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Extend LULUCF rules to all land uses and include soil emissions.

Annex I countries currently report greenhouse gas emissions resulting from human induced land use change activities and deforestation (LULUCF). These emissions should however become part the mandatory accounting for Annex I countries and should be extended to all land uses and include soil emissions such as from peatland degradation.

Clean Development Mechanism

At this moment, western countries can achieve their climate targets by investing in clean technology in other countries (CDM). Preventing emissions from the loss of carbon stocks in vegetation or soils are however limited. Ending degradation to avoid otherwise inevitable emissions of for instance degraded, drained peatlands cannot be carried out under the conditions of the CDM mechanism.

Accounting the total emissions in the life cycle of biomass (biofuels)

The Kyoto Protocol rules for accounting emissions make a rigid distinction between fossil fuels and renewable, zero emission fuels like biofuels. Emissions from combustion of biofuels are therefore not accounted for. Emissions connected to the production of biofuels (deforestation, loss of soil carbon, transport) are also often largely not accounted for in any country - as they take place in non-Annex 1 countries or from sources that are not included in the mandatory national accounting like LULUCF-emissions. This has led to the complex situation that the Kyoto protocol provides incentives to the use of biofuels that are in fact causing large emissions in their life cycle.

UNFCCC should therefore adjust to a mandatory system that accounts for emissions from biomass / biofuel combustion as for fossil fuels, unless carbon savings in the entire life cycle of the used biomass can be proven.

Address emissions from degradation of deforested and non-forested peatlands

The Bali Action Plan and the decision on ‘Reducing Emissions from Deforestation in Developing countries’ place the carbon dioxide emissions from ‘forest carbon stocks’ on the agenda for a post-Kyoto climate treaty (paragraph 1 b (iii)). This outcome of the UN Climate Summit provides for the first time a good opportunity to address the (so far ignored) huge greenhouse gas emissions from peatland degradation and loss. We welcome these first steps to develop policy approaches and positive incentives to reduce deforestation, reduce forest degradation and enhance forest carbon stocks; like peatswamp forest soils.

However forested areas are not the only areas that need to be addressed because of their immense carbon stocks. Deforested and non-forested peatlands should be addressed through measures to avoid further loss of the carbon in the peat soils, since these below-ground carbon stocks are often much larger than those of forest vegetation. The Roadmap seems to exclude the very large but threatened non–forest carbon stocks such as found in peat soils of tundra or non-forest bogs and fens.

The Contracting Parties of UN-FCCC should therefore also address formerly forested and non-forested peatlands to reduce carbon emissions and to conserve and enhance their carbon stocks.

Reducing deforestation: priority to remaining peatswamp forests

The UN-FCCC decision on ‘Reducing Emissions from Deforestation in Developing countries’ calls for direct action. Peatswamp forests contain extremely high amounts of carbon, not only in the forest cover, but primarily in their peat soils. These huge amounts of carbon are released to the atmosphere when peatlands are deforested and/or drained, exposed to direct sunlight or - in the worst case - burnt. Peat soil degradation globally leads to carbon dioxide emissions equivalent to more than 10% of global fossil fuel emissions

For reducing emissions from deforestation and enhancing forest carbon stocks, there is a need for the prioritisation of conservation of remaining peatswamp forests, including maintaining water levels to prevent oxidation of peat soils..


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