Industry and NGOs lobby to weaken UN carbon credit rules in “coordinated” push

Carbon credit developers, corporate buyers and some leading conservation NGOs are challenging new proposed rules to stop UN carbon credits being wiped out by fire, drought or logging, in what critics have called a “coordinated lobbying campaign” to weaken the nascent market’s push for greater integrity.

According to documents seen by Climate Home News – including a briefing given to government officials – companies, NGOs and the UN Environment Programme (UNEP) have contested the scientific basis for the move, arguing that stronger protection for carbon reductions could hike project costs and restrict the supply of credits to the market.

The climate benefit of credits that claim to reduce or avoid greenhouse gas emissions by storing carbon is undone if that carbon is released back into the atmosphere – something known as reversal risk. To protect against such losses and preserve the credibility of the credits’ carbon-offsetting claims, projects are generally required to set aside a reserve of credits that cannot be sold, as a form of insurance.

How these “buffer pools” are calculated has long been a source of contention, especially in forest conservation projects, which many experts say have historically underestimated the risk of carbon losses.

In July, the technical UN panel tasked with drafting rules for the Article 6.4 mechanism, which underpins the credits that countries and companies can use to meet their climate goals, proposed a new system. It would require project developers to size these insurance pools of credits based on local risk values derived from new research published by a group of independent scientists.

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Its supporters have hailed it as a more rigorous approach than current practice in the voluntary carbon market, which largely relies on expert guesswork and, in some cases, gives significant leeway for project developers to come up with their own data.

“The decision on the reversal risk assessment tool will be crucial,” said Federica Dossi, an expert at Brussels-based advocacy group Carbon Market Watch. “It would bring a new paradigm for calculating the number of units forwarded to the buffer pool based on empirical data.”

The technical panel is due to discuss the reversal risk tool and its application to a specific set of projects at a five-day meeting in Bonn this week. It is then expected to forward new recommendations to the mechanism’s regulator, the Supervisory Body, for a decision on whether to approve them at a meeting in early October.

The rules are set to be applied initially only to clean cookstove projects, one of the market’s most popular and heavily criticised credit types. They could then be extended to other activities, including programmes to protect forests.

Copy and paste?

More than 30 organisations aired their views in lengthy public submissions to the Article 6.4 mechanism, responding to a call from the UN secretariat for external feedback.

A Climate Home News review of those submissions found that there was significant overlap in their messages and, in several cases, sections of the text, or even entire submissions, were copied and pasted by different organisations. This points to a coordinated effort to flag concerns regarding the new rules.

In one instance, tech giant Apple, a large buyer of nature-based carbon credits, warned against relying on one scientific model and called for rules that let project developers use a variety of risk mitigation tools, rather than surrendering buffer credits, to cover the risk of carbon losses.

Apple’s submission is a lightly-edited version of a separate input presented by the Beyond Alliance, a coalition of corporate buyers and NGOs that promote market-based climate investments. In an apparent oversight in one paragraph, the Beyond Alliance’s name appears in Apple’s submission instead of the tech giant’s.

The Beyond Alliance told Climate Home News that, after receiving input from its members, it shared its final submission, leaving them to decide if and how they wanted to use it. The coalition rejected any characterisation that its submission advocates for a weaker tool and only reflects business concerns.

The Beyond Alliance added that its members received briefings by UNEP, which Climate Home News understands has played an important role in wider efforts to influence the development of the rules underpinning the UN carbon market.

Three experts and a European Union diplomat told Climate Home News that the interventions of the UN agency overwhelmingly supported the views of those with a financial interest in carbon markets.

UNEP’s head of mitigation Gabriel Labbate rejected this accusation. He told Climate Home News that the UN agency contributes technical inputs from a “politically-neutral, science-based perspective” and its positions are grounded in an assessment of environmental integrity and are not shaped by, or aligned with, the financial interests of any market participant.

UNEP, NGOs criticise scientific basis

In mid-July, representatives from UNEP, Conservation International and The Nature Conservancy (TNC) briefed government officials from Canada, the UK, Germany, Costa Rica, Belgium, Nigeria and Peru, according to a webinar readout seen by Climate Home News.

The online event was organised by the Forest & Climate Leaders Partnership (FCLP), an initiative that brings together 41 countries plus the EU.

The speakers voiced strong criticism of the new proposed rules. A technical advisor to Conservation International, a US-based NGO that runs several large-scale carbon offsetting programmes, told participants the Article 6 panel’s approach was “based on bad science”. This, he said, is because it relies on a single model that he claimed is not appropriate to determine buffer pool contributions, according to a presentation seen by Climate Home News.

During a high-level discussion led by UNEP’s Labbate, speakers said the application of measures to manage reversal risk on cookstove projects could “impose disproportionate costs and undermine the financial viability of these activities”, according to the readout.

Burn company enumerator Teresia Wanjiru checks moisture on firewood at a client’s house using clean cookstoves in Kachoroba village of Kiambu county, Kenya, August 16, 2023. REUTERS/Monicah Mwangi Burn company enumerator Teresia Wanjiru checks moisture on firewood at a client’s house using clean cookstoves in Kachoroba village of Kiambu county, Kenya, August 16, 2023. REUTERS/Monicah Mwangi

Cookstove programmes issue credits by calculating the greenhouse gas emissions prevented by burning less fuel – usually wood or charcoal – through the use of more efficient stoves. With the new reversal risk tool, these activities would be expected to guard against future carbon losses for the first time under the UN carbon market.

But UNEP, as well as leading NGOs and carbon credit firms, have pushed back against the requirement, arguing this type of credit represents a “flow” of avoided emissions rather than a “stock” of stored carbon that can be released. Scientists reject that distinction, noting that the wood left unburned is still standing in a forest exposed to the same risks as any other.

At the online briefing, speakers also raised concerns that the tighter approach would be replicated for nature-based carbon projects with a direct impact on the future of large-scale forest conservation credits. The Conservation International advisor called it a “bad precedent”.

Both Conservation International and TNC run carbon credit programmes that aim to protect trees from being cut down**. **Labbate leads the UN-REDD programme, which supports countries developing forest protection initiatives including through carbon credits, and is co-chair of the expert panel advising the Integrity Council for the Voluntary Carbon Market (ICVCM).

After the webinar, the organisers shared by email a series of “key messages” and draft submissions produced by the three organisations, which participants were invited to consider and adapt in their own inputs to the Article 6.4 consultation process.

Getting the rules ‘right’

In a statement to Climate Home News, Ghana, Paraguay and the UK – which are FCLP co-leads for its work on forest carbon credits – said members of the coalition welcomed expert views from a range of partners to help them understand the potential impact of Article 6.4 rules on the eligibility of forest carbon credits in international markets.

They added that the FCLP does not have a common position on the rules and its members are free to choose whether to attend webinars and use any of the materials circulated.

In a statement to Climate Home News, Conservation International said “getting these rules right is important to the environmental integrity of the carbon market, while ensuring all sectors have a place in it”. It added that the NGO does not dispute the validity of the scientific research underlying the proposed buffer pool, but recommends a broader approach including multiple models and datasets.

A spokesperson for TNC said the organisation had helped clarify complex materials and their potential implications, while decisions on how to respond remained entirely with participating countries.

‘Inconvenient science’

The scientific basis for the disputed reversal risk tool rests on two pieces of research. A peer-reviewed study, published in Nature in May and led by scientists at several US universities, modelled forest carbon-loss risk across the United States and found existing buffer pools there are undersized by an average factor of six.

To extend that approach worldwide, the Article 6.4 panel also drew on a second, global analysis by the same research team, which has not yet completed peer review. That study used satellite images, weather records and computer modelling to estimate a 31-42% chance of forests worldwide losing stored carbon within 100 years, depending on the scenario.

The panel picked one of these scenarios and turned its estimates into fixed risk percentages for individual countries, and in some cases provinces, which projects in those locations would need to apply.

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Critics say the peer-reviewed portion of the research was calibrated on North American forests, and that applying the same approach to other regions relies on a global study that is still going through academic checks.

But, for William Anderegg, professor of biological sciences at the University of Utah and one of the authors of that research, it is the best science currently available. He described it as “light-years better” than assumptions underlying the voluntary carbon market, where risk numbers are not generally based on independent evidence and tend to be incredibly low.

Scientific research, including by Anderegg, has found that buffer pools in forestry projects in the voluntary carbon market are substantially smaller than they should be to adequately protect against future releases of carbon.

“There really seems to be a fairly coordinated campaign to try to weaken the strength of these [Article 6.4] tools and their scientific underpinning,” he told Climate Home News. “It’s a little dispiriting to see folks attack science that’s inconvenient.”

Regulators under pressure?

An EU diplomat told Climate Home News that experts and negotiators working on the Article 6.4 mechanism have faced intense pressure from big carbon credit developers and large parts of the nature-based solutions community.

“It is very clear that they are lobbying against strong rules, and they want to align the Paris Agreement mechanism with the standards of the voluntary carbon market,” the diplomat said. “They have influence, time and money, even more than some governments, so they can be very effective in their efforts.”

Last year, the Article 6.4 Supervisory Body, the new market’s regulator, approved rules on the permanence of credits aiming to remove carbon from the atmosphere which critics said were watered down compared to the technical panel’s recommendations. This followed feedback from carbon market firms and conservation NGOs, which submitted dozens of critical views.

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Carbon Market Watch’s Dossi said decisions that strengthen environmental integrity are targeted in particular as they tend to reduce the number of credits that can be issued.

Then, as now, those who opposed tighter rules argued that overly strict safeguards would make some projects too expensive to carry out, with a negative impact on local communities and the climate.

But proponents argue that higher-integrity programmes will drive up market prices, ultimately benefiting everyone.

“If rules ensuring better-quality credits make them somewhat more expensive than they are today, that’s an acceptable consequence, not a reason to weaken the rules, especially since these credits will be used to offset continued emissions,” said Dossi.

Efforts to pull the rule-makers in different directions are expected to intensify in the coming weeks as a decision on the new credit protection system nears.

“I really don’t know how this will turn out in the end,” one veteran carbon market expert said. “What I am sure about is that it will be quite a battle.”

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