Impact Assessment of LULUCF and Forest-Based Carbon Credits: A Response to DG Environment’s Staff Working Document

This paper responds to the assertions on land use, land­-use change and forestry (“LULUCF”) and forest­-based carbon credits of the Staff Working Document on an Impact Assessment accompanying the draft proposal for a Directive amending Directive 2003/87 on the EU Emissions Trading Scheme, which the European Commission’s Directorate General for Environment circulated last December 2007 (the “Staff Working Document”). The Staff Working Document is factually incorrect and reveals a bias against the contribution of sustainable forestry to climate change mitigation.

Among other things, the Staff Working Document fails to cite a single authoritative source for any of its broad assertions against LULUCF and forest­-based carbon credits. In fact, the unsubstantiated assertions contained in the Staff Working Document are entirely at odds with the scientific, economic and political consensus that has emerged during the last several years and which was emphatically endorsed at the 13th Conference of the Parties of the United Nations Framework Convention on Climate Change at Bali. This is all the more surprising as the material referred to below is publicly available and has repeatedly been brought to the attention of DG Environment’s staff during the last months.

Therefore, for reasons set out in this paper, policymakers should wholly ignore DG Environment’s impact assessment on LULUCF and forest­-based carbon credits.