TICOS POSITION ON DOUBLE COUNTING AND ADDITIONALITY
TICOS took a very early decision that it would operate on a global basis. We seek to develop meaningful CO2 reduction programmes anywhere in the World. All of our projects also have wider environmental and social benefits. We recognise that where projects are developed in countries that are 'Kyoto compliant' viz. they have set national targets for CO2 reduction, there is a potential for double counting carbon reductions against both company targets and those of the national Government.
To avoid any confusion TICOS has formulated the following position.
- All TICOS projects are funded by voluntary contributions and donations and all companies working with us do so voluntarily. They and their customers do not have regulated targets so no TICOS offsets or reductions are a part of any regulatory process and therefore do not count towards any regulated statistics, for example the European Trading Scheme.
- We see it as natural and indeed a healthy role of voluntary action that where we have projects in Kyoto compliant countries elements of our CO2 savings will appear in national figures, for example where we reduce energy supplied through grid systems and where the overall use of petrol may be reduced by alternative fuels. This is no different to the fact that these figures will also include voluntary action by thousands of individuals and households who may use their cars less or install energy efficient light bulbs. We feel that Governments should embrace the fact that non regulated businesses and their customers should be seen to be helping to reduce national CO2 emissions. We do however feel that all voluntary action including that by TICOS should be over and above the targets set for regulatory purposes under Kyoto or any subsequent agreements. We recognize that if voluntary action becomes as strong as we would like there is a danger that Governments will reduce their regulatory demands as a consequence. We will watch this carefully and monitor any back sliding at the national level.
- Just as we are making it clear through the publication of this position on our website we will also make it clear to all companies working with us that the validated and measured offset figure we give them should not be added to or aggregated within any national statistics where there is a Kyoto compliant programme in place. All figures in such instances should be seen as a direct contribution towards the national CO2 saving statistics and not additional to them.
- As none of the CO2 benefits realized by TICOS are being sold or exchanged our retirement policy will ensure that there is no chance of double counting in relation to any financial transactions which we see as a key requirement.
- All TICOS projects will pass an additionality test as none of our work is required by regulation and in all cases the projects we support would not go ahead without our financial input. One of the defining tests for additionality is that projects funded by offset funds should not be a part of 'business as usual,' i.e. it would happen anyway as a natural part of business development. All TICOS projects will be over and above business as usual.
We recognise that there will be some who feel that we should not support projects in Kyoto compliant countries, especially those classed as Annex 1 countries (i.e. developed countries with legally binding reductions under the Kyoto protocol agreement). The reality is that TICOS is a programme of choice and many companies and their customers want to support projects 'close to home' or in countries they visit during their holidays. Whilst the substantial part of our project work will be in developing countries where our wider sustainable development objectives have greater benefits, we recognize that a tonne of CO2 removed in a developed country is the same as a tonne of CO2 removed in a less developed country.
We fully understand that there is a certain amount of controversy and uncertainty involved with the topic of double counting and additionality in the voluntary carbon offset market and many differing views. However we see it as crucially important to push the voluntary response to climate change forward in innovative and practical ways and to develop solutions as we progress. Where our chosen path is unclear or uncertain we will take the best advice we can and in many cases, such as the role of tree planting in CO2 sequestration, we will engage in research and debate to improve knowledge.
We recognise that our work has to fit into the broad and complex range of CO2 offset and reduction programmes and projects supported by Governments and agencies and we want to ensure that the TICOS contribution is both transparent and understood by those who use our services and those who benefit from them. Where we see action by others having detrimental interests to our work we will discuss these and seek change. For example it would be counterproductive for TICOS to support sustainable tree planting in any country that imported timber from unsustainable sources such as rain forests. We will also actively seek to make sure that all of the offsets we achieve are only counted once in Kyoto statistics.
TICOS is a constantly developing service, we are undertaking primary research in a number of areas and in discussion with those we respect about how to create a consensus for all voluntary offset project providers to avoid double counting and additionality. Our whole approach is to be transparent and to ensure that the companies working with us are in a position of choice; fully informed of the basis of our work and are given our best advice and due diligence in the execution of our work.
Dick Sisman
June 2007