that
'any Annex I Party that makes use of such removal to achieve compliance
with its Kyoto Protocol commitment shall continue to be responsible
for the equivalent emission reduction at the appropriate point in time',
but in reality 'the equivalent emission reduction' added to the
ordinal reduction commitment in future will usually be difficult. So
the CO2 credit for the sinks in LULUCF should be admitted only in
minimal ranges.
6. The carbon storage in soil organic matters may often show the
tentative increases after logging but decrease after that, so
unconsidered accounting of it may bring overshoot accounting of
increases in sinks. So such temporal increases in soil carbon should
not be accounted for as the carbon stock increases and should be
considered as emission, though the greenhouse gas emissions from soils
by artificial impacts such as reported by Canada should be accounted
for.
For example, residues of felling, thinning, pruning or lopping, left at
the forest floor, usually induce temporary increases in soil carbon
storage and decreases in it after that. It may bring disguised increases
in carbon sinks during the commitment periods.
7. Forest fire should be accounted for as CO2 emission even in the case
where it was regenerated after it. Because if not so, much greenhouse-gas
emissions by forest fires become unaccounted for, and furthermore if
some additional activities at the sites after forest fires are admitted
to be accounted for, even CO2 credit may occur in the results of forest
fires, which is clearly improper. Considerable parts of climatic damages,
and pest and disease damages should also be accounted for as CO2 debit
under Article 3.4, because large parts of these damages are brought by
combined influences of human-induced activities such as air pollutants,
acid deposits and climatic changes, as described in item 8. of this
appeal.
8. As to "additional human-induced activities" under Article 3.4 of the
Kyoto Protocol, human-induced negative effects including acid deposits,
air pollution, and climate changes, such as the decline of forests and
vegetation, increases in climatic damages or pest and disease damages,
and so on, should be taken into account and considered as the
"human-induced activities". Asymmetrical accounting that accounts for
only the activities increasing sinks without accounting for these
negative activities, is not permissible, though the effect of CO2
fertilization should not be accounted for, from the below reasons.
These influences of air pollution, acid rain and so on, may appear not
only in the reduction of wood volume growth but also in the decrease of
wood density, density of latewood, or latewood rates, and in early
death of the trees and the high incidence of disease and pest damages
or climatic damages due to the decline in tree vigor. Despite some
reports on the effects of volume growth enhancement by nitrogen
deposits, the reduction of growth is often reported as described below
(and Schutt 1985), and nutritional imbalance due to base cation loss
and nitrogen deposits has been reported to induce tree decline in
Europe (Schulze et al. 1989).
These decreases in CO2 absorption due to acid deposits, air pollution,
and climate changes are in some respects difficult to account for
precisely, partly due to uncertain evaluation of tree mortality rate
and difficulty in differentiation of combined causes. Furthermore they
are under the pressure from the industry and so on to be hidden (in
some countries such as Japan the government does not even admit the
occurrence of the influences officially). Nationwide assessments of
wood density are rare, and reports on the trend of decrease in wood
density are, if any, hardly made public for the fear of a decrease in
the market value of wood products. Some parts of the pollutants are
cross-border and difficult to estimate responsibility of each country.
But such absorption decreases are obviously of a sufficient amount to
offset the CO2-absorption increases due to additional human-induced
activities under discussion on accounting, as described below. So if
the precise accounting of such decreases in CO2 absorption by sinks is
impossible, the increases in CO2 absorption due to additional
human-induced activities also should not be taken into account.
For example in Europe, in the results of the survey by UNECE/CEC (2000)
it is described that in 1999 almost 1of the trees were dead, 1 - 2
were severely defoliated, 20were moderately defoliated, 41were
slightly defoliated, and only 36were classified as healthy. It was
shown that nitrogen and sulphur deposition, stand age, soil type, and
precipitation influenced this defoliation. Nevertheless, some reports,
such as Spiecker et al. (1996) which is cited in the IPCC special
report on LULUCF, showed that increase trend in tree volume growth in
most regions of reported countries. But in this report, changes in wood
density, tree mortality rate, climatic damages, and pest and disease
damages are seldom evaluated, and descriptions on soil parent materials
are lacked in many reports and large parts of described parent
materials are calcareous ones which are unsusceptible to acid deposits.
So even if it is true that in some or broad regions tree volume growth
is increased by the effects of nitrogen-deposit fertilization in the
relatively less precipitation European conditions which tend to induce
nitrogen accumulation, or by the effects of CO2 fertilization or
temperature rise, in reality, tree death rates, tree climatic damages,
pest and disease damages, or wood density may be negatively influenced
by the air pollutants and climatic changes. On the other hands, there
are some reports that some examples of growth recovery in 1980s are
often related to reduction of air pollutants and that even the
recovered growth rate around 1990 is still inferior to that before 1960
(Visser1992,1995). The report by UNECE/EC (2000) describes the reduced
ecosystem stability due to nitrogen deposits, citing the report that
decreases in the ratio of root biomass to above ground biomass, and
decreases in fine root biomass were observed related to the nitrogen
deposits (Eichhorn 1995). It is reported that cation nutrient deficit
and overdose of nitrogen have become major causes of tree decline
(Schulze et al. 1989). In December 1999 in Europe a very large scale of
windfall occurred mainly in France Denmark, Switzerland, and southern
Germany and nearly 180 million m3 of trees were windthrown (UNECE/EC
2000). For instance in Switzerland and France more than twice as much
as the annual wood harvest volume of trees have fallen, which means
that more than the national annual growth was lost and in the year the
forest was not a sink but a source in these countries. The background
causes of this large windfall is thought to be not only rare strong
winds, but also weakening of trees due to air pollutants and acid
deposits (for example, severe damages in Black Forest which is famous
for damages by acid rain, may have possibility of endorsing this).
In North America and Japan, similar severe damage and decline of forests
are reported. There are many reports describing recent decreases in
forest growth in North America. In the northeast United States, the
biomass increment of a mountainous forest felled 70-80 years ago was
reported to have become nearly zero recent years, the cause of which is
related to loss of soil calcium (Likens et al. 1994,1996). In 200 plots
of forests in Pennsylvania, it was reported that growth rates decreased
and mortality rates increased in the period of 1970s - 1985 compared to
the period of 1960s-1970s, which was most frequently related to
stocking, defoliation by insects and drought (Brooks 1994).
In Japan present coniferous trees lose nearly 30of their leaves on the
average due to decline main
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