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Carbon Market Watch response to the EU consultation on the 2030 Effort Sharing Decision
Carbon Market Watch responds to the EU consultation on the 2030 Effort Sharing Decision (ESD), opposing the use of EU ETS and LULUCF offsets to meet non-ETS targets. The organization argues that such flexibilities risk reducing the EU's 2030 climate ambition and delaying necessary mitigation. Instead, it proposes enhancing transparency in annual emission allocation (AEA) transfers, introducing a central auctioning system for AEAs to support lower-income Member States, and implementing a project-based intra-EU offset mechanism for transformative projects. The response emphasizes the importance of early action and calls for a comprehensive package of EU-wide policies in transport, buildings, agriculture, and waste to ensure the 2030 targets are met without compromising environmental integrity.
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Document type: Statement
EU LULUCF consultation
A coalition of environmental organisations urges the European Commission to adopt 'Option 1' for the 2030 Climate and Energy Framework, which establishes a separate LULUCF pillar. They argue that including Land Use, Land Use Change and Forestry (LULUCF) in the general 'at least 40 per cent' reduction target would dilute ambition by 3-7 percentage points. The authors call for the removal of fungibility between pillars, the use of base-period accounting instead of reference levels for forest management to expose bioenergy emissions, and the maintenance of agricultural non-CO2 emissions within a strengthened Effort Sharing Decision (ESD).
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Document type: Statement
FLEXIBILITIES IN THE EUS 2030 EFFORT SHARING DECISION
The document analyzes the EU's Effort Sharing Decision (ESD), which sets emission targets for non-ETS sectors (transport, buildings, agriculture, and waste). It argues that the 2013-2020 period was characterized by weak targets and overgenerous flexibilities, leading to projected overachievement without new mitigation actions. For the 2021-2030 period, the EU aims for a 30% reduction compared to 2005. The brief warns that certain proposed flexibilities—specifically the use of EU ETS allowances and forestry offsets—could increase overall EU emissions by up to 28% by 2030. It recommends focusing on early action, implementing EU-wide mitigation policies, introducing auctioning based on the polluter-pays principle, and restricting borrowing to avoid delaying climate action.
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Document type: Policy brief
The Land Sector in the First INDCs Intended Climate Contributions of the United States, the European Union, and Mexico
The Union of Concerned Scientists (UCS) evaluated the land sector (AFOLU) plans within the initial INDCs of the US, EU, and Mexico. The analysis finds a stark contrast between developed and developing nations: while the US and EU provide reasonable accounting standards, they lack specific action plans to realize their substantial mitigation potentials. In contrast, Mexico provides a highly transparent and ambitious plan, including a goal of zero deforestation by 2030 and a target for emissions to peak and decline by 2026. The report emphasizes that the land sector is critical for closing the global emissions gap, but current INDCs from developed nations are insufficient in detail to determine if their ambitions match their capacities.
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Document type: Report
Enhanced flexibility in the EU’s 2030 Effort Sharing Agreement: issues and options
The document argues that the EU's 2030 target of reducing non-ETS emissions by 30% relative to 2005 levels will create a significant gap between the demand for and supply of Annual Emissions Allocations (AEAs). It suggests that the existing 2020 flexibility mechanism is insufficient and proposes the creation of an AEA Clearinghouse to facilitate project-based trading, increase market transparency, and catalyze low-carbon investment in lower-income Member States.
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Document type: Research paper
TomorrowNow— Manitoba’s Green Plan: Toward a New Provincial Climate Change and Green Economy Plan Consultations Background Paper
The document outlines the context for Manitoba's transition to a new climate change and green economy plan, highlighting the province's emissions profile and the critical role of peatlands. It identifies transportation and agriculture as the largest emission sources and discusses the potential for peatlands to either sequester carbon or release GHGs depending on management. The paper also reviews climate policies in other jurisdictions and proposes principles for the new provincial strategy, emphasizing the integration of adaptation and mitigation.
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Document type: Briefing
VIEWS 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 opposes expanding LULUCF activities within the CDM, citing risks to climate adaptation, a lack of market demand for offsets, and the non-permanent nature of land-based carbon sequestration compared to permanent fossil fuel emissions. The organization suggests that LULUCF activities are better suited for Nationally Appropriate Mitigation Actions (NAMAs), National Adaptation Plans (NAPs), and REDD+, emphasizing a rights-based approach to food security and land rights.
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Document type: Statement
Analysis of Europe’s 2030 Climate Ambition
The report analyzes the EU's 2030 climate deal, which includes a binding 40% domestic greenhouse gas reduction target, a 27% renewable energy target, and a 27% energy efficiency target. Carbon Market Watch argues that these targets fall short of the 55% reduction required for a fair contribution to global climate goals. The analysis highlights significant risks to the 40% target, specifically the oversupply of EU ETS allowances (estimated at 2.6-4.5 billion by 2020) and the use of ETS allowances to meet non-ETS sector targets. It also criticizes the continuation of free emission allowances for industry and the provision of financial support to the power sectors of low-income Member States, which may prolong the use of coal.
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Document type: Report
Principles and recommendations: LULUCF and the EU climate and energy framework for 2030
The document argues that LULUCF should be treated separately in the EU's 2030 climate framework to prevent its carbon sink from being used to reduce mitigation efforts in energy, industry, and transport. It emphasizes that land-use policies must prioritize biodiversity and environmental integrity over simple carbon sequestration, specifically recommending the rewetting of peatlands and the end of subsidies for unsustainable farming. Globally, it calls for the EU to address its role as a major importer of deforestation-embodied products through mandatory standards and a new EU Action Plan on deforestation.
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Document type: Policy brief
Tackling 60% of the EU’s climate problem
The Effort Sharing Decision (ESD) covers approximately 60% of EU greenhouse gas emissions, focusing on sectors like transport, buildings, and agriculture. The document argues that the 2013-2020 targets were too weak, leading to a projected surplus of 600 million tons of CO2-eq by 2020. It recommends that the 2030 framework significantly increase targets to at least 45% below 2005 levels, exclude international offsets, and maintain a separate pillar for land use, land-use change and forestry (LULUCF) to avoid undermining overall climate ambition.
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Document type: Policy brief
TACKLING 60% OF THE EU’S CLIMATE PROBLEM
The document details the Effort Sharing Decision (ESD), which manages greenhouse gas reduction targets for EU Member States in sectors not covered by the EU Emissions Trading System (EU ETS). It explains how targets are set based on GDP per capita, the role of Annual Emission Allocation units (AEAus), and the specific reporting and compliance cycles managed by the European Commission. The report also outlines seven flexibility options—including banking, borrowing, and the use of Kyoto units—and discusses how the ESD interacts with other EU directives on renewable energy and energy efficiency, as well as the Kyoto Protocol.
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Document type: Report
European Council must close loopholes in the 2030 climate & energy framework
Carbon Market Watch recommends that the European Council increase the EU's 2030 greenhouse gas reduction target to at least 55% and permanently remove the surplus of over 2.5 billion emissions allowances in the EU ETS. The organization warns that carrying over this surplus could weaken the 40% target to a de facto 33% reduction. It further argues against the use of international offsets due to poor environmental quality and cautions that including land-use, land-use change and forestry (LULUCF) sectors as net sinks would undermine the effectiveness of the GHG target.
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Document type: Statement
Carbon Market Watch reaction to leaked 2030 Council Conclusions
Carbon Market Watch warns that a leaked draft of the 2030 Council Conclusions contains 'technical loopholes' that could reduce the effective EU greenhouse gas emission reduction target from 40% to as low as 26%. The organization specifically criticizes the potential banking of 'phantom pollution rights' (surplus allowances), the use of afforestation offsets for agriculture, the dynamic allocation of free permits to industry, and the possible inclusion of transport fuels in the EU ETS.
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Document type: Statement
Bonn Climate Change Conference – Report on SB 40, 4 – 14 June, 2014
The SB 40 conference in Bonn saw limited progress on reforming Kyoto Protocol mechanisms and defining a framework for various mitigation approaches, though 60 nations agreed to phase out fossil fuels by mid-century. Negotiations on the Clean Development Mechanism (CDM) and Joint Implementation (JI) were largely postponed to future sessions in Lima, while discussions continued on including land-use sectors in the CDM and the role of local stakeholder consultation.
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Document type: Report
Position sur REDD (Réduction des émissions dues à la déforestation et à la dégradation des forêts)
Friends of the Earth International (FoEI) opposes the REDD (Reducing Emissions from Deforestation and Forest Degradation) system, whether market-based or publicly funded. FoEI argues that REDD treats forests as mere carbon stocks, which ignores their social and cultural value and creates perverse incentives for deforestation. The document highlights risks such as the criminalization of traditional forest management, the displacement of communities, and the failure of carbon offsets to permanently reduce emissions. Instead of financial incentives, FoEI proposes strengthening the land rights of Indigenous Peoples and local communities, supporting collective forest management, and demanding that industrialized nations reduce fossil fuel emissions without relying on offsets.
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Document type: Statement
Friends of the Earth International Position on REDD (Reducing Emissions from Deforestation and forest Degradation)
Friends of the Earth International (FoEI) argues that REDD schemes, whether market-based or publicly funded, fail to address the root causes of climate change and risk harming the rights of Indigenous Peoples and local communities. FoEI contends that REDD commodifies forests, reduces them to 'carbon stocks', and creates perverse incentives for deforestation while enabling industrialized nations to avoid direct emission reductions through offsets. The organization advocates for the recognition of communal land rights and the empowerment of forest-dependent populations as the only effective means of forest conservation.
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Document type: Statement
The Three Salient Global Mitigation Pathways Assessed in Light of the IPCC Carbon Budgets
The document evaluates three prominent global emissions pathways against IPCC AR5 carbon budgets to determine their probability of limiting global warming to 2°C. It finds that only the highly ambitious 1.5°C marker pathway has a high probability of achieving this goal, while the 2°C marker pathway carries higher risks than previously believed, and the G8 marker pathway is insufficient to be considered a 2°C-compliant pathway.
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Document type: Briefing
Advancing Climate Compatible Development (CCD) for Food Security through the Implementation of National Climate Change Strategies
The document evaluates Honduras' National Climate Change Strategy (NCCS), highlighting its focus on reducing climatic vulnerability through a participatory framework involving over 60 institutions. While the NCCS identifies agriculture, soil, and food security as a priority sector, stakeholders report that implementation is in its early stages due to institutional, knowledge, and financial barriers. The report emphasizes the need for a territorial approach via Regional Development Councils to better integrate climate-compatible agricultural practices and access international finance.
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Document type: Case study
Watch this issue
The document argues that current emissions pledges from 42 developed countries, projected to reduce emissions by up to 4 billion tons of CO2e in 2020, are insufficient to meet the 2°C warming limit and are further undermined by accounting loopholes. It identifies five specific loopholes—including 'Hot Air' and LULUCF rules—and compares their cumulative size against the approximately 18 Gt of cumulative emissions reductions projected for the 2013-2020 period.
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Document type: Research paper
Second National Communication on Climate Change for Saint Lucia
The Second National Communication for Saint Lucia details the country's climate profile, reporting a 2% increase in total CO2e emissions between 1994 and 2000, totaling 579 Gg. The report identifies high vulnerability in tourism, agriculture, and water resources due to projected temperature increases (up to 3.6C by the 2090s) and rainfall decreases (up to 57% by the end of the century). It proposes two mitigation scenarios to reduce emissions by 19.6% and 25.7% by 2020, respectively, and outlines a series of adaptation measures including revised building codes, coastal setbacks, and integrated watershed management. The document emphasizes significant gaps in financial, human, and technical resources, calling for the mainstreaming of climate resilience into national development planning.
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Document type: Report