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The following letter was sent to the chair and vice-chair of the Supervisory Body of the United Nations Framework Convention on Climate Change on February 28, 2023. 

Dear Ms. Qui and Mr. Dombrowicki,

The Institute for Agriculture and Trade Policy (IATP), a non-governmental organization accredited by the UNFCCC, appreciates the opportunity to submit this short comment prior to the March 7-10 meeting of the SB in Bonn. This letter concerns agenda item 2.2, paragraph 7, the approval of the 2023 work plan, with some reference to agenda item 3, paragraph 10, on “removal activities.”

As the SB is aware, controversies about the environmental integrity of land-based emissions removal projects continue to proliferate in frequency and scale, particularly regarding avoidance credits derived from forest conservation projects.

Carbon Direct's “Assessing the State of the Voluntary Carbon in 2022” concludes that "The Voluntary Carbon Market has a quality problem with the continued proliferation of risky project types." The proposals of the Integrity Council for Voluntary Carbon Markets (ICVCM) to enhance removal project environmental integrity by harmonizing certification protocols that issue Verified Carbon Units (VCUs) derived from these projects face many obstacles. Among them is the refusal by Verra, which issues about 75% of all VCUs, to cooperate with the ICVCM project.

However, even if the ICVCM succeeds in improving project and VCU environmental integrity, it will not have resolved the concern of prospective VCU buyers that the projects and VCUs lack “social integrity” to ensure Parties and non-Parties’ protection of human and land rights in removal projects. The COP27 CMA requires the SB to propose measures that would improve the social and environmental integrity of removals before they are converted to and issued as tradeable VCUs: "Activity participants shall minimize and, where possible, avoid, negative environmental and social impacts of an activity involving removals including impacts on biodiversity, land and soils, ecosystem health, human health, food security, local livelihoods, and the rights of the indigenous peoples, by following requirements to be developed by the Supervisory Body while acknowledging that the enforcement of environmental and social protection laws is a national prerogative of the host Party." The requirements to minimize and avoid these negative impacts are an integral part of this CMA recommendation, not to be postponed while the SB  deliberates the definition of “removals” and which removal techniques are proven to be efficacious towards meeting the 1.5C Paris Agreement objective.

Although the Parties hosting removal projects reserve the right to enforce or not enforce environmental and social protection laws, prudent buyers of Internationally Transferred Mitigation Outcomes (ITMOs), certified by Parties for sale to non-Parties, retain the right to perform due diligence investigations about the environmental and social integrity of the VCUs subsequently offered for sale. IATP urges the SB to revise its work program to recommend to Parties measures to provide documentation of compliance with social integrity requirements in ITMOs, which will affect how the private sector attempts to improve the integrity of VCUs. The SB should pair any recommendation for a COP28 Decision on removals with a COP28 recommendation for a Decision on methodologies to ensure the protection of human and land rights in the jurisdictions of removal projects.

To continue reading the letter, see here


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