Recommendations for SBSTA Item 11(a) on Land use, land-use change and forestry under Article 3, paragraphs 3 and 4, of the Kyoto Protocol and under the clean development mechanism
Prepared for the SBSTA, 45 session, COP 22, 7-18 November 2016
Carbon Market Watch welcomes the opportunity to provide input to the SBSTA discussions on land use, land-use change and forestry under Article 3, paragraphs 3 and 4, of the Kyoto Protocol and under the Clean Development Mechanism. This item directs SBSTA to continue consideration of work on paragraphs 5, 6, 7, and 10 in 2/CMP.7 that request SBSTA to initiate the following four work programmes:
- To explore more comprehensive accounting of anthropogenic emissions by sources and removals by sinks from LULUCF, including through a more inclusive activity-based approach or a land-based approach, and to report to CMP 9 on the outcomes of this work programme (paragraph 5);
- To consider and, as appropriate, develop and recommend modalities and procedures for possible additional LULUCF activities under the clean development mechanism (CDM), with a view to forwarding a draft decision on this matter to CMP 9 for consideration and adoption (paragraph 6);
- To consider and, as appropriate, develop and recommend modalities and procedures for alternative approaches to addressing the risk of non-permanence under the CDM, with a view to forwarding a draft decision on this matter to CMP 9 for consideration and adoption (paragraph 7);
- To develop and recommend modalities and procedures for applying the concept of additionality, with a view to forwarding a draft decision on this matter to CMP 9 for consideration and adoption (paragraph 10).
The only eligible LULUCF activities under the CDM are afforestation and reforestation activities. Other LULUCF activities are ineligible is because of major uncertainties over how to measure and verify the amounts of sequestered carbon from lands. Concerns also exist over incomplete or inaccurate accounting rules and non-permanence of activities in land sectors. Accordingly, there is no coherent vision or set of rules in relation to land use and carbon markets under the UNFCCC.
To properly address the land use sector under the UNFCCC and increase confidence in the achievement of NDCs, it is essential to ensure that accounting rules are improved, that the land use sector be addressed outside of carbon markets under a framework that equally values all objectives of the sector, including adaptation and protecting local livelihoods. This requires that non-permanence be appropriately addressed with current rules or by excluding non-permanent activities from the CDM. Finally, the concept of additionality must be replaced by more comprehensive and accurate accounting of the land use sector to see a full picture of carbon fluxes that will allow countries to clearly see trends in the overall health of their carbon sinks.
Read recommendations here
 SBSTA Agenda. http://unfccc.int/resource/docs/2016/sbsta/eng/03.pdf
 Decision 2/CMP.7 Land use, land-use change and forestry. http://unfccc.int/resource/docs/2011/cmp7/eng/10a01.pdf#page=11
25 Feb 2021