Recommendations for SBSTA Item 11(a) on Land use, land-use change and forestry under Article 3, paragraphs 3 and 4, of the Kyoto Protocol and under the clean development mechanism

Carbon Market Watch argues that LULUCF activities are currently unfit for market mechanisms due to data uncertainty, incomplete accounting, and risks of non-permanence. The organization recommends moving toward a land-based, net-net accounting approach using historical baselines rather than projected emissions. It further proposes that LULUCF sectors be managed through non-market measures under Article 6.8 of the Paris Agreement to better integrate adaptation and sustainable development goals, while calling for the exclusion of non-permanent activities from the CDM.

• Current LULUCF accounting is insufficient because the activity-based approach fails to capture all emissions and removals. Carbon Market Watch recommends transitioning to land-based reporting where gross emissions and removals are calculated separately, and the carbon-neutral status of biomass is removed to account for full life-cycle emissions.
• LULUCF activities are deemed unsuitable for carbon market mechanisms because of the complexity of measuring landscapes, which creates uncertainty for buyers regarding whether one credit equals one ton of emission reductions. Instead, these sectors should be treated under Article 6.8 of the Paris Agreement, which focuses on non-market approaches and holistic measures for sustainable development and poverty eradication.
• To address the risk of non-permanence in carbon markets, the document suggests either excluding non-permanent activities from compliance use or requiring the full replacement of both intentional and unintentional reversals indefinitely, or through the cancellation of the unit.
• The concept of additionality is criticized as being based on flawed methodologies, such as Forest Management Reference Levels (FMRL) which rely on projected emissions that can be overestimated to generate unearned credits. The document recommends replacing additionality with 'net-net accounting' using a land-based approach and historical baselines to accurately measure Nationally Determined Contributions (NDCs).

APA

Carbon Market Watch (2016). Recommendations for SBSTA Item 11(a) on Land use, land-use change and forestry under Article 3, paragraphs 3 and 4, of the Kyoto Protocol and under the clean development mechanism. https://carbonmarketwatch.org/wp-content/uploads/2016/11/Recommendations_SBSTA_Landuse_FINAL.pdf

Chicago

Carbon Market Watch. Recommendations for SBSTA Item 11(a) on Land use, land-use change and forestry under Article 3, paragraphs 3 and 4, of the Kyoto Protocol and under the clean development mechanism. 2016. https://carbonmarketwatch.org/wp-content/uploads/2016/11/Recommendations_SBSTA_Landuse_FINAL.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Recommendations for SBSTA Item 11(a) on Land use, land-use change and forestry under Article 3, paragraphs 3 and 4, of the Kyoto Protocol and under the clean development mechanism |date=November 2016 |url=https://carbonmarketwatch.org/wp-content/uploads/2016/11/Recommendations_SBSTA_Landuse_FINAL.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatch2016recommendations, author = {{Carbon Market Watch}}, title = {{Recommendations for SBSTA Item 11(a) on Land use, land-use change and forestry under Article 3, paragraphs 3 and 4, of the Kyoto Protocol and under the clean development mechanism}}, publisher = {Carbon Market Watch}, year = {2016}, month = nov, url = {https://carbonmarketwatch.org/wp-content/uploads/2016/11/Recommendations_SBSTA_Landuse_FINAL.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }