TICOS response to the kitemarking system proposed by DEFRA
We believe that the current proposed kitemarking system is inherently flawed for the following reasons.
- The idea of kitemarking individual projects rather than an overall programme is wrong. Some offset companies already use greenwash and can have a couple of kitemarked projects and many others that are not. Which are they going to use in their marketing?
- The fee structure is disproportionate for many of the small scale Sustainable Development projects which we encourage. These may only produce relatively low levels of emission reduction but massive behavioural change in energy use and wider benefits in reducing people's carbon footprints. We calculate that for us to kitemark our current project portfolio would cost us £200,000 per year. We cannot afford this and cannot pass it on to the thousands of individual customers who support our work.
- The kitemark only applies to Kyoto credits. The whole point of what we do is to encourage all tourism destinations and businesses to develop comprehensive climate change programmes of the type we are developing with Climate Change Scotland. We have to be free to develop projects wherever in the World we can. Often these are not Kyoto compliant but they achieve benefits outside of the regulatory market. These are high quality projects with some of the World's leading agencies and NGO's - yet none can be kitemarked under the current proposal.
- We are concerned that the kitemark will effectively only apply to the 'brokers' who buy and sell CER's. They do nothing personally to help individuals or companies to reduce their carbon footprint and do not contribute to any climate change programme. They simply act like stock market dealers or bookmakers. Buying and selling offsets from projects as a commodity is not something we favour. We would not like to see a kitemarking system that embraces these brokers.
- We see offsetting as one of the many tools we use and not an end in its own right. Without some form of direct linkage to climate change action we do not see a lot of value in the kitemark system.
The kitemark as proposed is really only about giving something for voluntary offset programmes to support the compliant market. This could be achieved far more simply and more cost effectively by kitemarking projects already agreed as CER's etc. This would overcome the need to kitemark providers. In a sense you would create a currency or brand and as with a tin of Heinz beans it would not matter if you bought it from Tesco's or the corner shop. It would still be the same quality protected by the brand.
Unless the kitemark proposal is amended to embrace the sort of projects we develop with and for the travelling public, it will certainly not be something that we will either support or encourage.
Dick Sisman
TICOS Founder
23 March, 2008