Submitted by Global Witness on behalf of: ECOSYSTEMS CLIMATE ALLIANCE and CDM WATCH
Response to call for submissions on the inclusion of reforestation of lands with forest in exhaustion as afforestation and reforestation CDM project activities
This submission is in response to the SBSTA invitation (FCCC/SBSTA/2010/L.15) for views on the implications of the inclusion of reforestation of lands with forest in exhaustion as afforestation and reforestation clean development mechanism (CDM) project activities.
The Ecosystems Climate Alliance and CDM Watch welcome the opportunity to highlight potential implications of the “forest in exhaustion” proposal, which we lay out below.
In summary, we consider the proposal to be little more than an attempt to provide subsidies to industrial tree plantations in circumstances that encourage bad management practices and the establishment of plantations in inappropriate locations. Such a subsidy would insulate the wood growing and processing industries from commercial pressures to improve their efficiency, reduce wastage, increase recycling and select more suitable sites for plantation establishment. The “forests in exhaustion” proposal also risks undermining the recently established REDD+ mechanism by incentivizing the establishment of plantations under the CDM rather than the restoration of natural forest ecosystems under REDD+.
The Ecosystems Climate Alliance and CDM Watch therefore consider that the proposal to include the reforestation of lands with forest in exhaustion as a CDM project activity should be rejected.
This submission consists of four sections:
I. Background to the proposal
II. Defining “forests in exhaustion”
III. Justification for the proposal
IV. Grounds for rejection
