UK Government changing its position on voluntary carbon reduction and offset programmes

TICOS has lobbied the UK Government and its Office for Climate Change at great length to try to convince politicians and civil servants that voluntary action to tackle climate change by companies and individuals should be encouraged rather than simply seeking to place all initiatives within a highly "regulated" Government framework.

Following a major review of carbon offsetting and its role in the non regulated arena we are gratified, and not a little surprised, that members of the House of Commons Environmental Audit Committee have recently concluded that voluntary carbon offsets have a "useful role" in reducing emissions and engaging the public.   It recommends that encouragement and assistance should be given to individuals and organisations to offset their carbon.

TICOS will revisit this recommendation with Ministers and the Office for Climate Change to see how they will put this recommendation into practice.   We will certainly try to meet the Government half way in our own responses to the audit committee and list below some of their findings and conclusions (in bold) and our response to them:

"Encouragement and assistance must be given to individuals, organisations and companies to offset because robust and credible offsetting can have a useful if limited role in mitigating current levels of, and projected short-term trends in, emissions" Pg 3

TICOS recognises that carbon offsetting is only one of the tools in combating climate change and that other measures based on carbon reduction are important.   Offsetting does have immediate results and is an important tool in the overall scheme of things.

"One of the clearest messages we received in our evidence was that there is a lack of general understanding about the voluntary carbon offset market" Pg 6

TICOS has clear and informative information on its website about all of the technical issues and whilst we do not offer a service direct to the public we do include important articles and information from the press and other sources.

"Voluntary offset retailers have developed their own standards which create credits which use the generic term of Verified Emission Reductions (VERs). They share their acronym with Voluntary Emission Reductions and the two are often using interchangeably which can cause confusion as in one, the emissions reduction or saving has been verified, whereas in the other, this is not necessarily the case." Pg 10

We use the term voluntary offset to describe the fact that all of our work is undertaken with companies on a voluntary basis.   This simply means that our work is based upon the principle that it is done because companies want to do it and are not because they are compelled by regulation or legislation.   We use our own standard and verification system drawn up specifically to suit the needs and demands of the tourism industry.   We do not see that there should be any confusion between the terms verified and voluntary as they are totally different concepts and can be used separately or together.   All TICOS projects are both voluntary and verified to our own standard.

"We support the view that it is primarily individuals who have to take steps to avoid and then reduce their own carbon emissions. In parallel to this, however, we believe that the voluntary carbon offset market does have a role to play both in reducing carbon emissions and raising awareness of climate change issues to the general public. Moreover it can provide a much-needed source of funding for the development of low carbon technologies and innovations in developing countries" Pg 12

We have argued this with Government for many months.   Over 13 million people take overseas holidays each year and this provides us with a huge opportunity to showcase carbon reduction programmes in tourism destinations.   Most TICOS projects are in developing countries and all include wider social, environmental and pro poor benefits.   We have also added education to the list of requirements of our projects.

"The Government must set out its own view on the role that the voluntary offset market can play in reducing emissions and why offsetting is a positive thing. The view should be unambiguous, well-publicised and prominent in all Government communications concerning offsetting and climate change" Pg 12

TICOS will gladly assist the Office of Climate Change in spreading this message to the millions of customers served by the companies we work with.

"We urge the Government to explore measures which would incentivise businesses to encourage their individual customers to offset. We recommend that Government make it compulsory, for more carbon-intensive activities, for associated businesses to offer offset services either themselves or through a provider" Pg 13

We firmly believe that compulsion should be a matter of last resort and not a start position.   Any company able to demonstrate that it can reach or out perform Government targets through voluntary action should be exempt from any compulsory action.   In fact compulsion can lead to a lowering set of targets from those being achieved and will invariably mean companies and their customers bearing some central costs and bureaucracy which is unnecessary.

"It is often argued that offsetting might be seen as validating polluting behaviour. The Co-operative Group made the point that no substantial evidence is offered to support this thesis. Indeed out the of the 45 submissions we received, we found little substantial evidence to support the view that offsetting encourages ethical carelessness" Pg 14

We support the Co-op's position and assertion.   Although we firmly believe that many carbon offset programmes are expensive and that their programmes lack transparency or relevance to their customers we have seen no evidence that companies using such services take this action as a "licence to pollute".   In TICOS we always discuss with companies ways in which they can reduce their carbon footprint as well as offset.

"One of the strengths of the voluntary market highlighted to us in evidence is its ability to be a source of 'innovation' for the credits and projects operating outside the compliance market" Pg 16

We feel that this role of innovation is hugely important in addressing climate change.   The compliance market is narrowly drawn and limited in scope.   We regularly receive new and exciting project proposals which push at the boundaries of new thinking and technology.   The regulated compliance market is also totally lacking in any strategic vision, something we think is equally important to innovation.

"The rules and regulations of the compliance market are strict and often problematic for many smaller projects which do not have the funds, time or expertise to cope with the burden of administration" Pg 16

This is a clear problem in developing countries and in communities where putting together complex bids and proposals is difficult.   Language can also be a problem.   TICOS has a specialist team of experts to help any project proposer to gain access to us and to make application for funds.   Our project matrix is simple and structured to help applicants.

"The voluntary market is able to develop projects in different countries from where most of the compliance market projects are based, in particular in Africa where currently only 1% of CERs originate. Often, voluntary market projects have more 'value-added' characteristics than those found in the compliance market, such as additional environmental or sustainability benefits" Pg16

All TICOS projects have added sustainability values and we deliberately encourage new proposals and projects in Africa and other continents and regions where we see CER's failing.

"Verification ensures that the claimed emissions reduction by the project has been achieved. To ensure integrity of the resulting credits this should be done by an independent third party to an established protocol or standard" Pg 17

TICOS has its own independent verification expert and a set of standards.

"Some companies insist on the credits they retail (or projects they support or establish) having additional, sustainable development or environmental, benefits while others happily look no further than the direct GHG/carbon benefits, even if other benefits are not only lacking but the projects concerned possibly carry detriment to their local environment or society. In such a market there is a risk that mandatory regulation could either be so light and unspecific as to be ineffectual or so heavy and specific as to stifle innovation and retard growth" Pg 31

We share these concerns.   We have already been approached by communities in developing countries concerned that the growing of crops for bio fuels is damaging local agriculture and displacing families.   The CER market is helping to push the demand for bio fuels and even in the UK there is now a concern that the amount of wheat designated for climate change programmes will have an effect on food production.   We strongly argue that wider social and sustainable targets must be integrated into climate change action.

"It is essential that no credits should be retired which do not represent carbon savings already made. Credits should all be vintage marked and while future credits may be sold on to others they should not be retired until that vintage date is reached" Pg 54

TICOS issues annual certificates for all carbon savings made together with details of all other sustainable development achievements.

"Although offsetting alone will have only a minor impact at best on increases in global emissions as a result of air travel, the action of offsetting air travel may encourage better carbon behaviour overall" Pg 54

We fully support this view and believe that inviting customers to support and see offset projects in those destinations they visit will encourage better carbon behaviour at home.

"We support the Government's proposals to require all those selling air tickets within the UK to include in the price offered the cost of an offset, and to retail that offset along with the ticket unless the customer requests otherwise" Pg 54

This is the "opt out" process favoured by TICOS and we see no problems in Government encouraging all those involved in the supply of air travel to have an offset service available on a voluntary basis to their customers.   Whilst this encouragement should be strong - perhaps backed by incentives such as a reduction in APD for all customers offsetting - we do not feel that it should be mandatory.

Tree Planting

Tree planting and the saving of existing forests has been a problem in climate change policy.   NGO's in particular have taken conflicting and contrary positions which have discouraged many companies from supporting such programmes.

The following points made by the Audit Committee are helpful in providing guidance - if they are adopted by the Government.

"Some of the most rigorous and environmentally beneficial of all projects come from the stewardship of tropical forests and the well-judged re-forestation or afforestation of land in the tropics. Indeed, figures from the Stern and recent IPCC reports stress the significance of avoided deforestation, but also of reforestation, to avoiding dangerous climate change" Pg 4

"Well managed forestry projects, while they can be expensive, not least on account of their lengthy timescale and the need to deal with the risks of impermanence and leakage, can be as robust as other projects and invariably carry with them many of the additional benefits and environmental extras that consumers want to buy into" Pg 4

"There is no dissent about the need to keep the forests we have. Recent figures from the Global Canopy Programme's report Forests First in the Fight Against Climate Change have highlighted the massive contribution to GHG emissions from deforestation. The GCP report shows how deforestation accounts for 18-25% of global carbon emissions; and how emissions for deforestation between 2008-2012 are expected to be greater than the total of aviation emissions from the invention of the flying machine until at least 2025"Pg 36

"Anything that can be done through the mechanisms of offsetting--in the voluntary or compliance markets--to preserve existing forests, so long as the projects or methods are robustly grounded in good science and good practice, and allowances or credits made available are properly audited, has to be encouraged"Pg 37

TICOS has commissioned its own report "Forestry projects as voluntary carbon offsets" and will encourage and support new tree planting and the saving of existing forests as a part of its wide range of projects.

Dick Sisman
TICOS founder
31 July 2007