Picking up the REDD Tab

Brazil is at the forefront of a debate between those advocating the use of the carbon markets to save tropical rainforests, and others insisting that national and international funds should do the work. Ecosystem Marketplace looks south to find where the two camps are finding common ground.

Second in a series leading up to the 14th Katoomba Meeting in Mato Grasso, Brazil.

25 February 2009 | When the Katoomba Group gathers in Mato Grasso, Brazil for its 14th meeting in early April, it will find itself at the crux of a vital disagreement over how best to protect existing forests.

On one hand, we have the host Brazilian state of Mato Grasso, which contains some of the most threatened rainforest in Brazil. Last November, Mato Gasso signed a historic agreement with the US state of California to jointly pursue the generation of carbon credits to fund forest protection. The two joined five other developing states as well as the US states of Wisconsin and Illinois to develop the world’s first sub-national projects designed to Reduce Emissions from Deforestation and Degradation (REDD).

On the other hand, there is the host country, Brazil, which encompasses the forests of Mato Grasso and much more. The Brazilian government has publicly opposed funding forest protection efforts through a carbon credit generating mechanism such as REDD. Instead, it has actively courted donors for the Brazil Amazon Fund, a mechanism to protect forest cover that relies on contributions from countries and organizations.

This gap between the state and the federal government hints at a long-running rift in the forest protection crowd: Should forest-rich governments depend on donations from public and philanthropic sources to support protection efforts? Or should they seek to enter financial markets and let investors subsidize their work?

For a long time, many of the world’s leading conservation organizations remained as divided over the issue as the Brazilians.

Organizations like the World Wildlife Fund opposed focusing on the carbon market.

Staffers observed the well-chronicled problems in the European carbon markets and doubted these mechanisms had the muscle to fund effective reforestation efforts.

Plus, marketing forest protection as a commodity came with its own host of well-explored challenges.

“There wasn’t a system to measure forest degradation,” says Christine Pendzich of the World Wildlife Fund’s Forest Carbon Network Initiative. “You didn’t know what your baseline was and you couldn’t measure reductions (from forests).”

Meanwhile, organizations like Environmental Defense Fund (EDF) argued that private markets couldn’t be dismissed, because public donations would never be equal to the task.

“If the only way we think we can avoid deforestation is by the US Congress allocating funds, that’s not realistic,” says EDF’s Gus Silva-Chí¡vez. “We clearly see a huge problem with non-market funding.”

Now, outside of Brazil at least, this policy divide seem to be collapsing.

By the end of this year, delegates to the 15th United Nations Climate Change Conference in Copenhagen (COP-15) plan to have made final decision about forest protection’s place in the global compliance carbon markets, and players seem to be lining up under a shared reality: both mechanisms will be necessary to save the worlds’ forests and slow climate change.

“We are going to need a lot of money,” says Pendzich of the WWF, which has abandoned its opposition to using the carbon market to help protect forests. “We’re going to need it from many sources. No one funding source is the solution.”

“The old way of market versus non-market is unrealistic,” says Silva-Chí¡vez of EDF, which has dropped its opposition to non-market funding.

Now, EDF supports the kind of spending that helps pave the way to sell emission reductions from forestry initiatives.

“What we need to do is create the right set of incentives for developing countries to start getting money to get them ready for the market,” says Silva-Chí¡vez.

And so it seems the outlines of a consensus could be emerging: use non-market funds to lay the groundwork for an eventual market-funded incentive system. Employ philanthropic dollars and government money to prepare countries around the world to sell emissions reductions from forestry.

Now, the debate has shifted to what kind of non-market spending is needed to pave the way to REDD’s entrance to the carbon market – and how it should be done.

Capacity-Building

The most common answer you’ll hear is capacity building. That means doing to the fundamental dirty work that would provide the fundamental guarantees for any carbon market. And it is not the type of expense that really interests many investors.

“You have to have regulations, property allocations. Who owns this carbon? People want to know that,” says Pendzich. “It’s a whole big rural planning exercise once you start looking at it.”

Since Bali, a number of initiatives have begun to work with developing countries on this front.

The World Bank’s Forest Carbon Partnership Facility is working with thirty developing countries on capacity building, using $169 million pledged by eleven industrial countries to support the effort.

The United Nations has an entity called the UN REDD Programme Fund that has $35 million dedicated to capacity building as well.

It is also happening country-to-county. Earlier this month, Norway and Guyana announced a partnership where Norway will fund the South American country’s efforts to fight deforestation and prepare for the REDD markets.

But the sheer number of initiatives begs the question: Is this effort being properly coordinated?

“I think that’s one of the real problems,” says Silva-Chí¡vez. “You run the real risk of throwing money without knowing where it is going.”

Demonstrating Upside

Climate Focus director Charlotte Streck sees another problem with the widespread focus on capacity-building. It misses perhaps the most important role that non-market funding can play in jump-starting the market: demonstrating to countries a sense of what they have to gain.

“In Brazil, you have the political commitment,” says Streck, “but in tropical countries you don’t have a widespread commitment.”

For Streck, that means providing money to help developing countries choose their own consultants. It means investing in studies that can speak in economic and policy terms to the impact of this revenue on their budgets.

“It’s not a problem of monitoring, it is a problem of development,” she says. “People need to understand the benefits. That is a much more ambitious undertaking, but I think it is absolutely essential.”

Funding Demonstration Activities

While most non-market funding focuses on training governments, a new effort is focusing on training carbon market actors in developing countries.

Conservation International is in the pilot testing phase of a fund (a two-page overview PDF can be accessed here) designed to support field-based carbon demonstration activities.

The fund’s focus is on supporting the local communities and developers as they attempt to make “investment-grade” carbon projects in advance of investor demand.

“If you look at the more than 100 forest carbon projects and some REDD projects, they are all underfunded because they are living hand-to-mouth,” explains Ben Vitale, Managing Director of CI’s Conservation and Community Fund. “They can’t find the money to get through PDD (Project Development Document), verification and project start-up. We see that there is a gap in funding.”

Vitale says CI has raised a “significant sum” from a range of donors to support these efforts.

Meanwhile, Back in Brazil

So what to make of the conflict in Brazil? In one sense, the disagreement is unique to the country, but in another sense it could portend the future for the rest of the world.

Brazil, after all, is one of the few places where capacity building is relatively advanced. The Brazilians have established solid baselines and monitoring efforts for their forests.

In that respect, the national government isn’t an uneducated youngster, passing the hat to get schooled in the carbon market. It’s more like a college graduate with a sophisticated critique.

“They are concerned that industrial countries will remain at the status quo while Brazil does all of the work,” says Anthony Anderson, who is stationed in World Wildlife Fund’s Brazil office.

Instead of making binding commitments to future reductions, which would be required in the carbon markets, the Brazilians would prefer to take donations to support their protection efforts. These donations have performance benchmarks for future funding (i.e. no reductions, no more money) but they won’t make Brazil legally responsible if emission reductions don’t occur for any number of reasons, from poor management to rapid deterioration of the world’s climate.

Could other countries start making the same demands once they’ve learned the carbon ropes? Or will it be Brazil that falls into the fold?

With Brazil’s own states courting the carbon market, a resolution will be necessary.

“There’s going to have to be some kind of meeting of the minds on this,” says Anderson. “The Brazilian government has been known to change its mind in the past.”



Ted Rose is the principal of Rose Carbon LLC, which consults with companies and organizations on the renewable energy and carbon markets. He is based in Boulder, Colorado, and can be reached at [email protected].

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Additional resources

Payments for Ecosystem Services: Download the Primer

Payments for Ecosystem Services encourage entities that benefit from ecosystem services to pay for maintaining those ecosystems – but how? At the Biodiversity Conference (COP 9) in Bonn, Germany, Forest Trends, the Katoomba Group and the United Nations Environment Programme (UNEP) have jointly unveiled a nuts-and-bolts primer designed to answer that question.

21 May 2008 | Francis Ogwal has spent years trying to balance the opposing forces of economic development and environmental protection.   Now, as focal point for the Convention on Biological Diversity (CDB) within Uganda’s National Environment Management Authority, he believes he’s found a tool that help him do just that.

“Payments for Ecosystem Services (PES) are still relatively new in Uganda, but there is growing interest in that approach, because we have been relying mainly on the old method of provision of money for conservation from government and donors,” he said at the ninth meeting of the Conference of the Parties (COP 9) to the CBD. “But there is a lot of competition for these resources, especially in developing countries – where you want to put money into education, health, and agriculture – and conservation always ends up way down on the list.”

New Resource for Rural Poor

He was speaking at a side event introducing Payments for Ecosystem Services Getting Started: a Primer, which is now available for download.

The 70-page document was compiled by theKatoomba Group (parent of the Ecosystem Marketplace), Forest Trends, and the United Nations Environment Programme (UNEP), with contributions from the Division of Environmental Law and Conventions (DELC), and funded through UNEP by the Norwegian Government.

It is designed as a resource for people in developing countries looking to implement such schemes in a way that not only preserves and promotes ecosystem services, but does so in a way that empowers the rural poor of the developing world as stewards of an ecosystem service, for which they can be justly compensated.

Four-Step Process

The document covers the challenges of structuring programs that both deliver environmental benefits and benefit the rural poor, and its core is a four-step process for establishing PES projects. The steps include:

• Identifying Ecosystem Service Prospects and Potential Buyers
• Assessing Institutional and Technical Capacity as well as Access
• Structuring Agreements
• Implementing PES Agreements

Each of these steps is broken down into smaller steps in an effort to introduce potential sellers of ecosystem services to the details of PES deals. Throughout the document, there are numerous case studies to illustrate components of the process.

Not a Panacea

The document makes it clear that PES is not a panacea. Among the obstacles highlighted: high transaction costs, a lack of regulatory drivers, and lack of understanding among those who can benefit the most from such schemes.

“People have to understand that PES schemes won’t lead to a windfall of money, and that you can’t just go out, plant trees, and hope to get rewarded,” said Rahweza. “This is a learning process, and we are simply trying to provide a resource that will help people along that process.”

Eva Haden agrees. Water and Ecosystems Program Officer for the World Business Council for Sustainable Development, she said that industry has a long to go before funding of PES schemes takes place on a level anywhere near that of the booming carbon markets.

“At this point, there is just too much uncertainty – even about basic definitions of what constitutes payment for an ecosystem service, or what constitutes an ecosystem service,” she said. “Documents like this go a long way towards moving beyond abstract theory and providing some sort of common definition, but we have a long way to go.”

Steve Zwick is managing editor of the Ecosystem Marketplace. He can be reached at [email protected].

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Additional resources

Registries: Tracking the Trades

In the classic comedy The Producers, an unscrupulous businessman sells one product to scores of investors, each of whom believes they are the sole owner. In ecosystem markets, we call that “double counting” – and it’s what registries have been set up to prevent. Ecosystem Marketplace takes stock of carbon credit registries in the voluntary markets.

24 April 2008 | Max Bialystock is the carbon sector’s worst nightmare. He’s the character who, in the Mel Brooks classic The Producers, persuades scores of investors to back a single stage play – each thinking they own the whole deal.

The scam collapses, of course, and Bialystock ends up in jail – as well he should. Investor confidence is the cornerstone of any financial market. When that conficence suffers, we all lose.

And nowhere is that more true than in the market for environmental offsets.

After all, these are units of trade that represent verified economic good, and the amount of environmental good they create depends on that verification.

Carbon credit registries that track credit ownership are a cornerstone of that verification.

Registries: Public, Private, and In-Between

Here we take a look at registries that have been set up to track offsets in the voluntary carbon markets, but registries are by no means limited to this one sector. They have also been set up for compliance markets, such as the European Union Emissions Trading Scheme (EU ETS), which was designed to meet the needs of companies seeking to comply with the Kyoto Protocol.

Kyoto’s Clean Development Mechanism (CDM) has links to its own established registries, as does Australia’s New South Wales Greenhouse Gas Abatement Scheme (NSW GGAS).

In 2007, we found that many participants were utilizing their own organization’s specific registry – some of which are public. For example, the Carbon Neutral Company created its own type of online registry, which posts detailed information on projects contracted. Dom Stichbury of the Carbon Neutral Company notes that the company does not see its private online registry as a substitute for a third-party, multi-company registry. Instead the “registry was created to be as open as possible about the projects that we’ve contracted … and to contribute to increased transparency in the voluntary markets.”

In the latter part of this article, you will find links to all of the registries covered.

Emissions Tracking versus Carbon Credit Accounting

Dozens of greenhouse gas (GHG) registries exist around the world, and most of them can be divided into two different categories: emissions tracking registries and carbon credit accounting registries.

Emissions tracking registries identify emission reductions at the source, leaving others to track the credits once they enter the market.

“We’re measuring the beans, not tracking the trades,” says Joel Levin of the California Climate Action Registry (CCAR), an emissions tracking registry.

Because these registries help companies establish baselines and account for emission reductions, they’re a critical tool for both regulated and voluntary cap-and-trade systems.

Among emissions tracking registries up and running, the World Economic Forum has launched its Global Greenhouse Gas Registry, while Canada has the Canadian Greenhouse Gas Challenge, and the United States has the Department of Energy’s 1605(b) Program and The Climate Registry.

Carbon credit accounting registries, on the other hand, are designed specifically to “track the trades” – to follow the ownership of verified emission reductions (VERs) after they start getting bought and sold. Many carbon credit accounting registries utilize serial numbers as an accounting tool, and most incorporate screening requirements such as third-party verification to a specific offset standard.

Carbon credit accounting registries include the Bank of New York’s Global Registry and Custody Service, verifier TÃœV SÃœD’s BlueRegistry, and the New Zealand-based Regi (not to be confused with the US Regional Greenhouse Gas Initiative, or RGGI, pronounced “Reggie”).

Other registries are designed to underscore an exchange, such as the Chicago Climate Exchange (CCX) Offset Registry and the Asia Carbon Registry.

Then you have registries created by suppliers, such as the Carbon Neutral Company, as well as those created by third-party standard organizations, such as the Gold Standard Voluntary Registry.

The Environmental Resources Trust’s (ERT) GHG Registry and California Climate Action Registry cover both categories, tracking corporate emission reductions and carbon credits.

Carbon-Credit Accounting Registries: The Architecture

Registries themselves face the quandary of how to make sure they can trust the information they are receiving. Some focus on transparency, while others focus on levels of legal liability. Still others look at the “ethos” behind how reporting companies are contributing to the voluntary carbon marketplace.

This has led the registries to embrace different standards.

TZ1, for example, is a carbon registry and exchange based in New Zealand. Set to launch in June, it will accept credits verified to the Voluntary Carbon Standard and perhaps the Gold Standard.

TÃœV SÃœD’s Blue Registry, on the other hand, only lists credits certified to the VER+ standard, but plans to extend its registry services to encompass a wide array of different standards, such as the Voluntary Carbon Standard, Chicago Climate Exchange Standards, and the Gold Standard.

The Bank of New York’s Custodial Registry only accepts credits certified to the Voluntary Carbon Standard, and ERT’s GHG Registry doesn’t specify whether or not registered credits are screened by a specific standard.

The majority of greenhouse gas registries are designed as public or partially public databases. For example, stakeholders interested in tracking the sales or purchases of a particular company registered on the Environmental Resource Trust’s GHG Registry website will find that most of the information is publicly-available.

Alternatively, the Bank of New York registry is structured less like a public database and more like a bank account – something Alex Rau of Climate Wedge says is critical to many investors.

“Would you want your bank account open to the public?” he asks.

Getting Registered: The Costs

The cost of listing credits on an OTC registry varies widely, and is often difficult to pin down – especially when you factor in the way different registries bundle their services.

ERT’s registry process, for example, costs more than Regi’s and plenty of others, but often includes third-party verification, while Regi only accepts credits that have passed inspection by a certification service.

The Registry Roster

Here is a brief run-down of registries either up and running or in the works:
The Asia Carbon Registry (ACR) was developed in 2007 by the Asia Carbon Group (ACG), which provides carbon advisory, finance and asset management services under several different initiatives, primarily the Asia Carbon Exchange (ACX) and the Asia Carbon Asset Development Facility. The Registry plans to accept a variety of carbon credit types, including Voluntary Carbon Standard and Gold Standard credits. Currently, however, voluntary credits traded on ACX are simply third-party VERs. The scope of registry services includes electronic listing, transferring, and eventually retiring VERs.

The Environmental Resources Trust (ERT) GHG Registry is a relatively long-standing registry. Created in 1997, it tracks both “qualified emissions reductions” and actual carbon credits. Both buyers and suppliers can register credits, which they can either re-sell or retire.

In mid-2008, Canada’ Globe Advisors plans to launch the Globe Carbon Registry, which attaches serial numbers to offset credits and uses them to track ownership transfer and retire credits against end-users emissions. It’s designed around accepting credits verified to a third party standard, but will also accept credits verified to a ‘custom standard’ and provide users information on the criteria utilized.

The GHG CleanProjects Registry‘s chief objective is to list and de-list GHG reduction projects that result in Verified Emission Reduction-Removal credits (VERRs) for the voluntary and regulated markets. Participants in this Canadian registry may attach a unique serial number to each VERR representing one tCO2e. Because the GHG CleanProjects Registry is structured to track projects rather than serve as an accounting tool, however, serialization of verified emission reduction volume is not required. The VERR classification requires adherence to the ISO 14064 standards adopted in March 2006.

New Zealand’s new online voluntary carbon offset registry is a project of M-co and hosted by Regi. While the website is tailored to players in New Zealand’s voluntary carbon market, it will also consider foreign account requests on a case-by-case basis. The online registry was created to get a feel for how much demand exists in New Zealand’s voluntary market. Gold Standard credits are issued on a provisional basis until the Gold Standard Foundation establishes a Gold Standard Registry, upon which all of the information on Regi will be transferred to APX, which administers the trading platform. Regi has a high level of transparency, and the general public can visit its website and view the Certificate Summary Listing, which identifies the offset provider, project name, credit type and volume, and transaction status.

The Triodos Climate Clearing House is a project of Netherlands-based Triodos Bank, which focuses on financing “enterprises which add social, environmental and cultural value”. It claims to track”CO2 credits in a transparent, accountable and efficient manner.” The organization does not explicitly state a requisite for third party verification or certification, but it does state that qualified projects include activities involving “afforestation, renewable energy and energy efficiency” and was created, in part, to assure that credits cannot be double counted. Account holders include the Carbon Neutral Group and the Dutch Face Foundation.

The upcoming TZ1 Registry was created to underpin the TZ1 Carbon Exchange. It aims to act as a “meta registry” that combines and connects the systems of other major voluntary carbon market registries. Credits will be assigned a serial number. In addition to tracking trades, the registry will also include an externally-audited retirement facility for both VERs and Kyoto credits. Organizations listing information on the registry will be able to choose the level of transparency in their account.

Examples of Exchange, Standard, Verifier or Supplier-Specific Registries

Similar to other trading platforms operating in emissions markets, the Australian Climate Exchange (ACX) maintains an operational registry that facilitates transparent transactions in its “Electronic Emissions Trading Platform.” The “product listing process” that compliments the ACX Registry provides market participants with the ability to track emission credits along the supply chain, from project generation, offset verification, transaction status, and eventually retirement. Transparency is limited to ACX participants, but ACX is in the process of establishing trade mechanisms to facilitate international transactions of CERs and VERs.

The Bank of New York’s Global Registry and Custody Service for Voluntary Carbon Units was created to become a means of accounting for Voluntary Carbon Standard Voluntary Carbon Units (VCUs). It aims to streamline and legitimize the trading process of the standard’s VCUs. This centralized, electronic, and private accounting system stores VCUs, assigns each a unique serial number for tracking and verification purposes, and provides clear parameters for defining account ownership. The registrar requires certification under the Voluntary Carbon Standard and account information is not publicly disclosed.

TÃœV SÃœD, a German company that validates and verifies both Kyoto and voluntary emission credits, created the BlueRegistry. For now, the database only covers VERs certified by TÃœV SÃœD, but the goal is to become a “master” registry for voluntary carbon credits, including CCX CFIs and Voluntary Carbon Standard VCUs. The BlueRegistry is designed to be transparent, and will have publicly available information on factors such as credit-type, credit ownership and vintage.

The California Climate Action Registry (CCAR) was established by California law as a non-profit voluntary registry for greenhouse gas (GHG) emissions aimed at protecting and rewarding companies reducing greenhouse gas emissions before required by regulation. Building on its emissions reporting system, CCAR launched the Climate Action Reserve in April. A program designed specifically to track and register voluntary projects verified to CCAR Protocols, CCAR currently has approved protocols for livestock methane and forest activities and will soon release a natural gas transmission and distribution reporting and certification protocol.

The Chicago Climate Exchange registry is an accounting system for the CCX cap-and-trade program. Suppliers seeking to include their credits in the Chicago Climate Exchange’s (CCX) registry must first become members and then have their offsets approved by The CCX Committee on Offsets, which then assigns serial numbers to ensuing third party verified credits. Because the CCX system trades both emissions reduction allowances and project-based offset credits, the registry is both an emission reductions tracking program and carbon credit (in this case referred to as Carbon Financial Instruments) accounting system. The registry is somewhat transparent, providing publicly available information regarding the offset provider/aggregator, project type and location, as well as transaction volume.

In 2008, the Gold Standard Foundation joined forces with APX to create a registry that creates, tracks, and enables the transfer of Gold Standard certified VERs, ERUs, and CERs. The Gold Standard Registry for Voluntary Emissions Reductions aims to be a user-friendly, low-cost and transparent electronic database. Information about the status of credits (for example, if they are sellable or retired) can be accessed by stakeholders who register on the website. The registry features the serialization of each Gold Standard VER credit, a double-entry accounting framework, and full ownership and transaction tracking for VERs, CERs and ERUs.

Katherine Hamilton is the Associate Director of Ecosystem Marketplace. She can be reached at [email protected].

Thomas Marcello is a Research Assistant at Ecosystem Marketplace. He can be reached at   [email protected].

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The Matrix: Mapping Ecosystem Service Markets

17 June 2008 | Over the past decade, more and more businesses have come to recognize that man’s economy depends on the earth’s ecology, and that ecosystem services – from waste treatment and pollination to genetic resources – generate tangible benefits to industry.

Furthermore, because these benefits have gone unquantified, they have also gone unpaid for – and the ecosystems that provide them are in decline.

This has sparked a diverse array of efforts around the globe to value and pay for ecosystem services.

Many of these Payments for Ecosystem Services (PES) efforts – like the booming carbon markets – already channel billions of dollars into projects designed to keep the planet’s ecosystem infrastructure alive.

Others, however, are less developed.

Even in carbon – by far the most successful ecosystem market to date – the concepts are emerging, changing rapidly, and dispersed across geography and institutions.

All of which makes it difficult to get a clear sense of the big picture of these markets: What are the major markets for ecosystem services? How big are they? Who’s involved? Where are they heading?

 

Mapping the Markets

To map this PES landscape, the Ecosystem Marketplace researched the main PES schemes and each of their sub-categories (mandatory or “compliance” offsets for carbon forestry, voluntary offsets for carbon forestry, government-mediated watershed protection, and mandatory or “compliance” offsets for biodiversity, among others) and their key characteristics (size, environmental impact, community impact, market participants and shapers, and emerging trends).

To collect the information on such a broad spectrum of topics, we pulled together a team of authorities on PES, each of whom performed interviews, literature searches, and web searches to collect information for a specific category of market.

The result of this effort is a large spreadsheet showing all of the markets and their defining characteristics side by side. This poster-sized chart is a powerful tool for viewing and thinking about PES markets. We’ve dubbed it “the Matrix”.

To create a more reader-friendly format for accessing this information online, we’ve split the Matrix into ‘market profiles’ that are essentially executive summaries or narratives for each market.

 

Commodity Types

There are different ways of categorizing markets for ecosystem services. If you’re viewing them as ecological commodities, they follow the popular grouping of: carbon, water, biodiversity, and bundled services.

Carbon markets generally reward the stewardship of an ecosystem’s atmospheric regulation services – specifically, the absorption of carbon dioxide from the atmosphere.

Water markets provide payments for nature’s hydrological services – primarily the filtering of water through wetlands.

Biodiversity markets create an incentive to pay for the management and preservation biological processes as well as habitat and species.

Bundled payments secure all or a combination of carbon, water, and biodiversity services. Bundled payments also include those in which the ecosystem service payment is built into the price of the product, such as certified timber or certified produce.

 

Payment Types

If, on the other hand, you are viewing them as payment types, they fall into three categories: voluntary, compliance, or government-meditated.

Compliance markets are driven by regulation and enforcement, similar to other pollutant trading markets.

Voluntary markets are driven by ethical and/or business-case motives. In many cases, the threat of future regulation also drives these markets.

And government-mediated markets are publicly-administered programs that use public funds to pay private landowners for the stewardship of ecosystem services on their property.

 

Lay of the Land

The Matrix shows that while most PES markets are growing at approximately 10 to 20 percent a year, the carbon markets are skyrocketing at 200 to 700 percent a year.

While this is no surprise to most followers of environmental markets, carbon’s surge is a dramatic entrance for an environmental commodity onto the world markets, and perhaps indicative of the power of markets for ecosystem services.

 

Promises and Pitfalls

The participants and experts we surveyed said they believe existing markets have the potential to serve the environment – but may not be living up to their potential. This underscores that these payment systems are instruments that by themselves aren’t a solution.

PES, in other words, is not a single tool, but an entire tool box with different instruments for different circumstances.

To achieve the sustainable management of ecosystem services, PES schemes must be designed and implemented carefully, intelligently, and adaptively.

 

Spreading (and Tailoring) the Wealth

A recurring theme is the potential benefit for PES schemes in developing countries, as well as the necessity to tailor them to the specific circumstances of the region.

Many of the national compliance markets in developed countries require sophisticated regulation and enforcement to drive effective markets, such as species mitigation credits and water quality trading.

Developing countries, however, host a good number of PES schemes that are structured differently. The largest of these are the government-mediated programs in South Africa, Brazil, and China. China’s watershed protection program alone is estimated to generate $4 billion a year in payments.

 

Social Equity

Perhaps the most important example of how these markets must be crafted and managed carefully is the issue of social equity.

The majority of ecosystem services are produced in rural and natural areas where local communities depend closely on ecosystem goods and services and are the environmental stewards. It is clear from our research that an important aspect across all of these markets will be to ensure that the communities and small scale producers are able to actively participate and benefit from ecosystem service markets.

This will mean developing instruments to provide support, such as aggregation services to communities, shaping regulation to engage local small-scale providers, and clarifying tenure and user rights associated with these new opportunities.

There may be a large wave of investment opportunity in rural areas that are providers of these services. To make sure it is distributed fairly, organizations and overseas development aid groups that care about the equity dimension will have to provide a focused effort.

This is an important section of the Matrix and is reflected in the work of Forest Trends and the Ecosystem Marketplace.

 

Staying Oriented

A quick glance over the Matrix and through the pages of the market profiles will show that, indeed, there are a good number of initiatives attempting to value and pay for the services our green infrastructure provides. And with a closer look, informative patterns emerge in how PES are being applied in different circumstances.

We developed the Matrix to help members of the Katoomba Group and others working in this field to visualize and track the shifting global trends and nuances in PES – basically, to get oriented in the PES landscape.

 

Building a Database

To further this aim, we are developing an online database of the Matrix. This will provide convenient and current access to basic PES information provided in the Matrix. It will also allow for collaboration and data contribution, enabling the PES Matrix to be a living document under broad and continual update.

The Matrix products – chart, narrative, and online database – will aid in the evaluation and comparison of the different shapes and sizes of PES systems around the globe, creating a better understanding of what is being done, as well as where, by whom, and with what effect. We hope this will help refine existing PES systems and spur new and creative solutions.

Nathaniel Carroll is Biodiversity Market Adviser to the Ecosystem Marketplace and Forest Trends. He can be reached at [email protected].

Michael Jenkins is Publisher of the Ecosystem Marketplace and founding President of Forest Trends.

 

Additional resources

Climate Change and Forestry: A REDD Primer

One of the most contentious issues in the debate over how to tackle climate change is the role of REDD (Reducing Emissions from Deforestation and Forest Degradation) in market-based mitigation strategies. The Ecosystem Marketplace summarizes the key issues.

19 May 2008 | In 2007, more than 50,000 fires raged through the Brazilian Amazon, reducing what were once lush rainforests to charred plains stretching to the horizon. Meanwhile, on the other side of the world, fires on the island of Borneo consumed millions of hectares of old-growth forests.

Drenched by more than 75 inches of rain annually, neither the Amazon nor Borneo have ecosystems that are naturally adapted to fire. Instead, these fires were set with the express purpose of clearing the forest – to open the land for soy production and cattle farming in the Amazon and for palm oil plantations in Borneo. While fires consumed these forests harboring some of the world’s most diverse ecosystems, they released the carbon that had been stored in the trees’ woody matter for as much as 1000 years.

Land-use change, such as the conversion of Amazonian forests to industrial mono-crop agriculture, accounts for approximately 20% of global greenhouse gas emissions – more than the emissions from the transportation sector worldwide. The majority of these land-use change emissions come from deforestation in developing countries, where forests are being cleared for agriculture and timber. Currently, the international climate change community is considering how to create incentives for reducing emissions from deforestation and forest degradation – or “REDD”.

Forests and Carbon Emissions

Forests play an integral role in mitigating climate change. Not only are they one of the most important carbon sinks, storing more carbon than both the atmosphere and the world’s oil reserves, they also constantly remove carbon from the atmosphere through photosynthesis, which converts atmospheric carbon to organic matter.

But while forests are working diligently to clean up the carbon we have emitted through burning fossil fuels, deforestation is pumping carbon right back into the atmosphere.

The Drivers of Deforestation

Deforestation in developing countries is frequently driven by agriculture, logging, and road expansion. Rising prices for soy, palm oil, and beef make it increasingly profitable for landowners in developing countries to clear forests and convert the land to agriculture. Often, burning is the cheapest and easiest way to clear the land.

Contrary to popular belief, when logging occurs, only a fraction of the wood that is cleared ends up as dimensional lumber and eventually in housing and other structures. The majority of the forest vegetation ends up as waste, and thus the majority of the carbon from the forest ends up in the atmosphere.

And it’s getting worse as policies that expand road infrastructure provide access for loggers, farmers and homesteaders to the previously inaccessible forest interior.

Deforestation Highest in Indonesia and Brazil

Deforestation is not evenly distributed around the world. In fact, Indonesia and Brazil account for 50% of the world’s deforestation emissions. Because of these deforestation emissions, Indonesia and Brazil are ranked third and fourth among the top greenhouse gas (GHG) emitting countries. If Indonesia and Brazil were able to abate their deforestation, their ranking would fall to 15th and eighth, respectively.

The irony is that we normally associate high GHG emissions with development and increasing GDP, but the activities that drive deforestation generally have low economic returns. Thus, Indonesia and Brazil are among the top GHG emitters, but their emissions are from low-return activities.

Low-Cost Emission Reductions

Analyses examining the cost of REDD activities indicate that abating deforestation is one of the most cost-effective ways to reduce emissions. In their conservative calculations, the Intergovernmental Panel on Climate Change (IPCC) estimates that approximately 25% of deforestation emissions can be abated at a cost of less than $20 per metric ton of carbon dioxide (tCO2).

By comparison, the market price for carbon on the European Union Emissions Trading Scheme (EU ETS) was $35/tCO2 in the first quarter of 2008. It is important to note that the IPCC’s cost estimates are based on the opportunity cost of probable land uses and don’t include transaction costs such as monitoring, enforcement, and capacity building.

The Role of REDD

Given the magnitude of deforestation emissions and the low cost of abating those emissions, REDD is poised to play a very important role in the global strategy to abate GHG emissions.

“We cannot solve the climate problem if we do not include forests,” said Stuart Eizenstat in testimony before the House Select Committee on Energy Independence and Global Warming. A former Under Secretary of State in the Clinton Administration, Eizenstat now advocates the need to include market-based incentives for REDD activities in any future climate-change policy.

In addition to the benefits from reducing emissions, REDD activities can protect the biodiversity and important ecosystem services provided by tropical rainforests. Although Eizenstat and others see REDD as an opportunity to collaborate with developing countries to shore up a huge source of emissions at relatively low cost, there are no incentives to pursue REDD in any of the market-based mechanisms of the Kyoto Protocol.

Banishing REDD from Kyoto

In 1997, the Kyoto Protocol laid out target emission reductions and the different mechanisms by which countries could achieve those targets. In order to achieve target emissions levels, countries had two options: either take actions to reduce their own domestic emissions, or pay someone else to reduce their emissions and thus offset the country’s domestic emissions with reductions somewhere else.

The Kyoto Protocol established the rules and financing structures surrounding different types of offset mechanisms. At that time, the Parties to the Protocol excluded REDD from the offset mechanism because of uncertainties about the magnitude of deforestation emissions and the ability to monitor deforestation.

The Kyoto Protocol does recognize credits from reforestation and afforestation – the first being when you replant forests that have recently been chopped down or otherwise destroyed, and the second being when you plant forests that have either been gone for quite some time or never existed. Both can be used to generate offsets under the Kyoto Protocol’s Clean Development Mechanism (CDM), but only if they meet a narrow definition of success.

Because of their exclusion from regulatory markets, REDD credits have been limited to the voluntary market, where a handful of projects are generating credits. These credits are sold at a fraction of the regulatory market price to buyers concerned about reducing their carbon footprint for reasons other than compliance with the law, as documented in State of the Voluntary Carbon Markets 2008, published by the Ecosystem Marketplace and New Carbon Finance.

Bali: REDD Rising?

The outlook for REDD changed at the 2005 Conference of the Parties in Montreal. Costa Rica and Papua New Guinea, on behalf of the Coalition for Rainforest Nations, proposed to give developing countries access to the carbon market through credits generated from REDD activities. In response, the United Nations Framework Convention on Climate Change (UNFCCC) launched a two-year initiative to examine the potential of REDD. Those two years culminated at the 13th UNFCCC Conference of the Parties (COP 13) in Bali.

Officially, the Bali decision was quite modest. The Bali Action Plan formally listed REDD among other mitigation activities as a potential means to achieve emissions targets and encouraged voluntary action on REDD. The decision of whether and how REDD will fit into the international climate mitigation strategy was put off until COP 15 in 2009 in Copenhagen.

And yet, Bali was a turning point for REDD.

“Bali put REDD on the broader COP agenda,” explains Tracy Johns, Policy Advisor and Research Associate at Woods Hole Research Center. “Bali legitimized REDD as a tool for the UNFCCC’s broader strategy to mitigate climate change, and put it on the same track and timeframe as the post-2012 discussion.”

The Bali decision sent a signal that the international climate change framework will take on the problem of emissions from deforestation, but the financing mechanism is far from decided.

Still, the Bali decision encourages capacity building and the development of pilot projects. By ameliorating some of the uncertainty about the future of REDD, the Bali decision encourages developing countries and project developers to begin investing in REDD activities.

Three Shades of REDD

Broadly speaking, you can break all REDD activities into three categories: project-based, policy-based, and sectoral.

Project-based REDD activities would generate credits based on the maintenance of carbon stocks in a localized area.

Many of the current REDD projects focus on forest conservation that creates reserves and parks to protect threatened forests. These place-based REDD projects preserve the carbon stocks on a parcel of land that otherwise would be deforested.

Policy-based REDD activities would generate credits by reforming land use policies in a manner that would lead to reduced deforestation.

Emissions from deforestation can be reduced by land use policies. Agricultural subsidies, for example, often create incentives to deforest, and transportation networks provide access to clear forests and remove timber. Reforming land use policy could lead to significant reductions in forestry emissions, just as reforms in energy policy are expected to reduce emissions rates in the electricity sector.

Sectoral REDD activities would generate market-based credits by reducing net deforestation rates over an entire country.

A country or province could take on an emissions cap in the forestry sector in which they would commit to a target emissions rate from forestry. For some developing countries, actively pursuing emissions targets in the forestry sector might be the most appealing and powerful way for them to participate in the global effort to mitigate climate change. Eizenstat points out that the voluntary participation in sectoral targets in the forestry sector could create “a model for other developing countries to take targets in other sectors, such as electric power or transportation.”

These three shades of REDD – project, policy, and sectoral targets – capture the different scales at which REDD activities could be implemented, and each have their own set of strengths and weaknesses.

An Argument for Every Shade

Project-based REDD activities could be modeled after the forestry CDM, and there are a number of project developers ready to begin investing in REDD projects. However, the CDM model has its strengths and weaknesses.

Because REDD projects would be geographically-bound, they would be easier to implement than sectoral or policy-based activities. There are, however, also a number of technical challenge that must be overcome – such as minimizing and accounting for “leakage”, which is what happens when preventing deforestation in one place encourages it somewhere else. This is dealt with in more detail under the heading Technical Issues.

Further, emissions from deforestation account for 20% of global carbon emissions, and there is concern that there would never be enough REDD projects to have a meaningful impact on the large magnitude of emissions from deforestation.

In contrast to project-based activities, policies and sectoral caps that reduce emissions from deforestation may be better matched to the scale of the problem. Consequently, they would also require more coordination, and some countries don’t have a sufficiently strong central government or the proper governance institutions to monitor and enforce these programs.

In reality, countries currently have very different capacities on the ground to implement REDD activities. A climate change policy could allow a spectrum of REDD activities, creating incentives for countries to take actions at the most appropriate scale for them. All three shades of REDD face a number of technical and policy-design challenges that must be addressed to ensure an environmentally robust REDD mechanism. These challenges differ with each shade of REDD. For example, projects that maintain carbon stocks on a hectare of land would require different accounting mechanisms than sectoral caps that reduce emissions rates over a country’s entire forests.

Potholes on the Road to Copenhagen

Although uncertainties still linger, the technical sub-committee that focused on REDD for the two years leading up to Bali concluded not only that the magnitude of deforestation emissions was significant – approximately 20% of global emissions – but that sufficiently cost-effective methodologies exist for measuring forest carbon and monitoring deforestation.

Support of the measurement and monitoring methodologies was a significant first step in overcoming the technical challenges that face the implementation of REDD policies, but there are a number of additional hurdles (technical and political) that lie on the road from Bali to Copenhagen.

Technical Issues

Leakage means that preventing deforestation in one place might actually encourage deforestation somewhere else. It could, for example, take the form of the actual deforestation agents shifting their equipment and labor to a nearby patch of forest. But it can also be less direct. If REDD activities force up the market price of timber, livestock, and crops, they could drive deforestation somewhere else.

Unless all global forests are included in a REDD policy, leakage cannot be eliminated; however, it can be minimized through careful project design. Further, leakage can be accounted for by requiring that a percentage of a project’s REDD credits be held in reserve and not be sold (the so-called “buffer” approach). In this manner, the reserve account would offset or neutralize the leakage that was assumed to have taken place.

Concerns over permanence are rooted in the idea that emission reductions are potentially reversible due to forests’ vulnerability to fires, pest outbreaks, changes in management, and other natural and anthropogenic disturbances. However, the scale at which REDD activities are implemented affects the risk of impermanence. For example, as you move to policy- and sectoral-scale activities, credits would be generated based on net deforestation rates over some political jurisdiction.

As a result, you are not bound to maintaining forest carbon in any one specific location, and increases in deforestation in one place can be offset with reducing deforestation somewhere else. As you move to scale, there is greater flexibility in how land is managed, and there is greater impermanence in any specific site.

Too Much of a Good Thing?

Because REDD credits are expected to be relatively inexpensive, there is concern that a mechanism that incentivizes REDD activities will flood the regulatory market with cheap credits, deflating the price of carbon and shifting attention away from low-carbon technologies such as carbon capture and storage.

The realistic extent of this concern depends on the extent to which REDD projects can be implemented and begin generating credits. While the potential for REDD credits is high, it’s not clear how much of this potential could be realized in a timely fashion. In reality, because many countries need to develop on-the-ground capacity before they can begin generating REDD credits, fears of a deluge may be over-stated.

Even so, the decision about whether to include REDD credits in a cap-and-trade program cannot be separated from the negotiations about future emissions targets. More aggressive emissions reductions targets would neutralize any effects on the price of carbon.

Policy Design Issues

Even more challenging are the policy design issues that will decide the extent to which a REDD instrument will interact with the over-arching climate change mitigation strategy.

In 2005, the Coalition for Rainforest Nations proposed creating market based incentives for REDD activities – arguing that because market prices for agricultural goods drive deforestation in many countries, then international prices for carbon would drive forest conservation if REDD is allowed into a global carbon-trading scheme. This, they said, would offset the incentive to chop down forests for agriculture, while enhancing economic development.

Some countries, however, oppose linking REDD activities to the compliance carbon market and favor creating a fund where REDD activities would be financially rewarded. Proponents of the fund approach argue that linking REDD credits to the carbon market will delay the transition of developed countries to low-carbon technologies and will restrict developing countries in their ability to reform land use policies.

Additionality and Baselines

As if leakage and permanence aren’t difficult enough issues to wrestle with, how do you prove that a REDD regime actually saves a forest that is in danger of being chopped down?

The typical answer is “baselines”, which are the yardstick by which countries measure whether they have successfully reduced deforestation or not. There is confidence in the ability to establish historic deforestation rates based on existing remote sensing imagery, but many regions and countries argue that historic rates don’t indicate the current risk of deforestation.

For example, some countries currently experiencing political instability have a low rate of deforestation because the domestic turmoil suppresses access to forests and markets. They argue that deforestation pressure will increase if the domestic situation subsides, and that the historic baseline thus underestimates the real pressure on the forests.

And what about countries that have already taken action to prevent deforestation? Some argue that countries with low rates of deforestation should be rewarded to avoid creating a perverse incentive for these countries to increase deforestation in order to then qualify for REDD incentives. However, in order to maintain the environmental integrity of a REDD policy, credits can only be generated by additional reductions in emissions from deforestation, and these countries would have to be rewarded through other means.

Co-Benefits and Sustainable Development

REDD activities are often touted because of the added benefits that come with preventing deforestation, such as preserving ecosystems and encouraging sustainable development.

“Investors express a preference for and will pay a premium for projects that demonstrate social and environmental benefits in addition to robust climate benefits,” observes Joanna Durbin, Director of the Climate, Community & Biodiversity Alliance (CCBA) that developed a design standard for climate change mitigation projects to ensure the projects are designed to support sustainable development and biodiversity in addition to their carbon benefits.

Although the Bali agreement recognizes that “reducing emissions from deforestation and forest degradation can promote co-benefits,” Durbin and others are concerned that if REDD-generated credits move into a compliance market, the incentives for multiple benefits will be lost.

REDD policies promise to face all of the governance and equity challenges that have marked the international climate policy negotiations. The long-term success of REDD activities on the ground relies on ensuring that the priorities of forest-dependent communities are met and the benefits from REDD activities reach the communities bearing the burden of forest stewardship.

The Bali agreement recognizes the importance of forest-dependent communities, stating: “The needs of local and indigenous communities should be addressed when action is taken to reduce emissions from deforestation and forest degradation in developing countries.” However, critics argue that local and indigenous communities currently don’t have a voice at the negotiations table, and thus their needs are not being heard.

Two-Year Sprint

There is much work to be done. In December, 2009, the Parties will meet in Copenhagen to negotiate new target emission levels. Further, the parties will decide the mechanisms by which countries can meet those targets, including whether REDD will be incentivized through market-based incentives, or if REDD activities will be accomplished through a fund that rewards countries for measurable, reportable and verifiable reductions in emissions from forestry.

Though much ink will be spilled over the next 2 years addressing the technical and policy challenges facing REDD, the role that REDD will ultimately play in achieving global emissions targets depends on the on-the-ground capacity to implement REDD activities. “Readiness for REDD”, a term often used for the technical and institutional capacity to implement REDD activities, varies tremendously from country to country and province to province. In an effort to build capacity for REDD a handful of new initiatives have been launched to improve readiness among key developing countries.

Priming the Pump

At COP-13 in Bali, the World Bank launched the Forest Carbon Partnership Facility (FCPF), a $250 million fund focusing exclusively on REDD. In its first stage, the FCPF will help about 20 developing countries to build capacity to implement REDD activities. These capacity-building activities could include helping to assess national forest carbon stocks and sources of forest emissions, define past and future emission rates, calculate opportunity costs of REDD activities, and design REDD strategies. Australia launched a similar fund called the Global Initiatives on Forests and Climate (GIFC) that will focus on Southeast Asia and the Pacific.

The challenges facing the incorporation of REDD into mainstream climate change policies are not trivial. However, the potential rewards from getting it right stretch beyond the emission reductions themselves and include the sustainable development of forest-dependent communities and the conservation of some of the world’s richest forest ecosystems.

With the World Bank’s Forest Carbon Partnership Facility (FCPF), the Australian government’s Global Initiative on Forests and Carbon (GIFC) and other funds catalyzing REDD activities on the ground, and the clock already ticking on the UNFCCC’s countdown to a decision at Copenhagen, the next two years offer a unique opportunity to shape how the worlds forests can join the fight to mitigate climate change.

Erin C. Myers is a consultant for Resources For the Future and a Master’s candidate at the Donald Bren School of Environmental Science and Management – University of California, Santa Barbara. Questions or comments can be sent to [email protected].

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Wanted: Forest Carbon Projects for ForestCarbonPortal.com

Forestry advocates believe that halting the destruction of tropical rainforests is one of the easiest and most effective ways to slow global warming, and that’s led to a surge in development of projects designed to capture carbon in leaves, stalks, and bogs, but no centralized information hub for keeping track of all the activity – until now. Introducing: ForestCarbonPortal.com.

23 January 2009 | When Eveline Trines founded Treeness Consult in 2002, she was able to keep a running inventory in her head of all of the projects in the world that were offsetting industrial greenhouse gas emissions by capturing carbon in trees.

“Today, there’s no way,” she says. “You’ve got one initiative tumbling over the other, and the information stream is quite intimidating.”

And it’s bound to get more so as forest carbon projects evolve from ugly duckling to golden goose in the eyes of many project developers. The result is a torrent of information relevant to forest carbon, but no way to access the right resources.

To help meet the challenge, Ecosystem Marketplace recently launched the first phase of ForestCarbonPortal.com, an online information clearinghouse for the terrestrial carbon markets. Although still under construction, the site is active and can be viewed here.

SpeciesBanking.com for Trees

Like SpeciesBanking.com, ForestCarbonPortal.com is a satellite website to EcosystemMarkeplace.com and includes daily news posts, Ecosystem Marketplace articles, a calendar of events, and a “tool box” of the latest intro guides, curriculums, methodologies, software measurement tools and more.

In addition to news updates and a library of resources, the Portal also includes a first-of-its-kind Forest Carbon Inventory, which tracks terrestrial carbon markets. The Inventory also maps projects selling land-based carbon credits across the globe, and makes it possible for users to search for project sites by region, as well as by a variety of criteria such as project type, standard, registry, and credit prices.

Calling All Project Developers

The site only lists projects that have sold credits or have a publicly-available project design document (PDD), and all are described in consistent ‘nutrition labels‘ listing a range of criteria (click here for an example).

Forest Carbon Associate Maria Bendana has researched 250 projects so far, but only 30 have been posted – largely because verifying the information is a tedious process that begins with simple web searches and cold-calling, but ultimately involves analyzing project documentation. That tedium, she says, represents the true value to end users: because they won’t have to go through it themselves.

Potential Users See Promise, Challenges

Potential end users generally agree.

“I haven’t seen anything as complete and sophisticated as this,” says Trenes. “The need is definitely there – because the whole REDD (Reduced Emissions from Deforestation and Degradation) issue is so big at the moment, and it’s very difficult to cross oceans every time you think there might be an interesting project out there.”

One thing the Inventory does not include is projects that have not yet been developed. Katherine Hamilton, Managing Director at Ecosystem Marketplace explains that “the goal is currently to ensure information provided is accurate and to establish a dynamic list of active projects… so the site does not currently include pipeline projects. Instead we’re encouraging project developers to let us know if their project is not listed and to keep information updated.”

Joachim Sell, Head of Forestry and Biofuels for First Climate Group, is one voice asking for more. He says he’d like to see a sub-portal with more early-stage projects, even if they don’t have the degree of transparency necessary.

Room for Early-Stage Projects?

Sell says that his company looks for both issued credits and early-stage projects that want to sell carbon credits on a forward basis and then use the forward contract to attract further investments or as collateral to borrow money for further development.

“A main issue for the development of carbon forestry projects will be the availability of advance payments at risk, i.e. before the project is registered,” he says. “A platform with early stage projects could help to bring players together able to commit advanced payments that help to kick-start projects.”

Bendana, meanwhile, is asking project developers interested in getting their projects on the site to contact her – and trying to figure out how she’ll keep up with the paperwork if she gets what she’s asking for.

“I hope they will face that problem,” says Trenes. “It would mean a lot of projects are coming their way.”



If you would like to see your project showcased on the Forest Carbon Inventory map, or if your project is already on display and you have any corrections or additions, please contact Maria Bendana: [email protected].

Steve Zwick is Managing Editor of the Ecosystem Marketplace. He can be reached at [email protected].

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US WQT: Growing Pains and Evolving Drivers

With the Global Katoomba Meeting just weeks away, the Ecosystem Marketplace continues its series on Water Quality Trading schemes around the world. In this installment, we take stock of the key drivers in the US WQT Sector. Fourth in a Series

14 May 2008 | Earlier this year, the Township of Fairview, in York County, Pennsylvania, announced it was buying nutrient credits from nearby farms through Red Barn Trading Company rather than spend $6.4 million to upgrade its sewage treatment system.

In so doing, it became the first municipality in the Chesapeake Bay Watershed to meet its water quality improvement requirements entirely through Water Quality Trading (WQT).

The deal is projected to cost 75% less than an upgrade, and WQT advocates hail it as the kind of transaction that’s going to become increasingly prevalent in the Chesapeake Bay area and waters across the nation.

Skeptics might point out, however, that such trades are few and far between – and argue that if WQT transactions were all they’re cracked up to be, there’d be a lot more of them.

The World Resources Institute (WRI) has analyzed WQT programs in countries around the world, and believes the paucity of such deals simply reflects the types of growing pains common to all new endeavors – and that these growing pains are rapidly giving way to growth.

They’ve found, among other things, that projects were often implemented before key drivers were in place, that legal liability often exceeded rewards, and that an understanding of these markets was just beginning to take hold among stakeholders, decision-makers, and the public at large.

As this understanding spreads and kinks are worked out of the system, WQT schemes will be able to make more and more of an environmental impact. Here the authors examine some of the challenges facing the sector, and how they can be overcome.

Incentivization without Incentives

WRI research found that many WQT programs were developed in anticipation of regulatory caps that either never materialized or were too weak to create sufficient demand for trading. As a result, these trading programs experienced little or no trading – and some are still sitting idle.

Before investing the time and money needed to develop a WQT program, it is therefore critical to know whether regulatory requirements or voluntary motives are likely to generate the needed demand for credits.

More Risk than Reward

Regulated point-source entities, like industrial enterprises or urban waste treatment plants, face costly Clean Water Act (CWA) enforcement actions if their discharges exceed regulatory limits. Many, therefore, would rather pay for expensive upgrades that are under their control than leave themselves dependent on the performance of a third party from whom they have purchased credits.

If the seller of those credits is also a regulated point source, this issue can be resolved by transferring legal liability to the seller by modifying both the buyer’s and the seller’s discharge permits.

But it’s not so simple if the seller is an unregulated nonpoint source, such as a farm or new development whose pollution washes into a watershed over a diffuse area. That’s because you can’t transfer legal liability from a regulated point source to an unregulated nonpoint source.

This creates the risk that a credit buyer would be held in violation of its permit if an unregulated credit seller defaults on its contract. While the contract between the buyer and seller could protect the buyer financially in this event, it could not transfer the enforcement action, and the public disapprobation that goes with it, to the seller.

And that leaves buyers open to very real risk – for actual reductions from on-farm activities are difficult to estimate and are dependent on external factors like weather. Supply is thus variable and can depend on annual management decisions made by farmers, who are often unable to guarantee credits for long periods of time.

Current and developing trading programs address this risk primarily through three mechanisms: the aggregation of credits, the development of credit reserves, and the creation of reconciliation periods.

Bring on the Aggregators

Aggregators like Red Barn, which handled the Fairview deal, are unregulated and typically private entities that purchase credits for the purpose of re-sale to interested buyers, and they generally purchase large quantities of credits from nonpoint sources. They’re generally large firms that are willing and able to accept and manage the risks inherent in the water quality market. In that sense, they’re like retail grocers who know a certain percentage of their merchandise might go bad, or insurers who know a certain percentage of clients will lose them money, but by holding a large portion of available credits they can ensure the buyer of delivery.

By introducing an aggregator, the regulated entity severs its direct liability link with the potentially unreliable nonpoint source and increases its certainty that credits will be delivered as promised.

Many sell only a portion of their credit portfolio and keep the remainder in reserve in the event that one or more of the credit-generating projects fail or are not implemented as promised.

The Ecosystem Marketplace will take a closer look at the challenges faced by aggregators, and Red Barn in particular, later in this series.

Credit Reserves

In some cases, the state also plays a risk-mitigation role similar to that of aggregators. Pennsylvania’s nutrient trading program, for example, has created a centrally-administered credit reserve to mitigate risks to regulated buyers. This credit reserve effectively guarantees that a buyer who acts in good faith to secure credits will be able to draw from the reserve if his purchased credits are in default at the end of the water year.

In a similar measure, Virginia’s trading statute stipulates that credits will be available from the state in the event of shortfalls or defaults in the market. If a buyer is not able to locate credits at reasonable cost within its watershed, it can buy them from the Virginia Water Quality Improvement Fund.

Reconciliation Periods

Another risk that buyers face is that they may under-estimate their discharges when buying credits, and thus find themselves out of compliance at the end of the water year. After all, wastewater treatment plants are subject to periodic upset conditions: temperatures can affect the efficiency of treatment, and flow and concentration levels can vary from year-to-year.

For these reasons, regulated dischargers cannot predict with absolute certainty the number of credits they will need to buy (or how many they might be able to sell) in a given compliance period.

Here, the solution is to create reconciliation periods at the end of the permit cycle to allow regulated facilities to either purchase credits to make up for any shortfalls or to place excess credits on the market. These reconciliation periods work hand-in-hand with credit insurance pools and target a slightly different challenge than do aggregators and credit reserves.

A Nonpoint Measuring Stick?

Then comes the challenge of directly measuring the results of pollution abatement measures implemented at nonpoint sources. Absolute measurement is, quite frankly, impossible – but estimation methodologies do exist. This is, however, an area of vigorous debate, and it’s critical that such methodologies are defensible from a scientific and regulatory perspective.

The methodologies used to estimate the reduction in nutrient losses from agricultural practices can be difficult and time-consuming to develop, but much can be learned from the experiences of existing and emerging programs.

In the United States, for example, some trading programs use spreadsheet-based tools that incorporate nationally available algorithms (e.g., Revised Universal Soil Loss Equation) which are relatively straightforward to adapt to different watersheds.

The Chesapeake Bay Program has incorporated a set of long-term average agricultural loading rates and Best Management Practice nutrient removal efficiencies into its watershed model, while New Zealand’s Crown Research Institute, commonly known as AgResearch, has developed Overseer ®, a nutrient budgeting model to help estimate nitrogen and phosphorous losses from pastoral lands. This model is also national in scope, and could easily be used by other New Zealand catchments embarking on WQT. Estimation algorithms may be more difficult to transfer between countries, but they should be easy to transfer within a country.

Pinch the Pennies

It is also important that the transaction costs of trading be minimized. Necessary costs should be held to the lowest possible level without jeopardizing the integrity of the program, and unnecessary costs should be avoided or eliminated.

As trading program implementation goes forward, ways can usually be found to streamline the process and reduce transaction costs. For instance, the development of standardized language in regulatory compliance documents, the use of ‘model’ contracts for sales, and mechanisms to eliminate unnecessary delays and in general facilitate trade execution are all important for ensuring trading program viability.

The development of trading infrastructure may also produce easily-transferable material and tools, leaving little need to dramatically change the trading marketplace between catchments and countries. The use of existing marketplaces can decrease the time and cost of implementing that part of a trading program, allowing program developers to concentrate their efforts on more controversial and difficult areas.

Where are the Champions?

Developing WQT programs within the context of a stakeholder process is crucial to the success of any trading program. Often the lack of understanding about what WQT is — and what it is not — creates misconceptions and tension during the development and implementation phase of the program.

Early education of stakeholders on the concepts of trading and the goals of the trading program is important in order to ensure that the process runs smoothly and creates stakeholder buy-in and support. However, it is not necessary to “reinvent the wheel” when it comes to communicating trading concepts and creating elements of a trading program—to a large extent, these materials exist and can be ‘borrowed’ from existing programs.

The success of the stakeholder process will frequently depend on the process employed and the personalities of the stakeholders involved. The identification of a ‘trading champion’ can be useful in this context. A high-level elected official (e.g., a governor, head of environmental agency, council chairman, etc) can help motivate other high-level officials during the early stages of developing a trading program, while a local trading champion can generate enthusiasm for trading at the grassroots level and help push a trading program forward.

Many of the programs in the US that have languished have not had the support of important stakeholders. For example, Michigan implemented state trading regulations in 2002, but trading has languished since then because a change in governor brought in new government officials who did not see trading as a priority. Subsequently, the Kalamazoo trading program and others in Michigan have suffered several set-backs as a result of agency resistance to trading.

Where Next?

The prevalence of WQT programs has steadily grown and will most likely continue to do so. Water quality issues are on the rise — there has been a four-fold increase in identified hypoxic zones globally in the last 12 years (Selman et al., 2007) — and governments will increasingly look for new ways to deal with these problems.

While trading does not supplant regulation, it does provide methods to help dischargers meet their regulatory obligations at lower costs. Over time, there will be more standardization in trading programs and the infrastructure that supports them; and trading processes will become more streamlined and efficient. All of these developments are good news for those who believe that WQT schemes can indeed be a cost-efficient mechanism to help meet water quality goals.

Mindy Selman, Cy Jones, Evan Branosky, and Jenny Guiling are with the World Resources Institute, 10 G St, NE, Suite 800, Washington DC 20002, United States.

Suzie Greenhalgh is with the Landcare Research New Zealand Ltd, Private Bag 92170, Auckland Mail Centre, Auckland 1142, New Zealand.

This article has been adapted from a WRI analysis that is currently in publication.

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US Water Trading: The Infrastructure

As governments around the world experiment with market-based solutions to water pollution, they look for lessons to those who have gone before them. The Ecosystem Marketplace examines the structure of the US water trading markets, and takes stock of the lessons learned. Third in a Series

6 May 2008 | The United States has been experimenting with water quality trading (WQT) for more than two decades, and it’s now clear the schemes, while far from perfect, need not be a “license to pollute,” as some critics charge. Furthermore, WQT does not inevitably lead to the creation of pollution “hotspots,” nor is it a rollback of regulations, or an attempt to replace traditional permitting authorities.

On the contrary, our experience with more than 70 specific cases of WQT programs suggests that these schemes – if properly structured and implemented – can achieve environmental goals while reducing costs. You will find links to summaries and analysis of programs we feel have been done right under the heading “Water Trading: The Programs”.

Recipe for Success

WQT is an evolving discipline, but a handful of ingredients necessary for success have become apparent. The first three were enumerated by former US Environmental Protection Authority
Assistant Administrator for Water G. Tracy Mehan III in 2003: ensuring that trades create environmentally equivalent pollution reductions; ensuring that trading activity avoids hot spots (localized areas with high levels of pollution within a watershed); and ensuring that programs identify and use reliable estimation techniques for calculating nonpoint source pollution reductions.

Before delving into lessons-learned, we’d like to add two ingredients of our own: minimizing transaction costs, and making sure there’s an enforcement mechanism so that promised environmental benefits are, in fact, delivered.

This last ingredient is our first lesson-learned:

Lesson One: The Need for Authority and Clarity

One of the first lessons drawn from the US experience is that to encourage trading there needs to be clear authority to trade and clear legal protection for using the rights purchased (in the form of water quality credits) to meet established regulatory requirements.

One of the projects we’ll be examining, the Long Island Sound Nitrogen Credit Program , uses a state-sanctioned watershed permit to institute a trading program backed by state funds to guarantee trades.

Another program, the Minnesota River Basin program, incorporates point source-nonpoint trading into a legal document issued by the National Pollutant Discharge Elimination System (NPDES) to ensure the right of point sources to discharge as long as the permit provisions, including trading, are not violated. Other programs that have successfully traded pollutant reduction credits also have similar measures protecting program participants against legal uncertainties.

Lesson Two: Create Demand

To generate trades, demand for credits must be created.

The Piasa Creek Watershed and Minnesota River Basin trades that we will be examining were created by mandating a 100% offset requirement for point source discharges. The Long Island Sound and the Grassland Area Farmers programs set discharge limits for each participating source, generating demand for credits when water quality limits were exceeded.

On the other hand, the Lower Boise River program uses a pending TMDL reduction goal as the baseline and has not seen a single trade because of TMDL approval delays and no creation of demand.

Lesson Three: Flexibility (and not Trading for Its Own Sake) is Key

Trades are not necessary for trading programs to realize cost savings and achieve environmental goals. Water quality trading offers a flexible solution for point sources to phase in technology upgrades or optimize existing technology to meet more stringent discharge requirements.

This flexibility alone is sometimes enough to introduce substantial load reductions and cost savings. For example, the point source association in the Tar-Pamlico Basin program that we’ll be looking at, faced with collective load limits for phosphorus and nitrogen, was able to maintain discharge levels below the limits despite population growth; mostly via changes in in-plant management practices.

Even in the Long Island Sound program, clearly one of the more widely-touted U.S. programs, some of the credit sellers are wastewater treatment plants that have not yet implemented capital improvement projects.

Lesson Four: Plan, Plan, Plan

Program design is an essential element for success. The dual goals of any WQT program are: first, to achieve the targeted pollutant load reductions, and second, to do so cost-effectively. Most of the programs cited here have received wide local support precisely because they were carefully designed to accomplish load reduction goals.

However, overly restrictive regulatory controls on trading programs (such as a cumbersome approval process for trades and highly complicated credit quantification methods) will increase the cost of executing trades, diminishing potential cost savings. The current Kalamazoo River Watershed project is a comprehensive attempt to address these issues by designing trading tools such as an on-line registry – among others – to strike a balance between ensuring environmental gains and achieving cost savings.

Lesson Five: Focus on Social Benefits

Water-quality trading programs—besides introducing cost savings—bring other social benefits to the watershed. Examples of such benefits include: providing for nonpoint sources to undertake pollution control measures (e.g., the Tar-Pamlico Basin and Piasa Creek programs); and providing a solution to the conflict between economic development and environmental protection (e.g., the Minnesota River Basin program).

The Potential

The first installment in this series introduced the concept of TMDL, as well as point and non-point sources. If these concepts are new to you, it pays to go back and review Water Trading: The Basics.

Under the pollutant cap set for the watershed, and with maximum allowable discharges assigned to various sources, each watershed’s Total Maximum Daily Loads (TMDLs) create the regulatory foundation for a market where individual sources can trade their surplus allocations. In this, the program closely resembles the Acid Rain trading Program.

The annual cost savings that may be achieved through water quality trading as states throughout the U.S. seek to implement some 44,000 TMDLs are potentially significant: the U.S. EPA has projected them to be as high as US $900 million per year.

Point and Nonpoint

As explained in Water Trading: The Basics, most watersheds contain two types of polluters – “point” sources and “nonpoint” sources.

Point sources are the ones we hear about the most: industrial enterprises or urban waste treatment plants that directly pollute a watershed from a single pipe or point. Most point sources are regulated by the NPDES, and have been the cornerstone of water pollution control in the US since the passage of the CWA.

Nonpoint sources, on the other hand, account for a whopping 80% of the nitrogen and phosphorous that ends up in US waters – and most of these are unregulated, for a variety of political, social, economic, and logistical reasons.

We call the TMDL for point sources “Waste Load Allocation” (WLA), and the TMDL for nonpoint sources “Load Allocation” (LA).

Because many nonpoint sources are not legally required to limit their emissions (and therefore do not have permits), the marketable permits approach does not have the essential condition that economists have prescribed, i.e., both the seller and buyer have a limited amount of permit-allowable pollutant discharge over a pre-determined time frame. As such, point sources are almost always the buyer in the market. Nonpoint sources therefore have the market power to influence the price, creating an equity issue. Another consequence of this unequal regulation is that to execute and maintain a trade with a nonpoint source, point sources often use private contracts to hold the nonpoint source accountable for achieving the desired pollutant reductions. Contract negotiation and execution, however, add transaction costs to the trade.

The Emerging Legal Framework

Though cost savings with point source-point source trading may not be as high compared to point source-nonpoint source trades, the uniform regulatory condition stipulated by permits issued by the NPDES provides an ideal legal framework for point source marketable permits.

This permitting system provides a well-tested legal framework for assigning and enforcing pollution control requirements on point sources. By modifying NPDES permit provisions with trading specifications, water quality trading programs that involve point sources can be readily integrated into the current permitting system. In addition, monitoring to quantify load reductions is relatively simple and monitoring requirements are already part of most NPDES permits. This leads to easier government and public supervision, and greater environmental accountability.

An emerging driver that may spawn geographically broader trading programs is the development of phosphorus and nitrogen water quality standards that states must promulgate over the next several years. These pending standards will likely influence wastewater treatment plant permits under the NPDES. Where wastewater permittees are recognizing these forthcoming requirements (which will necessitate expensive treatment upgrades to Biological Nutrient Removal, or “BNR”) to address stringent effluent reductions of both phosphorus and nitrogen, active point source-nonpoint source trading is being initiated.

Water Trading: Where It Exists

Now let’s examine water quality trading programs in the United States that illustrate how these issues are (or are not) being addressed.

Below you see, on the left, an overview of states that have developed their own water quality trading policies, while on the right you will see an overview of states that have implemented programs at the watershed level:

map1   map2

Water Trading: The Programs

We’ve also provided analysis of several illustrative water quality trading programs in the United States. For details, simply click the links below.

The Great Miami River Trading Program is an Ohio-based point-nonpoint trading system launched in 2003. Its purpose is nutrient reduction.

The Long Island Sound Nitrogen Credit Program is a Connecticut-based point-point trading system launched in 2002. Its purpose is nitrogen reduction.

The Kalamazoo River Watershed Program is a Michigan-based point-nonpoint trading system launched in 1997. Its purpose is phosphorous reduction.

The Grassland Area Farmers Program is a California-based nonpoint-nonpoint trading system launched in 1998. Its purpose is selenium reduction.

The Piasa Creek Watershed Program is an Illinois-based point-nonpoint trading system launched in 2001. Its purpose is sediment reduction.

The Lower Boise River (Idaho) is and Idaho-based point-point and point-nonpoint trading system launched in 1998. Its purpose is phosphorous reduction.

The Minnesota River Basin Program is a Minnesota-based point-nonpoint trading system launched in 2003. It’s purpose is sediment and nutrient reduction.

The Tar-Pamlico Basin Program is a North-Carolina-based point-point and point-nonpoint program launched in 2003. Its purpose is nitrogen and phosphorus reduction.

The Way Forward

Despite past and current programs, water quality trading has not generated the vibrant national (or even regional) credit market that many had hoped. Nor can it really be compared, in magnitude or effectiveness, to the US Acid Rain Trading Program.

The reasons behind this shortfall in expectations are both physical and political. Unlike air pollutants such as SO2, water pollutants are carried by, and have their impact within, specific water bodies (streams, inland impoundments, estuaries). This limits water quality trading geographically to watersheds of various scales.

In addition, the mono-directional and linear nature of water pollutant transport and/or dissipation, makes water quality trades (if they are not properly implemented) particularly prone to creating pollution hotspots.

One way to avoid this problem is the upstream-only trading condition (where buyers can purchase credits only from upstream sources) that many of the current programs require. Such a requirement, however, further constrains the potential market size and lowers the liquidity of credits generated.

These factors work against the creation of the sort of wide-ranging, free-trading, national water quality credit market envisioned by economic theories and exemplified by the Acid Rain Program.

The Regulatory Challenge

On the policy or regulatory side, the uneven regulation and enforcement on different sources of water pollution (i.e., point sources vs. nonpoint sources) also limits the size and potential of water quality credit markets. With the regulatory burden largely falling on point sources –and pollution control mostly being voluntary for nonpoint sources—a fully regulated market can only exist among point sources.

This is particularly problematic for broader market development as nonpoint sources are one of the leading causes of water pollution in many U.S. watersheds. Without including nonpoint sources, water quality trading programs will not, in most cases, be environmentally effective.

Moreover, nonpoint sources, particularly agriculture, have lower marginal costs of load reduction compared to point sources. In other words, for water quality trading to work as some believe it can, it will be necessary to formally engage, incentivize and/or restrict nonpoint sources of water pollution.

Uneven regulation and enforcement create uncertainties and increase the risks for regulated buyers; all of which make it more difficult for them to participate in water quality markets. Private contracts go a long way towards solving this problem, but have the potential to substantially increase the transaction costs of trading and thereby depress market activities.

To overcome these obstacles, economists (e.g., King, 2005) have suggested that “tighter federal and/or state limits on individual dischargers” and “aggressive enforcement of those limits” will be required.

Nevertheless, even without a national market, past and current trading programs studied in this article suggest that water quality trading can and likely will continue to provide a powerful policy tool to solve local problems. In smaller scale trading applications, program design is often more important than the overall regulatory reform economists want to see.

In our more-than-thirteen years of trading policy and program implementation experience, trading has been a “bottom up” process where diverse local stakeholder groups have defined how trading can best serve their needs while explicitly avoiding these long-standing criticisms through local program design.

Offsetting Growth

With TMDLs specifying pollutant caps in watersheds, one area of opportunity for further application of trading in the US is for offsetting growth. Growth stresses the capacity of municipal wastewater treatment plants. In addition, federal storm-water regulations have begun to treat sources of storm-water as they do point sources: requiring NPDES permits for stormwater discharges from urbanized areas and most construction sites.

Stormwater and wastewater treatment often involve expensive capital investments and high operation and maintenance costs, resulting in high marginal costs of pollutant load reduction. This presents an opportunity for such sources to trade with other nonpoint sources, especially agriculture, where marginal costs of load reduction remain low. Again, such trading markets will be limited in specific watersheds where growth rate is high and agricultural operations account for a substantial portion of the total pollutant load.

Conclusions

Economic theories that have proven successful in air emissions trading programs in the US are being adapted for water quality trading for cost-effective load reductions. Water quality trading is a flexible tool offering a mechanism to achieve additional environment benefits when used in conjunction with traditional command and control approaches.

A permitted discharger facing high costs to accommodate new growth or stringent permit restrictions can “trade” for discharge reduction credits with another source having lower costs. A portion of the reductions traded may be explicitly retired, which addresses uncertainty and results in a net reduction of pollutants discharged to the receiving water.

Experience suggests that where there is an enforceable requirement for pollutant load reductions associated with high cost solutions, water quality trading can be considered as an option, provided trading is legally recognized by regulatory agencies.

Trading does face cost and technical challenges with program design and implementation. Thus, it is necessary to carefully address design issues such as transaction costs, environmental equivalence, hot spots, nonpoint source reduction quantification, and program enforcement for a functioning market.

It is clear, however, that the US has developed extensive experience on this issue through a variety of water quality trading projects that have taken place over the last two decades. Lessons learned from these experiences will hopefully lead to new innovation and provide guidance in addressing the most difficult issues related to water quality trading programs. This, we hope, will lead to water quality trading becoming a large and growing environmental market in the U.S. and eventually the world.

Mark Kieser is Acting Chair of the Environmental Trading Network, a non-profit clearinghouse for market-based environmental program information. He is also Senior Scientist and Principal of Kieser & Associates, LLC, an environmental science and engineering consulting firm in Kalamazoo.

Andrew Fang, Ph.D., former Project Scientist with Kieser & Associates and currently a TMDL Engineer with the Oklahoma Department of Environmental Quality.

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New US Federal Office Puts Ecosystem Markets at Forefront of Resource Management

Ecosystem Marketplace has long envisioned a world in which farmers and ranchers are paid to save natural ecosystems that filter water, sequester carbon, and preserve wildlife – in addition to growing corn and hay. Now the US Department of Agriculture has taken a giant step towards realizing that vision as part of a massive realignment of the management of natural resources.

18 December 2008 | It took the formation of the Securities and Exchange Commission to create a trustworthy market for securities in the United States, and it took the formation of the Commodity Futures Trading Commission to legitimize futures and options trading by offering clear regulations backed by the rule of law.

Now, a similar evolution is taking place in ecosystem markets, which supporters believe have the power to save the planets natural resources by identifying their economic value and encouraging Payments for Ecosystem Services.

The concept has progressed dramatically over the past two decades, with burgeoning markets for biodiversity and water quality emerging from California to Dar es Salaam.

In practice, however, the only real successes have come in cap-and-trade emissions schemes like the ground-breaking reduction of SO2 emissions in the United States and, of course, the massive carbon markets.

Time and again, experience has shown that such schemes hinge on government support and regulatory drivers – both of which have been sporadic in carbon trading and woefully lacking in both water quality and biodiversity trading.

Bringing Order out of Chaos

That looks set to change in the United States, where the Department of Agriculture (USDA), under a mandate embedded in the 2008 Farm Bill to promote incentive-based conservation, has announced the formation of an Office of Ecosystem Services and Markets (OESM), which will be headed by USDA Forest Service vet Sally Collins, who has won accolades for introducing market-based mechanisms into the Forest Service’s sustainable land management policies.

She will report directly to the Secretary of Agriculture, and the new office is charged with providing “administrative and technical assistance to the Secretary in developing the uniform guidelines and tools needed to create and expand markets for these vital ecosystem services,” according to a press release posted on the USDA’s web site.

Department of Homeland (Environmental) Security?

The OESM will also support the Conservation and Land Management Environmental Services Board, a massive oversight board comprised of the Secretaries of Interior, Energy, Commerce, Transportation, and Defense – as well as the Chairman of the Council of Economic Advisors, the Director of the White House Office of Science and Technology, the Administrator of the Environmental Protection Agency, and the Commander of the Army Corps of Engineers.

The makeup of that board is, obviously, contingent on appointments to be made under the incoming Obama administration.

Steve Zwick is Managing Editor of the Ecosystem Marketplace. He can be reached at [email protected].

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SpeciesBanking.com: For All Your Species Needs!

Real estate developers use species banks to offset their damage to nature by paying for newly-protected habitat. It’s the ultimate “green” industry, and one worth nearly $400 million per year, despite the lack of a centralized information hub – until now. The Ecosystem Marketplace hopes to bring the field into the 21st Century with SpeciesBanking.com.

10 December, 2008 | When Kellie Barry needs a species bank stocked with the right blend of birds and turtles to offset habitat destroyed by new development, she can usually find one more quickly than anyone else.

“I’ve been in this business for a long time, and Northern California is one of the most developed biodiversity markets in the world,” says Barry, Manager of Land & Entitlements for Pulte Homes in the US state of California. “I can usually find the right bank by making just three or four phone calls.”

But few have her background, and most buyers get lost more than once on their way to the right bank, says Craig Denisoff*, Vice President and co-founder of Westervelt Ecological Services. He believes the lack of transparency is preventing the market from delivering anywhere near the environmental benefits it’s capable of.

“Folks should be expending their resources evaluating the opportunities, and not digging around for them,” he says. “But the fact is that most folks just don’t know where to go when they need mitigation, and when they do find someone, they don’t know where to find competing providers. That has led to a bad reputation for the industry.”

“If you try to find out what all the conservation banks in the United States are doing, it’s beyond tedious,” says Ricardo Bayon**, who, as a Partner and co-founder of EKO Asset Management Partners, wants to invest in species banks across the nation. “It’s practically impossible for a single person to do it.”

Indeed, most buyers, researchers, and even regulators trying to get a grip on the state of species banking in any given part of the country spend countless hours surfing the internet or getting bounced around from one bureaucracy to another before finding someone in the right Department of Fish and Wildlife or Army Corps of Engineers branch who has an idea about which species bank might meet their needs.

Even then, they often find the bank they need has sold out or gone out of business – hardly the kind of efficiency you’d expect from a sector often touted as the ideal tool for supporting sustainable development around the world, and one with estimated turnover of $370-million-per year (or thereabouts, depending on who you talk to).

Bloomberg for Species Banking

If species banking is to deliver environmental benefits on a grand scale, it needs to be as transparent, fair, and open as the most advanced equities markets. To promote that transparency, the Ecosystem Marketplace is launching SpeciesBanking.com, an online information hub for bankers, buyers, researchers, and regulators.

The product of three years’ preparation and one year of tedious research, the site contains information and data on more than 120 US mitigation banks – including not only which species are being supported by which banks in which states, but also how much capacity the banks have and who the local regulators are. The site will even make banking documents available for download where possible.

“Think of it as a sort of Bloomberg for species banking,” says Bayon, who spearheaded the effort before leaving Ecosystem Marketplace in 2006.

“You could go out on your own and find information about every stock or every bond that you’re looking for through the SEC (Securities and Exchange Commission), but it wouldn’t be a fun process, and it wouldn’t be fast, and it wouldn’t be up-to-date, and it wouldn’t be tailored to your needs,” he says. “Bloomberg does all that for you, and presents the information in a way that makes it useful for investors and people who are actually in the business.”

If SpeciesBanking.com is analogous to Bloomberg, he says, the role of the SEC is filled by the Army Corps of Engineers, the US Fish and Wildlife Service and state or federal Environmental Protection Agencies (EPAs).

“They’ve gathered the information, or at least taken it down, but it resides in hundreds of filing cabinets spread from Sacramento to Austin to Washington, DC,” he says. “SpeciesBanking.com puts all that online for you in a way that’s useful and easy to understand.”

Phased Approach

The bulk of the gathering and sorting was carried out by project director Nathaniel Carroll, who culled the information from filings with local regulators and calls to individual banks.

Today’s launch is the first phase in a multi-stage roll-out that will see more and more data and functionality added over time.

For now, the site includes sell-side information on banks, but no information on buyers. It lists only North American species banks, and the information in the listings can only be altered by staff of SpeciesBanking.com.

The next iteration will make it possible for listed banks to update their own entries directly. Then comes the inclusion of wetland banks, followed by the inclusion of species banks from other countries.

Value to Researchers and Regulators

Though designed with buyers and sellers in mind, SpeciesBanking.com will also benefit researchers and regulators, according to Ken Sanchez*, the US Fish and Wildlife Service’s Assistant Field Supervisor for Sacramento.

“Species banking has really taken hold in just a few states, and I’m always getting calls from regulators in other parts of the US asking if it is credible and how to implement it,” he says. “They’re struggling with the same issues we did, and a site like this means we can get some policy out there so people don’t have to reinvent the wheel.”

George Kelly*, co-founder of Environmental Banc & Exchange, agrees, and adds that regulators in other parts of the world can also use the site to learn from early movers in the United States.

“This is not just a national exercise,” he says. “It’s an international approach that can inform the world about best practices – including voluntary initiatives.”

Prices: Elusive

One thing the site won’t yet be informing the world about are prices, which only three banks have so far agreed to post on SpeciesBanking.com.

“Pricing and other proprietary stuff is always going to be a sensitive issue,” says Sanchez. “We can only hope that people become more comfortable with pricing – after all, we all know what the invoice price of a new car is.”

Bayon agrees, but says banks have an incentive to withhold prices.

“The sellers want to charge what they want to charge, and they want to have the flexibility to charge different prices to different people,” he says.

“The challenge is that prices vary by location and by the amount you buy,” adds Denisoff. “We typically sell prices on a range, so if someone buys one unit, the price will be more than if someone buys 100 units – and that is the nature of any capital-based commodity.”

He and other project developers offer two other arguments for refusing to post binding bids and offers. First, they say, species offsets have not yet reached a degree of commoditization that would make such pricing practicable – and they may never do so. Second, they say that the community of buyers has not matured to the point of knowing what to look for.

“This is a customer base that doesn’t know if it’s getting a Cadillac or a Ford,” says Steve Morgan*, Chief Executive Officer and founder of habitat developer Wildlands. “Posting prices may eliminate dialogue with customers.”

Bayon, however, believes that more transparency – including pricing – will entice the buying community to evolve, perhaps by promoting the development of new intermediaries.

“It’s not a big repeat customer business,” he concedes. “But nobody knows what the dynamics are going to be – whether there are going to be aggregators or other entities entering the market whose expertise as buyers or brokers will make it worthwhile for sellers to offer as much information as they can.”

As an intermediate solution, several sellers say they’d consider posting a range of prices for various regions to entice contact from buyers. Such posting could be done individually or collectively.

“It could even be anonymous, so that you can populate the data for the price range,” says Kelly. “Or perhaps just do a poll of buyers and sellers, asking them what they see in the market.”

“If you create a mechanism where price discovery can occur, people will then be inclined to post prices even if they are just trying to test the waters,” says Michael Van Patten CEO and Founder of Mission Markets, which aims to build an electronic market for environmental products, including biodiversity offsets. “Whether or not anything trades is an entirely different matter”.

Market Integrity

Some worry that, as the site tries to follow the markets in real time and sellers have more leeway to change their own entries, the integrity of the information provided could be compromised.

“Rogue bankers may try to sell products they don’t have,” says Denisoff. “They’d do it for the same reason anyone does: to lock in sales.”

He says that pre-selling and forward selling are legitimate business practices – especially in mitigation banking, where buyers are often required to declare ahead of time where they plan to buy their credits. He worries, however, that SpeciesBanking.com could be used by aggressive providers who either overestimate their own capacity or under-estimate demand.

“If you tell a prospective buyer, ‘Hey, I don’t have these credits yet, but plan to in six months, would you like to buy some?’ that’s legitimate,” he says. “The problem is when you think you’ll have them, but don’t yet – and tell your buyer that you do.”

Denisoff believes the only solution is to work closely with regulators.

“This isn’t Wal-Mart,” he says. “We don’t have computerized inventory mechanisms, so we’ll have to forge close relationships with government agencies, who will be responsible for compiling information, certifying information, and hopefully having a group like this – the ‘Reuters of the environmental marketplace’ – able to tie it all together in a coherent fashion.”

Sanchez agrees, and says the site fits in with other evolving tools, such as the Army Corps of Engineers’ Regional Internet Bank Information Tracking System (RIBITS), designed to act as a sort of registry for wetland offsets.

“SpeciesBanking.com will be of more help on the marketing side, while RIBITS is a tracking device for the banks that we do have open,” says Sanchez.

“RIBITS was developed by the regulators for the regulators, so it’s sophisticated and pretty technical, while SpeciesBanking.com is more user-friendly for the buyers, sellers, students, and others interested in the market,” says Carroll, adding that he is considering the possibility of tying SpeciesBanking.com into existing post-trade providers.

“A solution we are considering and could fairly quickly implement is partnering with a registry company like APX or TZ1 to set up a robust registry system to ensure that credits are above-board and no one is trying to sell the same credit twice,” he says. “This would still require working closely with regulators, but would likely take a lot of the burden off of them.”

Standardizing the Market and Building an Exchange

Carroll emphasizes that SpeciesBanking.com is not an exchange, but rather an information portal designed to support an evolving marketplace.

Van Patten, however, believes the site will create the kind of information flows that could make an electronic exchange for biodiversity markets feasible.

“The timing for Speiciesbanking.com is perfect, as many in this space will depend on this data as a key information source within the biodiversity markets,” he says.

Going Global

In addition to the challenge of balancing the desire for real-time information with the need for accuracy, the site – and the team behind it – will face the challenge of scaling up when adding the larger wetlands banking sector to the mix and going global.

“I don’t think going international will be particularly difficult, because there’s not much going on globally,” says Bayon. “It’s really a data collection process – that’s where the intense labor is, and outside the US there’s just not much data to collect.”

Expanding to wetlands trading, however, is a different animal.

“Species mitigation is a $200-$300 million per year business, and there are only about 100 conservation banks,” he says. “Wetland mitigation, however, is a $3.3 billion-per-year business; the banking segment is $1 billion, and there are nearly 1,000 wetland banks, so it’s much more difficult.”

Some say it’s not just a challenge of scale, but of type.

“Of course it’s going to be very time consuming, because you have more volume,” says Kelly. “But you could also get into some issues with the Corps in terms of how they view this. Will they view this as a regulatory sanction of what’s out there, or just as generalized information coming in thru discretionary data?”

All of these are questions that will be answered in due time. For now, however, Ecosystem Marketplace invites all readers to peruse the first iteration of SpeciesBanking.com.



*Denisoff, Kelly, Sanchez, and Morgan are all members of the SpeciesBanking.com steering committee. We chose to interview them because they are among the few who have had a chance to review SpeciesBanking.com. They have no commercial interest in the Ecosystem Marketplace and have generously volunteered their time.

** Ricardo Bayon is a co-founder of the Ecosystem Marketplace and a member of the SpeciesBanking.com steering committee.

Steve Zwick is Managing Editor of the Ecosystem Marketplace. He can be reached at [email protected].

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Mitigation of Impacts to Fish and Wildlife Habitat

Every year, human activities cause significant – but often unaccounted – harm to fish and wildlife habitat and the environment. Now a new report from the Environmental Law Institute examines laws and programs that can require monetary or in-kind compensation for these impacts.

28 March 2008 | In October, 2007, the Environmental Law Institute (ELI) released Mitigation of Impacts to Fish and Wildlife Habitat: Estimating Costs and Identifying Opportunities, that draws on available data to estimate, for the first time, an annualized dollar amount of damages to habitat and the environment that are captured under the major federal compensatory mitigation programs.

In addition, the report highlights opportunities to use the fifty State Wildlife Action Plans to direct these compensatory mitigation funds in a manner that could support state, regional, or local conservation objectives; and, in so doing, to help conserve fish and wildlife species and biodiversity nationwide and over the long term.

For the most part, funds collected under these federal laws are reactively allocated on a permit-by-permit or case-by-case basis, with minimal regard for how they might be used to piece back together the fabric of the biological landscape. However, a proactive tool has emerged with the potential to address this problem: each of the fifty states is required to develop a State Wildlife Action Plan under federal legislation that established the Wildlife Conservation and Restoration Program and State Wildlife Grants Program.

The plans provide scientific data and identify priorities for conserving fish and wildlife habitat – information that potentially could be used to direct the allocation of compensatory mitigation funds from other programs.

Cost Estimates

Using the best available data and reasonable assumptions for each program, ELI estimates that the annualized cost of compensatory mitigation conducted under key federal programs nationwide is approximately $3.8 billion. In order to understand fully what this aggregate number represents, it is essential to review the detailed conclusions and methodology laid out in the original report. The following summary describes the program-by-program estimates:

Estimated Annual Compensatory Mitigation Costs Expended or Committed Under Major Federal Regulatory Programs Regulatory Program or Authority Cost Estimate (in millions)

Clean Water Act Section 404 $2,947.3
Endangered Species Act Section 10 $370.3
Federal Natural Resource Damage Programs $87.7
Federal Power Act $210.3
Northwest Power Act $207.1
Total: $3,822.7

The statute-by-statute breakdown of these mitigation costs is summarized below:

Section 404 of the Clean Water Act

Section 404 of the federal Clean Water Act is the primary mechanism by which activities in wetlands and aquatic resources are regulated. ELI’s dollar estimate for Section 404 compensatory mitigation considers both wetland and stream mitigation. With respect to wetland compensation, the figures were aggregated from disparate data that reflect the inherent variability in mitigation costs due to regional location, the mitigation mechanism (permittee or third-party), and the different methods of mitigation used (such as creation, restoration, enhancement and preservation). The available data for stream compensation are less detailed.

Working within these data constraints, and using FY 2003 as a baseline, ELI’s initial aggregate estimate of wetland mitigation costs across all regions of the country ranged between $2.5 billion and $4.4 billion, with a likely midpoint of approximately $3.4 billion. Adjusting these estimates to account for the probable mix of different methods of wetland mitigation used then reduced the bottom-line range to approximately $1.7 billion to $3.1 billion, with a mid-range estimate of about $2.4 billion. ELI further estimates that the total FY 2003 cost of stream mitigation was between $179 million and $955 million, with a likely mid-point of around $573 million.

Combining the two estimates for wetland and stream mitigation suggests that the total amount spent on aquatic resource mitigation under Section 404 of the Clean Water Act in FY 2003 was between $1.9 billion and $4.0 billion, with a probable midpoint of around $2.95 billion.

Section 10 of the Endangered Species Act

Under Section 10 of the Endangered Species Act (ESA), non-federal entities may receive a permit from the U.S Fish and Wildlife Service or National Marine Fisheries Service for the “take” of listed species, provided that the take is “incidental to, and not the purpose of, the carrying out of an otherwise lawful activity.” These incidental take permits and their associated habitat conservation plans require that permittees minimize and mitigate their impacts to listed species and habitat “to the maximum extent practicable.”

Federal data on mitigation costs associated with Section 10 habitat conservation plans and incidental take permits (HCP/ITPs) are available, although they are not complete. ELI’s estimate for the annualized commitment of funds to compensatory mitigation is based on an examination of the 65 HCP/ITPs approved by FWS in the years 2003 through 2006. These HCP/ITPs required permittees to commit a total of $1,481,345,433 in mitigation expenditures over the duration of the HCP/ITPs, for an average long-term commitment of $370.3 million per year.

Natural Resource Damages

Parties responsible for injuries to the environment, such as oil and chemical spills or leaks, may be held liable under one or more federal laws for the cost of removal and remedial actions, as well as the cost to restore the natural environment. Depending on the source and location of the injury, NRDs may be assessed under any of five federal laws: the Comprehensive Environmental Response, Compensation, and Liability Act, the Clean Water Act, the Oil Pollution Act of 1990, the Park System Resources Protection Act, or the National Marine Sanctuaries Act. ELI’s dollar estimates for mitigation required for NRDs include both the costs of injury assessment and restoration.

The data on NRD settlements are relatively complete compared to other programs, which allowed ELI to consider a wide range of years (1997-2005) to produce an annualized average figure. These data, combined with data for a somewhat different range of years for the Oil Spill Liability Trust Fund, suggest that, on average, about $87.7 million was expended annually for natural resource damages under federal programs.

Federal Power Act

The Federal Energy Regulatory Commission (FERC) issues and renews licenses for more than 1,000 non-federal hydropower projects under the Federal Power Act. To receive an original license, renew an old license, or surrender a license, a hydropower project must comply with conditions designated by FERC, which may include environmental mitigation requirements. The mitigation actions that are mandated under a license typically include a mix of measures intended to prevent harm from occurring and to compensate for harm to fish and wildlife habitat.

The best available data on compensatory mitigation required by hydropower licenses come from Environmental Assessments (EAs) and Environmental Impact Statements (EISs) issued by FERC during the licensing process. During the years 2003 through 2006, FERC issued a total of 70 EAs and final EISs that itemized recommended mitigation measures. Aggregated, these EAs and EISs on average recommended an annual commitment of $210.3 million to compensatory mitigation, including the cost of measures that would be spread out over the lifetime of the licenses.

Northwest Power Act

Federal hydropower projects in the Columbia River Basin must comply with the Northwest Power Act (NWPA) which, in addition to encouraging the development and conservation of electric power, seeks to “protect, mitigate and enhance” fish and wildlife in the Columbia River and its tributaries. Under the NWPA, a Regional Conservation and Electric Power Plan must be developed that considers this goal. The Act also requires the development of a Fish and Wildlife Program, the purpose of which is to enhance fish and wildlife in the Columbia River Basin. The program is developed and implemented by the Pacific Northwest Electric Power and Conservation Council and the Bonneville Power Authority (BPA), and provides funding for specific projects that include protection, mitigation, and enhancement measures.

The data from BPA on the cost of hydropower project mitigation expenditures are comprehensive, and are detailed in annual reports issued by the Council. These compensatory mitigation expenditures averaged $207.1 million per year during the years 2003 to 2005.

Conclusions and Recommendations

Most of the federal programs examined would benefit from better tracking and reporting of compensatory mitigation expenditures. With the exception of the Northwest Power Act, the programs reviewed lack comprehensive summary data on the dollar value of compensatory mitigation they require. These programs should more routinely track and report compensatory mitigation requirements and costs, to allow for a more accurate understanding of how these dollars are spent, and to ensure that adequate funds are being devoted to repairing actual impacts to fish and wildlife habitat and the environment.

The vast majority of compensatory mitigation required under federal programs is wetland and stream mitigation under Section 404 of the Clean Water Act. Over $2.9 billion of ELI’s estimated $3.8 billion annual total – over 77 percent of the funds spent on compensatory mitigation – is generated through the mitigation requirements of Section 404 of the Clean Water Act. As a result, any efforts to direct compensation monies toward protecting the critical fish and wildlife habitat identified in the State Wildlife Action Plans would most effectively focus on the Section 404 program.

Efforts to integrate the State Wildlife Action Plans into federally-required mitigation expenditures will necessarily be constrained by existing requirements and policies under each specific statute. Since compensatory mitigation by definition is intended to replace or restore specific resources that have been lost or damaged by a specific action, many federal programs restrict the siting and nature of mitigation projects to the affected area. It will be critical to take such limitations into account when considering whether and how funds could be strategically directed for fish and wildlife conservation purposes.

Nonetheless, opportunities exist to more directly apply State Wildlife Action Plans and the information they contain to federal compensatory mitigation programs:

  • In the area of Clean Water Act mitigation, there is a growing effort to develop and use a “watershed approach” to guide compensatory mitigation projects, a trend that might allow the Plans to inform and influence siting and design of federally permitted wetland and stream compensation projects.
  • Under the Endangered Species Act, it may be possible to encourage the use of State Wildlife Action Plans in identifying mitigation sites or actions that could support the protection of fish and wildlife habitat and implementation of conservation priorities identified in habitat conservation plans. The trend toward development of regional HCPs itself provides an opportunity for State Wildlife Action Plan priorities to influence local planning projects;
  • The Plans could be used to inform the implementation of natural resource damages programs in certain circumstances. NRD laws provide trustees with a range of options for mitigating injuries to natural resources. The agencies that implement these laws may have the discretion in some cases to consider the Plans in administering their programs;
  • State Wildlife Action Plans could provide Federal Power Act applicants with information about important natural resources, habitats, and species that may be affected by proposed hydropower projects. The Plans also could be disseminated to federal and state natural resource agencies and to FERC, and the agencies encouraged to use them in the licensing process;
  • Under the Northwest Power Act, State Wildlife Action Plans may help inform the Fish and Wildlife Program during revisions to the basin-wide program and the sub-basin plans. The Plans also may be helpful at the project development stage.

The ELI study was conducted with a grant from the Doris Duke Charitable Foundation. ELI staff contributing to the project included Jay Austin, Linda Breggin, Vivian Buckingham, Seema Kakade, Jim McElfish, Kathryn Mengerink, Roxanne Thomas, Jared Thompson, and Jessica Wilkinson, with contractor support from Mary Becker. For more information on the state wildlife action plans, see: http://www.wildlifeactionplans.org/.

Copies of the full ELI report are available for free from: http://www.elistore.org/reports_detail.asp?ID=11248. The full citation is: Environmental Law Institute. October 2007. Mitigation of Impacts to Fish and Wildlife Habitat: Estimating Costs and Identifying Opportunities. Washington, DC: Environmental Law Institute.

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Voluntary Water Markets: The Demand Dilemma

Farmers and other diffuse polluters should, in theory, welcome money from industry for voluntarily reducing their runoff – but high commodity prices and a fear of regulatory entanglement has put a lid on demand in water quality trading in the US. The Ecosystem Marketplace examines the challenge of stimulating WQT demand. Fifth in a Series

26 May 2008 | Figuring out how to encourage individuals to do something voluntarily for the greater good has perplexed philosophers for centuries, and the nascent market for Water Quality Trading (WQT) in the US is bumping up against a more prosaic version of the same dilemma.

WQT schemes aim to do for water what emissions trading schemes have done for air pollution: drive down levels of water pollutants, especially agricultural “nutrients” (nitrogen, phosphorous, and potassium), by letting emitters trade credits among themselves to find the most cost-efficient way of reducing them.

Voluntary water-trading schemes have spread in recent years, with a June, 2007, survey by the US Environmental Protection Agency (US EPA) identifying 23 WQT programs operating across the US that have traded credits at least once.

But WQT faces the same problem globally as the carbon-trading market does at present in the United States: participation isn’t yet mandatory, and polluters have different reasons for deciding whether or not to participate in local voluntary WQT schemes.

So, what’s driving them there? And will more incentives to trade bring laggards on board? For that matter, are voluntary drivers alone incentive enough to keep trading viable – or can WQT schemes fully succeed only when accompanied by strict enforcement of clear limits on specific pollutants by all emitters?

The answer appears to be somewhere in the middle.

“Pointed” Argument

Industry and agriculture typically represent the two major types of tradable water pollution. The first, called “point source”, is easily recordable from definable outflow points like discharge pipes from industry and municipal wastewater treatment plants; the second, called “nonpoint source” is spread across areas like fields and pastures and is therefore difficult to measure.

Not only that, but point sources tend to be regulated under the Clean Water Act (CWA) in the United States, while nonpoint sources are not – for reasons covered in Water Trading: the Basics.

The Meaning of the Word “Voluntary”

People often compare the burgeoning water markets to the booming carbon markets – but that comparison can be taken only so far before creating a distorted view of how WQT schemes work. Nowhere is this truer than in the use of the term “voluntary” trading.

In carbon markets, a “voluntary” offset is just that: a transaction that happens because people want to do it, and not because the Kyoto Protocol or another mandatory cap-and-trade scheme has forced compliance (although even voluntary offsets need to meet certain standards to be credible).

The 2006 Soccer World Cup, for example, was subject to no mandatory carbon cap, but went carbon neutral anyway by funding clean development projects in Africa and India that would have passed muster under the Kyoto Protocol’s Clean Development Mechanism (CDM).

Purely voluntary schemes exist in water as well. The classic example is the Vittel bottling plant’s payment to French farmers to protect the watershed feeding the aquifer that feeds the wells from which it draws its mineral water.

But that oft-cited example is the exception that proves the rule. Voluntary water transactions are rarely served up with a single entity so clearly willing – let alone able – to pay for reductions from scores of smaller entities dribbling gunk into their water.

All in the Watershed

What’s more, unlike greenhouse gas emissions, water pollution doesn’t spread itself equally across the world, but instead kills some bodies of water while sparing others. A polluter in the Red Sea does his neighbors no good if he offsets his emissions by reducing runoff into Lake Victoria (although polluters in Ohio do have an impact on, say, the Gulf of Mexico).

For now, WQT schemes focus on a single watershed, and the big focus is on promoting transactions between regulated point-source entities and unregulated nonpoint-source entities.

These hybrid point-nonpoint schemes are “voluntary” in the sense that credit sellers aren’t regulated, but the key driver is almost always a law mandating a reduction by point-source emitters. In this sense, they are analogous to the CDM: buyers of credits in a compliance regime are working with sellers of credits that are usually outside of the regulatory protocol – and in water trading, those outside the regime usually want to stay there.

In “voluntary” WQT schemes, the sellers of credits are in the same watershed as the buyers – but outside the regulatory apparatus.

Nevertheless, it is the regulatory pressure on buyers to reduce emissions that drives demand.

No Regulatory Driver, No Market

Indeed, as we saw in US WQT: Growing Pains and Evolving Drivers, many schemes that are “failing” are doing so because they were implemented in anticipation of mandatory emission limits that never materialized.

Under the types of “voluntary” WQT schemes that comprise the bulk of transactions taking place now and presumably in the future, regulated point source emitters pay unregulated nonpoint emitters to reduce their pollution. If the amount paid is higher than the cost of implementing the reduction, you’d expect farms and other nonpoint source emitters to be scrambling for WQT money.

But luring them into such schemes is proving to be more difficult than many had anticipated.

Bringing in the Nonpointers

“It’s a heck of a lot harder getting non-point sources involved in water quality trading,” said Tracy L. Stanton, Water Programs Manager with environmental consultancy Forest Trends (parent organization of the Ecosystem Marketplace). “Point sources have no choice but to meet water-quality standards and are governed by a regulatory scheme that can be quite tedious to deal with.”

The US EPA considers regulating discharges of specific pollutants a significant factor in successful WQT programs.

That works fine at places like already-regulated factory outflow pipes, where each pollutant can be easily tested for and its source held accountable. But it’s not so easy along a stream bank where the emissions of several different unregulated land users, not just the landowner, probably contribute to downstream water degradation.

“Trading works best when there is a ‘driver’ that motivates facilities to seek pollutant reductions, usually a Total Maximum Daily Load (TMDL) or a more stringent water quality-based requirement in an NPDES permit,” the EPA stated in a 2007 WQT document posted on its web-site.

Point-Point Bonanza

Not surprisingly, some of the most widely-touted success stories among WQT schemes are between one point-source emitter and another – so-called “point-point” transactions.

The EPA’s inaugural Blue Ribbon Water Quality Trading Award went to Connecticut for a much-cited WQT project that lowered nitrogen levels in Long Island Sound. Among the 79 sewage-treatment plants in the scheme, more than a third had lowered their nitrogen discharges below permit levels and were selling credits within three years.

“Nitrogen trading has accelerated the State’s schedule to meet the nitrogen targets,” the EPA noted in its award.

Why Not Regulate Nonpointers?

So, if regulation works on the point emitters, why not just regulate the nonpoint emitters?

“To have a hope of making (WQT) work, you need more regulation, not less,” says Dennis M. King, Research Professor at the University of Maryland’s Chesapeake Biological Laboratory. “For the climate around water trading to improve significantly, there must be more restrictions on agricultural pollution.”

He says that 30 percent Chesapeake Bay bay’s nutrient load is being contributed by agriculture, which contributes just 0.5% to the area’s economy. And he doesn’t think money alone will be sufficient to lure farmers into a voluntary WQT scheme that requires any documentation of their anti-pollution efforts. “Some see WQT as another way to get money to farmers, but the idea of having some verifier on their farm – they just won’t have it,” King says.

And they know how to lobby – a skill they deployed quite effectively in the passage of this year’s Farm Bill.

“Regulating nonpoint source pollution isn’t the answer,” says Carl Lucero, National Leader for Clean Water at the USDA’s Natural Resources Conservation Service (NRCS). “Instead, water quality trading offers a voluntary option for point sources to meet their water quality obligations at a lower cost than traditional ways.”

He points out that the main drivers for point sources are regulations and costs. “They want to find the cheapest way to effectively meet water quality limits set in their permits,” he says. “If water quality trading is the most efficient way, then it makes good business sense to go with it.”

In Ohio, the Great Miami River Watershed Water Quality Credit Trading Program was able to persuade farmers to join the program by assuring them in writing that they would be exempt from any regulation for the next ten years – but, as we will see later in this series, that project is in jeopardy because anticipated limits on point-source discharges have so far failed to materialize.

Bigger Fish to Fry

And even if supporting regulation materializes, it’s not clear the potential new income stream will seem worthwhile in an age of steadily rising prices for agricultural commodities and farmland – especially if that money is coming from a potential regulatory quagmire like pollution control.

“Farmers appreciate the fact that they’re not regulated and would rather stay under the radar screen than get involved in WQT,” says Stanton. “Even if you show them they can reduce pollution cost-effectively, some fear involvement now means regulation in the future.”

Bank on It

Despite what appear to be intractable issues, a WQT project manager can set policies that maximize incentives to getting polluters in to trade water quality.

The Miami Conservation District (MCD), for example, took pains to ensure that its Greater Miami River Watershed WTQ program would be “farmer friendly”. The district kept bureaucracy to a minimum by paying farmers to complete mitigation projects rather than by selling credits directly and it accumulated a pool of credits to avoid shortfalls.

Bundling Credits

Farmers might also be more amenable to trading a system that would “bundle” a credit like water quality with other environmental credits, Lucero notes. Such bundling could involve assigning different environmental credits, like WQ and carbon-offset, for single practices like cultivating vegetative buffers along streams that reduce nutrient run-off and store carbon. Those reductions or “credits” could then be sold to multiple buyers in different markets like publicly owned water treatment plants and the Chicago Climate Exchange, he adds.

Such a scheme requires help to get the timing and acceptance right, Lucero points out, and that’s where larger ‘third-party aggregators’ like local resource conservation and development councils and conservation districts can help create a stable market. He also sees financial institutions like local mitigation banks playing a role in creating WQT markets in much the same way they were created for wetlands around the country, thereby injecting more confidence into local WQT markets.

“Many are landowners themselves who know everyone in the watershed and can bring buyers and sellers together,” he said. “Some have done mitigation banking but water quality trading can be a whole new business for them.”

WQT can also encourage point sources to join the local WQT party early by dangling the right carrots at the right time. For example, setting the right ‘trading ratio’, or amount of emissions measurement allowed for each offset measurement funded – a key concern for point source polluters – at an attractive level at an early stage can establish a viable trading market more quickly. The Miami Watershed WQT scheme did so by setting trading ratios at 1:1 (2:1 in poor-quality water) for early movers, meaning wastewater plants that signed on first could buy a 1,000-pound phosphorous credit to offset 1,000 pounds of phosphorous emissions. Slower movers could only trade at ratios of 2:1, so needed twice as many credits for the same offset, and 3:1 in poor quality.

State of Play

Politics also has a way of seeping into the WQT debate, creating its own sets of incentive for participating in water trading. In a 2005 article entitled Crunch Time for Water-Quality Trading, King referred to the 2004 demise of a Chesapeake Bay project, where in 2003 a partnership of public agencies and private stakeholders drew up an agreement to launch a watershed-based WQT scheme after three years of preparation.

But one year later, the Maryland state legislature responded to public concern over water pollution with a monthly tax on urban sewer users and rural well-users to fund new discharge technologies and agricultural mitigation practices. The so-called ‘flush tax’, King noted, almost wiped out all demand from treatment facilities for WQ credits while continuing agricultural subsidies restricted supply. “With the stroke of the governor’s pen, prospects for WQ trading any time soon in Maryland evaporated,” King wrote.

Nonetheless, the Chesapeake Bay WQT project, covering an area of 64,000 square miles, is now back on the agenda and will be the subject of several environmental get-togethers over the next few months, Stanton said. But with seven states and their governments involved and not all of them seeing eye-to-eye on the issue of neighborhood water quality, she adds, nothing can be taken for granted.

“State agencies often work against other states (on water quality), and that may create different incentives and disincentives to launching a water trading scheme,” Stanton said. “The stakes are really high.”

Rob Luke has been covering markets and environmental issues for 15 years in Europe, Asia, Australia, and North America. He lives and works in Edwardsville, Illinois, and can be reached at [email protected].

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Is the Road through Poznan Paved with Voluntary Carbon?

Voluntary and regional carbon reduction initiatives continue to save tropical rainforests by using them as carbon sinks – along the way helping to define and standardize the means of measuring carbon captured in trees. The Ecosystem Marketplace takes stock of the latest developments in Reduced Emissions from Deforestation and Degradation (REDD).

1 December 2008 | As the climate world gathers this week in Poznan, Poland, to discuss life after Kyoto, the question of how to deal with emissions from agriculture and deforestation hovers at the edge of the debate like a wayward son: filled with potential and also dashed hopes.

While negotiators begin twisting around the layers of complexity in the international forestry debate for post-2012, on the voluntary side of the market stakeholders are moving full speed ahead in refining standards and developing projects.

The Voluntary Carbon Standard (VCS) announced its long-awaited rules for Agriculture, Forestry and Other Land Use (AFLOU) in November, underscoring the role the voluntary market hopes to assume in forging rulemaking in a sector that has generally stymied regulators. But while the chance to open up the market’s doors to carbon credits from forestry appears closer, real obstacles remain. And those obstacles will be explored during the scientific sessions in Poznan – and perhaps in the closed-door political discussions as well.

The Voluntary Solution

No one doubts the land use sector’s appeal. Deforestation alone accounts for roughly 20 percent of the world’s annual greenhouse gas emissions, and AFLOU emissions dwarf those of heavyweight carbon producers like transportation.

Yet no asset class is fraught with more technical challenges. How does a project account for clear cutting just outside the project zone? How does a project account for wildfires and other natural disasters that can threaten carbon sequestration?

VCS has now entered a new realm — providing a third-party standard for avoided deforestation. This is commonly called Reduced Emissions from Deforestation and Degradation (REDD) in the carbon policy world.

By providing REDD guidance, as well as the framework to fold in a large variety of land-use practices under the same standard, VCS has introduced the most comprehensive approach to thorny issues of leakage and permanence in forestry projects. The approach in the voluntary market sets the stage to bring forestry into the international fold. It also demonstrates the work yet to come.

Built for Forestry

From its founding in 2007, the VCS has been well-positioned to tackle forestry issues.

The standard brought together The Climate Group, the International Emissions Trading Association (IETA), the World Business Council for Sustainable Development (WBCSD) and others interested in bringing some unity to the voluntary markets, which were hampered by the lack of standards. But the VCS also held the promise of becoming a proving ground of sorts, one in which the industry could test out promising market mechanisms in the voluntary space before advocating their adoption in regulated ones. No sector needed more help than forestry.

And yet forestry wasn’t included in the original sectors covered by VCS – for a variety of reasons.

The Permanence Problem

“Permanence issues have been a real stumbling block for these projects,” explains David Antonioli, who started as VCS’s CEO in October.

Permanence is the policy term that considers the risk that credited carbon benefits could reverse. A project’s financing may depend on trees absorbing carbon dioxide for years, but what happens if those trees burn down three years from now? Or if they are illegally logged? Numerous solutions have been proposed to deal with permanence issues in forestry, but none have received wide acceptance.

Toby Janson-Smith, senior director, forest carbon markets, with Conservation International, wanted to tackle the permanence problem again through VCS. If a credible approach to address permanence was developed, Janson-Smith asked, would forestry be considered for VCS? The answer was yes.

“Then, it was about getting the best and brightest minds together,” Janson-Smith says.

Those bright minds met in person, spoke on conference calls and swapped emails and emerged with a concept called the buffer pool that is now enshrined in the new VCS rules as the way to overcome permanence issues in land use projects.

The Buffer Pool

The VCS aims to tackle permanence problems in the land use projects by removing the risk from the project level via a so-called “buffer pool”.

Here’s how it works: Every project that applies to use the VCS standard undergoes a risk assessment, which determines how many credits from the project will be contributed to something called the Pooled Buffer Account. Depending on the risks, a project could contribute anywhere from 10% to 60% of its credits to this account.

The intention is to create fungiblity of credits, explains Janson-Smith. If a project collapses, the buffer account can fill the credit gap. That means a VCS forest credit enjoys a level of insurance, free from the risks of a particular project. That means it can be traded interchangeably with any other VCS credit.

“We call it a means of insurance or self-insurance within the standard,” he says. “It’s just not managed by an external private entity that has ultimate liability.”

The concept has generally been well-received.

“It’s a good first step,” says Leslie Durschinger, founder of Terra Global Capital, a land-use project developer who estimates that roughly 40% of her project pipeline is filled with VCS projects.

“It’s quite innovative,” says Keith Paustian, a soil and crop science professor at Colorado State University who lead the VCS Agricultural Land Management expert group. “There are some distinct advantages to something like that that provides the greater fungiblity.”

But actors recognize that the test of the concept is yet to come.

“I’ll tell you if I like the buffer later,” says Ray Victurine, director of Conservation Finance Program for the Wildlife Conservation Society. “I think it makes sense. But the question really is how large does it need to be? How that gets determined matters.”

Even Janson-Smith admits the real moment for the buffer concept is not outlining how it should work, but seeing how it actually does work. And to do that, there need to be projects.

“The most important thing is to get experience with actual projects and project performance,” says Janson-Smith. “In short order, we’ll have major on-the-ground implementation experience.”

The Methodology Crunch

But it isn’t just the VCS guidance that has been holding up REDD projects from getting funded by voluntary buyers. It’s the lack of approved VCS methodologies, the documents that justify credit creation on specific projects. VCS has no approved REDD methodologies as of yet, a fact that is directly impacting the market.

“This is a major blockade,” says Ross MacWhinney, a broker at Evolution Markets.

The stumbling block appears to be a lack of trained methodology reviewers.

“Anyone could submit a methodology today, but a lot of people who would be reviewing methodologies are writing methodologies right now,” says Victurine of Conservation Wildlife Society. “Their priority is to get the approved methodologies out.”

One of the more anticipated efforts is being led by Climate Focus, which is developing REDD methodology modules that will be available to all project developers to incorporate into their projects’ designs.

“Each module will deal with a chunk of methodology,” explains Robert O’Sullivan, executive director of Climate Focus North America. “One is for above-ground biomass. Another for leakage (when a reduction in one place is negated by deforestation elsewhere). There is a series of twelve pieces. Any project developer can simply pick and choose.”

Climate Focus will introduce its modules at a side event on December 5th in Poznan and then seek public comment and input. It plans to submit the modules for validation in early 2009.

REDD vs. Land Use

While the REDD community waits for approved VCS methodologies to advance forest protection schemes in the voluntary market, most developers working on other types of land-use projects in the United States appear to be more interested in delivering credits under CCAR.

Why? One reason is simple economics: CCAR credits are trading at a premium above VCS credits generally.

In addition, the very barriers that are restricting VCS at the moment – a dearth of methodologies and trained reviewers – do not exist in CCAR.

“CCAR seems to be more project developer friendly,” says Sean Carney, a broker with Cantor CO2e, “and the likelihood of CCAR to be accepted in future regulatory schemes is tremendous.”

Compliance REDD?

That means the real near-term opportunity for the new VCS rules lies with REDD projects. Once the methodologies start flowing, projects will begin entering the voluntary market. It won’t be long before these REDD credits become candidates for the regulated market.

Indeed the same day that the VCS announced its new rules, California and two other states signed a memorandum of understanding with governors from Indonesia and Brazil to work cooperatively to incorporate REDD credits from projects in those places into the emerging regulatory schemes in America.

“That sets an important precedent,” says Janson-Smith. “That’s a key milestone.”

It certainly suggests that the wayward son of forest carbon is inching closer to taking its place in the center of the carbon market. But no one seems to think that the journey is close to finished.

“It’s crucial to have a standard everyone feels comfortable about,” says Victurine, “but it’s going to be a learning process anyway. We’re all going to be on a bit of ride.”



Ted Rose consults companies and organizations on carbon offsets and renewable energy credits. He is based in Boulder, Colorado, and can be reached at [email protected].

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Talking Trees in Poznan: The Shape of Forests to Come

A slew of new tools, methodologies, and reports designed to support the markets for forest carbon were unveiled on Forest Day at the 14th UN Carbon Conference in Poznan – including initiatives from Avoided Deforestation Partners, the Climate, Community, and Biodiversity Alliance, and the Ecosystem Marketplace.

8 December 2008 | The Center for International Forestry Research (CIFOR) initiated the first Forest Day last year so that people attending the13th UN Climate Change Conference in Bali could spend one day focusing only on the science – and the politics – of using trees to absorb carbon and combat climate change.

This year’s event, dubbed “Forest Day 2”, drew more than 800 people and offered a chance for non-governmental organizations (NGOs) to voice their opinions, debate the details and introduce tools that support the use of forestry offsets. Here’s a quick recap of a handful of tools introduced on Saturday – most of which you can expect to see covered in more detail over the coming months:

Forestcarbonportal.com: Tracking Terrestrial Carbon

The Ecosystem Marketplace launched ForestCarbonPortal.com, an online information clearinghouse for the terrestrial carbon markets. This satellite website to EcosystemMarkeplace.com includes daily news posts, original articles, a calendar of events, and a “tool box” of the latest intro guides, methodologies, software measurement tools and beyond. The site will also map projects selling land based carbon credits across the globe. Users can search for project sites by region, as well as by a variety of criteria such as project type, standard, registry, and credit prices. Projects are described in consistent ‘nutrition labels’ listing a range of criteria.

Any developers interested in making sure their project makes the list should contact Maria Bendana at mbendana (at) forest-trends.org.

Using Modules to Build Your Own VCS Methodology

Another initiative soft-launched in Poznan is a proposed set of modules and accompanying “instruction manual” that project developers can use to develop REDD methodologies under the Voluntary Carbon Standard’s new rules for Agriculture, Forestry and Other Land Use (AFOLU).

Led by Avoided Deforestation Partners and funded by an array of NGOs and philanthropic organizations, the effort began at the Carbon Expo in Cologne, Germany, and involved consultation with some of the most experienced project developers in the industry.

The modules themselves are designed to harvest the lessons of past experience to serve as building blocks of a project methodology – which is the first major step in project development, and one that often consumes hundreds of thousands of dollars in research and planning. Under the current system, every project developer creates its own, highly specific (and costly) methodology.

Proponents of the modular approach believe it will streamline project development dramatically – but also warn that developing a project methodology is a bit more difficult than assembling a prefab doll house.

“There is not one project anywhere in the world that is the same as any other,” says Eveline Trines, Founding Director of Treeness Consult and a leading contributor to the project.

The upcoming “decision-support tool” that serves as an instruction manual of sorts poses a series of questions to help project developers determine which modules should be applied to which project types under which circumstances.

The draft version of both the modules and the decision support tool are being circulated among experts now, and a revised version will be made available for public comment in January – at which point you can expect to see a more detailed analysis on Ecosystem Marketplace.

In a similar note, Terra Global Capital also announced a new VCS methodology for avoided deforestation, which we will be covering in more depth later this month.

CCBA: Raising the Gold Bar

The Climate, Community & Biodiversity Alliance (CCBA) also made a splash on Forest Day, unveiling the second edition of its CCB Standard – which provides an overlay of social and biodiversity criteria to verify the ‘gourmet’ portion of existing carbon standards.

CCB 2.0 strengthens and clarifies a variety of criteria covered in the first edition, most importantly beefing up provisions for ensuring that the legal ownership of the carbon is clear and that the rightful owners consent to the project being undertaken.

The new edition also updates criteria needed to gain ‘Gold Level’ certification, requiring that such projects not only demonstrate exceptional community and biodiversity benefits, but also generate adaptation benefits.

Keep your eyes on Ecosystem Marketplace for an in-depth analysis of the new CCB Standards in the coming weeks.

UNEP’s Atlas: Finding the Frogs in the Trees

Anyone interested in blending biodiversity and carbon offsets will do well to check out another tool unveiled on Forest Day: the new Carbon and Biodiversity Demonstration Atlas launched jointly by the United Nations Environment Programme (UNEP), the German government, and the Humane Society.

The tool makes it easier to see which forests have how much carbon and how much biodiversity – and might thus be the most important to preserve environmentally and, theoretically, economically as well.

Little REDD Book

Finally, there’s the Global Canopy Programme’s Little REDD Book, which is a handy, 112-page primer on the Kyoto debates on REDD. Instead of trying to explain the concept from A to Z, it provides easy-to-read summaries of seminal positions on REDD put forth by various governments and NGOs, as well as links to detailed position papers.

Not surprisingly, it closes with a reference to PINC (Proactive Investment in Natural Capital), Global Canopy’s own acronym for the fledgling practice of investing in areas of tremendous environmental wealth but no regulatory drivers.

The concept is betting that our economy will evolve to the point of recognizing the economic benefits of ecosystem services and rewarding those who preserve them. PINC advocates aren’t waiting for regulatory drivers to create demand for ecosystem service payments, but are investing in fragile ecosystems now. This subject, too, is on our calendar for the coming months.

Steve Zwick is Managing Editor of the Ecosystem Marketplace. He can be reached at S[email protected].

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The Thin Wet Line: Local and Global Ecosystem Markets

Carbon markets are off to the races around the globe, and wetland mitigation banking has shown it can deliver value in local cases. How do we take lessons from both worlds? How do we balance commoditizing ecosystem services with the reality that local people care deeply about these natural resources they depend on? For ecosystem service markets to move beyond a cheaper way to deliver regulatory compliance and drive us toward sustainability, they must become an integrated part of a larger ecosystem services arena. Bobby Cochran of Oregon’s Clean Water Services examines this issue through the lens of wetland mitigation banks.

22 February 2008 | It’s been nearly a decade since Clean Water Services (based in Oregon’s Tualatin River Basin) jumped into the world of wetland banking. In that time, partners in the Tualatin also launched a water quality trading program. In Oregon, we’ve watched the wetland mitigation banking sector grow into an important industry and part of a growing family of ecosystem services markets.

With some bumps along the way, this growth is showing some positive trends. Bankers from diverse backgrounds (farmers, restoration consultants, and private firms) working in the marketplace have created a constituency demanding predictable rules and a defined, tradable wetland product. As markets for wetlands, carbon, and water grow, their products can become more truly tradable. But the goal of truly tradable must co-exist with truly sustainable for these gains to carry their value into the future. Several barriers remain to melding these two goals.

Dealing with Differences in Quality

In an ideal ecosystem services market, information would be available for anyone to order up quantified ecological benefits by habitat type in the way many of us order peppers and mushrooms on pizza.

Ecosystem services markets, however, will never be so neat, because they deal with complex systems of land, water, air, biodiversity, and that wildcard – people. In Oregon, many wetland banks are of high quality, lining up nicely in the places mapped as having the highest conservation/ecosystem services value.

Astute wetland bank sponsors deserve much of the credit for this, but new investment capital is increasing capacity to engage in strategic site location rather than grabbing opportunities. In Oregon, and many other places, we see a broader movement afoot to pay closer attention to quality and sustainability in mitigation banking.

This is important because not all wetlands are created equal. A wetland filled with cattails and surrounded by development will not provide the kind of biodiversity or water quality benefits provided by a mix of emergent and wet prairie wetland surrounded by an upland mosaic of oak habitat.

Many Army Corps of Engineers Districts have used mitigation ratios to deal with the quality issue. For example, impacts on vernal pools require higher mitigation ratios than impacts on scrub shrub wetland. More recently, some Corps districts have added functions-based accounting, which moves beyond treating a wetland acre as any other wetland acre and tries to account for the larger suite of wetland functions. These efforts are laudable, but more could be done.

In ecosystem services markets, we pay an inordinate amount of attention to the science beyond defining the number of credits generated by a restoration action. There are other places in the market to insert incentives for quality. Imagine a quality rating attached to a credit like the US Green Building Council (USGBC)’s Leadership in Energy and Environment Design (LEED) Certification program. Criteria for quality might include the site’s location in a mapped priority conservation area, the level of permanent protection given to the site, or the time remaining before my bank reaches all performance standards. With a gold rating in hand, I could increase the income potential of my bank by:

  • Getting a premium price on my credits from that developer who wants wetland with species benefits;
  • Reducing the amount of financial assurances required by the Corps and other agencies to back my credits; and
  • Accessing a streamlined instrument approval and credit release process.

Efficiency, Transparency, and Local Control

Continued growth in the wetland mitigation banking industry and new federal rules, which provide greater incentives for banking, are likely to increase demand for standardized marketplace exchange processes, reporting requirements, and other market infrastructure.

In terms of exchange, bankers who work in multiple states or in multiple markets will not want to deal with multiple regulatory frameworks. Bankers in regions with many overlapping wetland bank service areas will want tools to get price information to ensure that bankers and buyers are getting the best deal.

Without marketplace exchange tools, registries, and standard processes, transaction costs remain high, and from the ecosystem’s perspective, it would rather have that money going directly into restoration. Tools like the Regional Internet Bank Information Tracking System (RIBITS) platform for registering credits and the Ecosystem Marketplace are helping by providing information, a critical element of efficiency and transparency.

In the quest for efficiency and market volume, we should not forget that local people who use and know wetland and wildlife services should remain in control of credit standards. Local in this context may be a state, a region, or a watershed.

This does not mean every region should invent its own infrastructure for setting prices or verifying bank performance. In fact, the opposite is true: as the banking industry grows, more and more regions should search for common procedures to create a standardized, tradable product.

This does not mean that a wetland restored in Oregon should be sold to offset an impact to a wetland in Nebraska or Thailand, but there are essential elements of all ecosystem markets that can and should be shared.

A common market infrastructure will make it possible for participants in mitigation banking to specialize and distribute their experience more easily across regions. In most states, institutional review teams of agencies verify credits, gather market information, assess market demand, and monitor compliance. This is an enormous amount of work. As markets grow, new entities can assume these tasks, leaving review teams to adjust program goals, verify standards have been followed, and monitor market performance.

Moving from Sites to Systems

Mitigation banking is a program tied to acquiring, restoring, and managing sites. The day-to-day business of running the mitigation banking market can easily distract banking stakeholders from looking toward new challenges facing ecosystems.

Current banking practices lock wetland and species functions into specific parcels, leaving them exposed to changes caused by climate change or urban growth. Important parts of wetland banking (e.g. trading ratios, endowments, and other risk management measures) are tied to sustaining the functions of a site at a snapshot in time. A lot of investment goes into wetland banks, investment that can benefit forests, wildlife, and riparian corridors. Looking at wetland banking in isolation misses the role wetland banks can play in restoring other ecosystem services. Wetland banking is part of a system of conservation investments that include grants, incentives, regulations, and other markets.

Within banking, some changes can be made to move from sites to systems. Instead of making sure each site succeeds, mitigation bank review teams can incorporate measures to make sue the whole program succeeds. Borrowing from the Great Miami water quality trading program in Ohio, a portion of credit transactions can be invested in an “insurance pool” of credits.

Alternatively, whole wetland banks can be sited to protect against risks of future habitat change, and credits can be withdrawn or purchased to cover projects lost to floods, invasive plants, or events not accounted for in current risk protection measures. Whatever the answer, ecosystems need the flexibility to move and still provide key services.

The Importance of Interconnectivity

In conservation biology, interconnectivity often evokes a picture of green corridors connecting large patches of habitat. Markets need to keep this picture in mind as they develop.

Wetland banking alone is not going to get us where we need to go with regard to ecosystem restoration, and banking needs to continually connect with other conservation tools if it is to be effective.

For example, the current “no net loss” national policy does not help make up for the decades of wetland loss before this policy took hold, and it does not protect the upland areas necessary to support watersheds and ecosystem services. The same is true in other ecosystem markets.

It is in linking wetland mitigation, water quality trading, carbon, and other ecosystem services markets that we begin to leverage the kinds of investments needed to recover entire ecosystems. The recent agreements between the Department of Agriculture, Environmental Protection Agency, and the Fish and Wildlife Service, coupled with proposed elements in the next Farm Bill, provide an important opportunity to link market tools with other conservation approaches and tools.

Regional efforts are also taking on the challenge of linking markets. In Oregon, the Willamette Partnership is moving from a water-quality trading program to an integrated marketplace for ecosystem services.

Together, ecosystem market leaders have begun organizing around the concept of an Ecosystem Services Council to promote transparency, integrity, and quality for ecosystem markets beyond Oregon in the same way the U.S. Green Building Council has successfully advanced sustainable building practices through its certification program. Regional efforts like the Ecosystem Services Council need to connect with networks in the Chesapeake, Mississippi, Great Lakes, and other regions to develop common infrastructure and standards.

As banking and other markets move into the next decade, greater attention to quality, more efficient transaction processes, and greater recognition and treatment of wetlands as “system elements” will make sure wetland banking continues to be a tool moving beyond regulatory compliance to real ecosystem gains.



Bobby Cochran is the Environmental Marketplace Analyst for Clean Water Services, a public wastewater and stormwater utility dedicated to the health of Oregon’s Tualatin River Basin since 1970. He can be reached at [email protected].

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Ugandan Water Markets: What Businesses Know (and Don’t)

Water markets can help provide a solution to Uganda’s looming water crisis – but only if buyers understand the stakes and the dynamics. Alice Ruhweza, East and Southern Africa Katoomba Group Coordinator, says Ugandan water users understand the crisis but haven’t yet explored market-based solutions. The Ecosystem Marketplace summarizes her findings.

18 April 2008 | Massive Lake Victoria spreads thinly over nearly 70,000 square kilometers in Africa’s Rift Valley, covering more surface area than any other tropical lake in the world. Millions of people and thousands of businesses in three nations depend on this vast but shallow body of water for survival – but huge parts of the lake are themselves “dead zones”, devoid of oxygen and barely capable of supporting what little life remains below the waves, let alone supporting humans on the shore.

Key among these humans on the shore are Ugandan brewers, bottlers, flower exporters, electric companies, and of course municipal water plants – all of which are not only dependent on clean water, but also have the economic and political clout to promote change.

But do they understand the importance of ecosystem services to their business, and are they willing to put their money where their menace is and support efforts to clean up the water? These were the key questions the East and Southern Africa Katoomba Group put to more than fifteen leaders of Ugandan industry in a survey conducted last year, the results of which have been published in Assessing the Market: Conversations with Private Sector Businesses About Payments for Ecosystem Services – A Letter from Uganda.

The answers are, in a nutshell: yes, they are aware of their dependence on this fragile resource, but no, they do not have concrete plans to invest in the lake’s future.

These findings were echoed in a survey of Fortune 1000 executives carried out by the Marsh Center for Risk Insights. Forty percent of the companies surveyed said the impact of a water shortage would be severe or even catastrophic, but less than one-in-five (17%) say they have prepared for such a crisis.

Identifying Key Ecosystem Services

All companies surveyed named water as the resource most critical to their business, and most of them draw their water from Lake Victoria. Those that aren’t directly dependent on the lake, such as some district or municipal water companies and flower exporters, draw their water from aquifers through the use of boreholes. Some companies also mentioned shallow wells and rainwater collection.

Energy or electricity came second on the list, but it is also directly tied to water and hydro-power.

Lake Victoria: an Overview

Despite its massive surface area, Lake Victoria has a mean depth of just 40 meters (131 feet), leaving it susceptible to both climate change and conventional pollution. Indeed, inflows of farm run-off and untreated effluent have led to fish die-offs, algal blooms and the spread of water hyacinth (a waterweed), which in turn depletes dissolved oxygen, blocks sunlight, and impedes water transport.

A recent survey by environmental engineering group Air Water Earth (AWE) concluded that Murchison Bay, where the Ugandan capital Kampala is located, has only about half the dissolved oxygen needed to support most species of fish; while all along the Lake Victoria shoreline, hyacinth provides habitat for malaria mosquitoes and snails which harbor bilharzia parasites.

The key drivers are easy to identify, but that doesn’t mean they will be easy to reverse. Kampala’s sewer system, for example, captures just ten percent of the city’s waste, and most of Lake Victoria’s pollution flows in from nonpoint sources that are almost completely unregulated – such as small-scale workshops, parking lots, and car repair garages. Furthermore, guesthouses, slum dwellings and industries discharge untreated wastewater directly into the Nakivubo Channel, an artificial stream that drains Kampala and its suburbs.

The channel flows directly into Murchison Bay, and is responsible for roughly 75% of the nitrogen and 85% of the phosphorus discharged daily into the bay daily, and these nutrients are largely responsible for the eutrophication and algal blooms that clog water treatment plants and extract oxygen from water.

The Consequences

Uganda’s National Water & Sewerage Corporation (NWSC) says that the worse the water gets, the more expensive it becomes to make it drinkable. Ironically, NWSC’s own sewage treatment plant at Bugolobi discharges 15,000 cubic meters of inadequately treated sewage per day into Murchison Bay, and has been named the lake’s single largest polluter.

The Nakivubo Wetland and other major catchment wetlands, which once played the vital role of filtering effluent and storm water discharging into the lake, have long ago been encroached and degraded by settlement and cultivation. Widespread lakeshore cultivation and soil erosion also contribute excessive sediment and nutrients into the lake. Storm water flowing through Nakivubo Channel now carries tons of soil and waste straight into the lake.

Climate Change and Low Levels of Water

All companies surveyed cited climate change as a serious threat, as lower levels of water not only leave more concentrated pollution, but also leave a loss of other services that water bodies provide. The flower exporters and the district water supplier, for example, said they fear canals drying up during ever more-frequent periods of prolonged drought.

The lake also acts as a reservoir for hydropower, and falling water levels have reduced water available for generation. This situation is becoming an issue for businesses, because diesel-generated power is expensive and electricity tariffs have increased recently. Already, some companies require water use permits from the Directorate of Water Development which now have even more strict approval conditions to use water.

Further compounding expenses, severe power outages in 2005 resulted in business disruptions. For example, exporters of cut flowers exporters failed to meet their customer orders, and Uganda’s overall revenue from flower exports dropped from US$ 24 million in 2005 to US$ 20 million in 2006.

Other Ecosystem Services

Good electricity poles are also in short supply in Uganda, due to deforestation. Therefore, at present, most poles are imported from South Africa at a cost of roughly 1,200,000 Ugandan shillings (approximately US$ 750) each. Recently, the Parliamentary Committee on Natural Resources raised concerns about these costs and asked Uganda Electricity Distribution Company (UEDCL) to find a solution.

Furthermore, due to land shortage from high population growth, no land will be allocated for growth of wood for poles and the shortage will continue. Eucalyptus poles have high nutrient and water demand, and are not a sustainable option. PES approaches that could rectify this situation need to be explored. For example, a group of land owners could be given an incentive to plant fast-growing native trees.

The Corporate Response

Most of the companies surveyed have made investments to respond to ecosystem changes, but these are focused on meeting their own, individual, needs – and do not address macroenvironmental issues.

Beverage manufacturers, for example, have built water reservoirs on their plants which store water for up to two days. They also recycle 80% of the water that they use, and maintain water treatment plants and waste treatment plants. In the future, many plan to minimize water usage by modifying technology.

Flower companies have supplemented the water shortages by drilling bore holes, constructing water collection reservoirs for rain water harvesting, and planting trees.

The district water system is advising communities to form water user committees to be proactive in address soil erosion threats by planting grass, and digging terraces in gardens.

Some of the companies also have a policy of training employees in safety and environmental management, but implementation is costly and policies are often not implemented.

Surprisingly, the electricity sector has not yet articulated a strategy to deal with various environmental service shortages, especially related to water, although the Ministry of Energy is promoting other sustainable alternative sources of energy such as mini-hydropower generation on small rivers, solar power, wind power, biomass energy, and biogas.

In addition, most companies are engaged in some form of public outreach, detailed in the full report.

Payments for Watershed Services

All companies said it was critical for natural resources management to be integrated into the company strategies. This would enable market-based mechanisms to be part of the company programs.

The easiest way to incentivize this is to begin charging for water, the delivery of which is currently supported through very low tariffs. This approach, however, would likely face stiff resistance from water users, many of whom assert that natural resources are free and should not be paid for.

The Payment for Watershed services (PWS) concept exists in Uganda, but has not been incorporated into the present models of water management. Based on the survey and roundtable discussions, payments for water to also cover the cost of maintaining and restoring watershed services would constitute a general shift in company policy.

Until now, the companies have emphasized on-site investments to cater for future water shortages and to ensure water quality. PWS would shift them towards the protection and maintenance of ecosystems that provide the water that they use and ideally an eventual recovery of costs.

For a payment scheme to succeed and endure, the actions and change brought about by upstream land and water managers should result in identifiable benefits for downstream water users. Therefore, clear cause-and-effect relationships between upstream land and water use practices and the provision of watershed services for downstream users needs to be identified. The degree to which this is possible varies considerably from case to case.

A key policy question of how competing users should pay for the services of one watershed may arise. A decision based only on willingness-to-pay may lead to the exclusion of those who have less ability to pay, or to free-loaders who enjoy the benefits of the watershed without paying for them

There is, therefore, a need for more site specific analysis in order to determine whether a particular site is feasible for PWS.

Why Take a Market-Based Approach?

Those who own or manage upper watershed land often have little incentive to provide watershed services because the benefits occur downstream, so upper watershed actors don’t receive compensation for providing them. Development of incentives for appropriate land use practices therefore require finding ways for upstream landholders to be compensated for their costs.

This is where a more broad-based Payments for Ecosystem Services (PES) scheme could help alleviate the problem. Paying land owners in the upper water catchment to maintain existing forest cover or vegetation, for example, could maintain stable stream flows and reduce sedimentation. Likewise, a small fee could be added to the monthly water bill, with the funds being set aside for conservation and watershed protection projects.

What Should Companies do Next?

Based on our conversations, we have mapped out a three-phase approach that would have to be carried out with the cooperation of private, public, and community stakeholders.

Phase 1: Exploring the potential for—and returns on investment related to—payments for watershed services in key areas of Uganda relevant to business, which would include identifying and locating specific areas within targeted watersheds that contribute the most to the water problem (such as water shortages or poor water quality). These studies would also indicate where and how land-use changes must be introduced in order to reduce and eventually eradicate the sources of such problem.

Phase 2: Designing a pilot PES project for private-sector investment. Based on Phase I findings, a pilot test of changed watershed management practices can be designed for private sector investment and collaborative implementation and study. Such a pilot would include a cooperation agreement (or memorandum of understanding) between upland watershed service providers and downstream service users (the companies/businesses), whereby the upland providers would agree to carry out certain activities to ensure water quantity and quality in return for an agreed amount of money or form of compensation. Monitoring and verification can be undertaken by a third party.

Phase 3: Implementing a pilot PWS project (or portfolio of projects) and assessing results, including return on investment (ROI). The last stage would be implementation of the agreement for an agreed period of time (with continuous monitoring) that would enable private sector partners to assess if payments for watershed services offers improved reliability of water quantity, quality and/or cost savings.



Alice Ruhweza is Coordinator of the East & Southern Africa Katoomba Group. She can be reached at [email protected].

Steve Zwick is Managing Editor of Ecosystem Marketplace. He can be reached at [email protected].

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Mbaracay: Lessons in Avoiding Deforestation

Nearly two decades ago, a small Paraguayan NGO teamed up with a global environmental NGO and a mid-sized American energy provider to save a chunk of rainforest from the sawmills by offsetting greenhouse gas emissions. The Ecosystem Marketplace revisits one of the world’s first carbon offset projects: the Mbaracayº Forest Nature Reserve. Second in a three-part series.

8 January 2008 | Six years before the Kyoto Protocol was drawn up, North American energy provider Applied Energy Services (AES) paid $2 million to offset roughly 47 million tons of CO2 by helping to fund the Mbaracay Forest Nature Reserve (MFNS) in Paraguay. It was 1991, and the debate over forestry credits was foggy to say the least.

Indeed, few outside of a tiny circle of forward-thinking academics and activists had truly pondered how to quantify the amount of carbon captured in trees, let alone how to measure the impact of sustainable forestry on indigenous people. MFNS organizers, however, managed to create a 64,000 hectare private reserve, the benefits of which flow out to a 300,000-hectare buffer zone of sustainable agriculture. The indigenous Ach people have taken an active role in managing the reserve, and smaller private reserves are sprouting like mushrooms in the buffer zone to create migration corridors in support of a UNESCO-recognized biosphere reserve.

 

Getting Started

The Mbaracay region is one of last remnants of the traditional Ach hunting ground, over which they’d been losing control for decades before finally being dispatched to reservations in the 1970s. Mbaracay then passed to an Argentinean logging group called FINAP, and finally ended up in the hands of the World Bank after FINAP defaulted on a loan.

North American anthropologist Kim Hill then began lobbying the World Bank to give the land to the Ach, but it remained in limbo for years, and by 1987 seemed destined to be divided up and auctioned off to soybean farmers for $7 million.

That’s when Hill teamed up with Raul Gauto, who was heading the Paraguayan Ministry of Agriculture’s Conservation Data Center and working with The Nature Conservancy (TNC) to build a biodiversity data base. Gauto and Hill asked TNC for advice on turning the area into a forest reserve with special use rights for the, and Gauto quickly carried out a comprehensive biodiversity survey of the property to help them make their case.

“With the help of a multidisciplinary team made up of 13 professionals, and over a two-week period, we tried to collect all the biological and physical data to support our next move,” says Gauto. “This was to try to persuade the World Bank to donate the land to us.”

But they continued to pursue other routes. Gauto had heard about AES after the company funded a pioneering forestry project in Guatemala. Through TNC, he was able to get word of the situation in Mbaracayº to AES owner Roger Sant. At the same time, he persuaded twelve Paraguayan businessmen to create a non-profit organization called Fundacion Moises Bertoni (FMB) to lobby the government on behalf of the Ach.

These efforts yielded fruit after the fall of notorious Paraguayan strongman Alfredo Strssner in 1989, and the Paraguayan government passed a law making the reserve possible and promising land near the reserve would be transferred to the Ach, in accordance with a 1989 United Nations convention on the rights of indigenous people. The World Bank, however, continued to balk at donating the land.

But they did lower their price to $5 million, at which point FMB offered $2 million and was given the property – on the condition that it would not be grabbed by the government and that indigenous people would play an active role in managing it.

 

Structuring the Deal

The two NGOs quickly secured donations to cover the purchase price, with a smattering of miscellaneous small donors (including members of the rock band REM) chipping in a total of $250,000. AES and USAID contributed $500,000 each, and one very generous anonymous nature lover from Ohio came up with $750,000.

But that was just the beginning, recalls Yan Speranza, who took over from Guato as head of FMB in 2001. “The only reason this program is so successful is because we can think in the long term,” he says. “And we can think long-term because we have a trust fund.”
That trust fund is where the bulk of the carbon offsets come in.

As the deal was coming together, AES was looking to offset 35 years of emissions from a new power plant it was building in Hawaii. The company calculated that the plant would emit 13.1 million metric tons of carbon over the ensuing 35 years—or about 47 million tons of CO2 using the generally accepted conversion factor of 3.6:1. They offered to pay just over 15 cents for each ton of carbon sequestered—or about 4 cents per ton of CO2, roughly $2 million in total, with $500,000 going to the purchase of the land, and $1.5 million establishing the trust fund used to maintain the property.

The reserve is managed from the proceeds of the trust fund, and the principle is off-limits. “We basically reinvest everything we can,” says Speranza. “It’s now grown to $6 million.”

Getting the money, however, required not only measuring the amount of carbon in the trees, but proving to AES that the forest would not survive without the funding—what today we call the “additionality” requirement.

“That was easy in this case—because the forest was earmarked for destruction,” says Speranza. “These days, the difficulty would be in quantifying the non-carbon benefits—biodiversity, culture, and so on. Back then, the biggest challenge was measuring the carbon.”

Gauto tapped the forestry faculty of the National University and the staff of the National Forest Service to measure the amount of carbon sequestered in the trees. The study involved first identifying three different types of forest using satellite imagery, and then measuring the diameter of all trees thicker than ten centimeters at chest height in fifteen plots within these three forest types, and then extrapolating the total carbon in each tree based on that data. Then they assigned a biomass per hectare amount for each forest type, and used the satellite images to come up with a total number.

“We came up with 27 million metric tons—about twice what we needed,” says Speranza. “We then sent our study to people at other universities, like Sandra Brown from the University of Illinois (now at Winrock International), who said the methodology was legitimate. Ultimately, AES agreed the numbers were good.”

Although the reserve is obligated to send yearly reports to AES, FMB has not commissioned another carbon inventory since the project launched. “The 64,000 hectares are intact, so we know the amount has not gone down,” says Speranza – adding that another inventory is in the works.

 

How to Spend It

“At first, we only had 57,700 hectares,” says Speranza. “The other 6,000 hectares came over the next few years – but 57,700 is still a lot of territory to protect from danger.” FMB found that illegal logging had been taking place around the edges of the reserve, and went about recruiting and training forest rangers.

“There are 17 public reserves in Paraguay, covering about five million hectares,” he says. “The biggest one is about 700,000 hectares, and only has two park rangers. We, in contrast, have 64,000 hectares and 18 park rangers – as well as modern communication systems, on-going training, and so on—all because of the trust fund.”

He also rattles off a litany of social benefits generated by the reserve. “We never thought only about conservation, but also about how to promote sustainable development for the whole region,” he says. “We’re really proud of this, because up until the mid-90s, conservation projects usually focused only on protection of nature, and not on the surrounding areas or communities.” See a (detailed examination of the project’s social benefits through the year 2000 — PDF)

FMB has been working with private land owners in the surrounding 300 hectare buffer zone since the reserve’s inception. “The problem in Paraguay isn’t just deforestation, but fragmentation,” he says. “We helped draft the legislation that offers tax incentives for private reserves, and now we’re working with private land-owners to get them to create private reserves so that we can have migration corridors.”
Four private reserves have already been created, and FMB hopes to see between 80,000 and 100,000 hectares of the buffer zone eventually covered in reserves. In 2001, the United Nations Educational, Scientific and Cultural Organization (UNESCO) recognized the surrounding area as the Bosque Mbaracay Biosphere Reserve, which has made it possible for FMB to secure more funding from grants.

The group has also promoted sustainable agriculture within the buffer zone, and introduced crops such as sesame into the area. Speranza says he can document a quadrupling of income over the past five years, and believes much of this flows from FMB’s social efforts—which include the funding of schools and a health center, as well as communications infrastructure.

 

Green Businesss

Speranza says that the trust fund has given FMB a chance to prove its financial competence, and three years ago became the first NGO in Paraguay to receive a grant directly from the World Bank’s Global Environmental Facility. They’ve since leveraged their good reputation to secure loans and grants to get into for-profit green businesses.

Seven years ago, for example, FMB purchased LICAN, a meat processing plant that had been dumping blood from slaughtered animals into a local river. “We discovered that you can use the blood to make plasma and hemoglobin, which is a raw material for animal feed,” he says. “By using the blood this way instead of dumping it to the river, and running this company with a triple bottom line, we are generating environmental, social and economic value: the blood does not go the river anymore, people who were suffering along river no longer are, and the company is profitable, helping us to finance—through dividends received—all our other activities. Truly a virtuous circle.”

They recently identified a similar meat packing plant in Chile, and together with a Chilean partner formed a joint venture to purchase and manage the property in a sustainable way. As shareholders, FMB receives dividends from the partnership.

“About 22% of our income comes from the for-profit companies, and 45% from the trust fund,” he says. “The rest comes from service fees and grants – but we are getting less and less from grants, and that is our goal.”

Controversially, FMB recently agreed to a ten-year strategic alliance with soybean growers interested in developing a management model also based in a triple bottom line. Speranza says the project creates both social and environmental value because FMB is helping neighboring communities create private reserves inside their properties, but he fears some will accuse him of making a pact with the devil.

“Soybean growers are blamed for deforestation, so this is bound to give us some problems,” he says. “Our feeling, however, is that you have to work with the private sector to develop agriculture in a good and sustainable way. We know how to work with local communities, and we know how to create reserves and deal with environmental issues, so it is part of our mission to share this know-how.”

 

Ach: Unfinished Business

The law establishing the reserve gave the Ach exclusive rights to hunt on the reserve, and they also have seats on the reserve’s advisory board, but Hill says they’re still being short-changed.

“While the Ach were given use rights by the 1991 law creating the reserve, they have not been titled any additional land surrounding the reserve, the area that encompasses their traditional homeland,” he says. “The Ach gave up the Mbaracayº Reserve area because they were promised another piece of land, but so far, after 16 years, they still have no land title.”

And that’s hardly a minor issue. One of the key selling points of avoided deforestation projects is that they will help indigenous people and small landowners—in part by forcing more clarity on land tenure. Critics say that clarity may come at the expense of the indigenous people such projects purport to help.

These issues are sure to gain prominence in the year ahead as we explore the efficacy of the new Climate, Culture, and Biodiversity (CCB) standards—the success of which will largely hinge on their resolution.

Next in this series: we revisit a late 1990s project in Brazil, the Guaraqueaba Climate Action Project, and examine the impact of standardized methodologies on projects in the works today.

Steve Zwick is a regular contributor to the Ecosystem Marketplace. He may be reached at [email protected].

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Painting the Town REDD: Merrill Lynch Inks Massive Voluntary Forest Deal

In a major demonstration of confidence in the viability of voluntary carbon offsets as a strategic investment, Merrill Lynch is raising equity for a 100-million-ton, for-profit avoided deforestation project in Aceh, Indonesia. Tellingly for the future of the forestry market, the decision to take the plunge had more to do with the cultural and biodiversity benefits than with the carbon itself. The Ecosystem Marketplace examines the deal and its significance.

8 February 2008 | “Pre-Bali, no one wanted to touch avoided deforestation,” says Dorjee Sun, CEO of Australian project developer Carbon Conservation. “Now people are starting to recognize AD as the next big thing, and they are looking for ways to participate with an edge.”

On Thursday, Carbon Conservation and Merrill Lynch confirmed that the investment bank will be offering its retail and commercial clients voluntary carbon credits from a massive Indonesian AD project that could yield up to 100 million metric tonnes of offsets over 30 years.

To put this number into context, Ecosystem Marketplace tracked just over 24 million tons of voluntary credits transacted in 2006.

More importantly, says Sun, the project is part of a larger scheme to build Aceh’s economy along what he calls a “Green Paradigm” incorporating not only culture and biodiversity standards attached to the carbon, but also sustainable agriculture.

Coffee and the Economic Ecosystem

The longer-term plan involves new financing mechanisms designed to jump-start the cultivation of sustainable palm oil, coffee, and cocoa, which will then be marketed under the brand name “Aceh Green.” It is this later phase, details of which are still to be announced, that convinced Merrill to take the plunge, according to Abyd Kamali, the bank’s Global Head of Carbon Emissions.

“The overall approach being proposed in Aceh is truly innovative and reflective of the need for forestry, carbon, and softs to be treated as one economic ecosystem,” he said.

Climate Community and Biodiversity

Both the future green commodity project and the current carbon project are centered on 750,000 hectares of the Ulu Masen Ecosystem. (For a detailed examination of the project and the challenges of implementing it, see It’s Not Easy Being Green in Aceh, Indonesia).

Carbon Conservation began developing the project together with Fauna & Flora International and the government of Aceh Province in February, 2007. One year later, on February 6, 2008, the project became the first forest conservation project to achieve Climate Community and Biodiversity (CCB) certification when the Rainforest Alliance SmartWood Program signed off on it.

“I can’t emphasize enough the significance of being approved by SmartWood,” says Sun. “Jeffrey Hayward raked us back and forth over the coals until he was convinced that we could implement the plan as presented, for the money budgeted, and in the time allotted.”

The Economics of Quality

Sun is banking on the idea that the extra money spent on preserving biodiversity and supporting the local economy will pay off in spades when it’s time to get the emission reductions certified – and the resulting certificates sold.

Both he and Karmali say the project wouldn’t have happened without strong local support, and they give credit for that to Aceh Governor Irwandi Yusuf, who Karmali first met in September. “Meeting the Governor of Aceh, as well as the other stakeholders involved in the project, left a strong impression about the collaborative approach that has been employed – and the strong buy-in from all stakeholders on this project,” he says.

Local buy-in, however, wasn’t a foregone conclusion, and the next five years will be critical in maintaining it. That is the time over which the first $48 million will be spent – more than half on economic development in local villages.

“Deforestation isn’t caused by big companies coming in and chopping down trees,” says David Pearse, who is overseeing the land use aspect of the project for Carbon Conservation. “It’s caused by local people having no other source of income than the forests.”

“Aceh still has standing forests because of the war between the Aceh rebels and the Indonesian government,” adds Sun. “Now that they have peace, illegal deforestation has started going rampant. The governor understood the loose structure of carbon credits, and tied it into a moratorium on logging.”

Jostling for Post-Kyoto

Sun says he expects the first tranche sold through Merrill Lynch to bring in $5 to $10 per tonne of CO2 sequestered, which is a slight premium to the price of voluntary allowances trading on the Chicago Climate Exchange.

Over time, however, he believes the social benefits of the project will boost the prices of his credits to a level more in line with those of the compliance market – especially if avoided deforestation becomes a recognized offset vehicle for carbon emissions in a post-Kyoto world.

“If we monitor our vintages right, we will be on the right track for compliance credits, and will be pushing a compliance price,” he says. “In the meantime, people will be looking at prices of carbon under the European Union Allowance (EUA) scheme, and then looking at voluntary methods, and they will realize that projects that can show additional benefits are worth paying extra for.”

The challenge now, of course, is to actually deliver. “This is only the first step,” says Governor Irwandi. “The hard work will be in financing and implementing our proposed project to help preserve the largest remaining bloc of unprotected Sumatran forests.”

Updated: February 11, 2008




Steve Zwick is managing editor of the Ecosystem Marketplace. He may be reached at [email protected].


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Water Trading: The Basics

16 April 2008 | In the early 1980s, the de la Motte family realized that cow dung and fertilizers were finding their way into the aquifer that fed the family’s famous (and lucrative) mineral water plant in the town of Vittel, in northeastern France, after upstream farmers had replaced natural, filtering grasslands with corn.

By the end of the decade it had become clear the problem needed an innovative solution – one Vittel’s new owner, Nestle, spent the 1990s hammering out with local farmers. The company purchased 600 acres of sensitive habitat and signed long-term conservation contracts with farmers whose corn and cows had polluted downstream waters.

Nestle now pays these farmers to manage their animal waste, graze their dairy cows the old-fashioned way, and reforest sensitive filtration zones. Though costly, it’s a lot cheaper than the alternative. Competitor Perrier (now also owned by Nestle) once spent more than $260 million on a global recall after benzene made its way into millions of its distinctive green bottles, and its market share has never recovered.

 

Payments for Ecosystem Services

Vittel’s action, like New York City’s payment to upstate farmers, has become a textbook example of a successful “PES” deal – short for Payments for Ecosystem Services – or, in this case, “payments for watershed services” (PWS). Such schemes, as frequent visitors to this site know, are based on the premise that ecosystems deliver valuable services that most of us take for granted – like filtering water in the above example – but whose value our economy doesn’t normally take into account.

PES schemes try to quantify the economic value of services that an ecosystem provides, and then either entice or mandate those who benefit from the service to pay the people who maintain them.

Unfortunately, for every successful PES scheme, there are scores of failures and near misses, and much debate about what works and what doesn’t. These issues are high on the agenda at the upcoming June Global Katoomba Group Meeting, and over the next two months we’ll be focusing on water-based PES schemes: the history, the theory, the practice, the successes, and the challenges.

 

Trading Water: Quantity and Quality

The Kyoto Protocol has put the trading of greenhouse gas emissions and offsets on everyone’s radar, but emissions trading actually began decades before the Kyoto Protocol was signed. The US Environmental Protection Agency’s (EPA) Emission Trading Program started in 1974, and allows a limited exchange of emission reduction credits for five air pollutants: volatile organic compounds, carbon monoxide, sulfur dioxide, particulate matter, and nitrogen oxides.

It kicked in at the height of the environmental movement in the United States. The first Earth Day was fresh in everyone’s mind, and the federal Clean Water Act (CWA) and the Endangered Species Act were laying the groundwork for today’s markets in water and biodiversity.

 

A Wetlands Savings Account

So-called “mitigation banking” covers the quantity of biodiversity and wetlands – which are more than just standing bodies of water. A well-functioning wetland plays a key role in filtering water and thereby “delivering” the ecosystem service of reliable water quality, as well as providing habitat for many plants, insects and animals that are part of the biodiversity of an area. These “services” are difficult to quantify – one reason environmentalists are up in arms over schemes that replace true wetlands with ponds and other bodies of isolated water.

Mitigation banking involves building up reserves of water capital, and is a key response to the CWA’s section 404.

The Act mandates that anyone who plans to dredge a wetland that nurtures other waterbodies try to find a way to avoid its destruction. When this is not possible, the developer must first get a permit through a program administered by the U.S. Army Corps of Engineers and the US EPA. Then, if a permit is granted, the developer must “establish, enhance, restore or preserve” an amount of wetland equal to or greater than what is being dredged – usually in the same watershed.

Mitigation banks are essentially wetlands that have been pro-actively established, enhanced, restored, or preserved – in exceptional circumstances when the land was under significant threat – with the goal of generating credits that can be sold to developers later as offsets. The CWA requires mitigation banks to replace function as well as acreage of jeopardized wetlands, although many complain that the function requirement is often overlooked.

 

The Drive for Distribution

In addition, you have schemes that cover the distribution of water for drinking and agriculture, and no one has taken this further than the Australians, who’ve turned water into a commodity that is almost as easily-traded as electricity is in other parts of the developed world.

But it’s in the developing world that such schemes could have their greatest impact. Studies show that the poorest usually pay the most for clean drinking water, while many industries simply waste it for free. Trading could put a uniform price on clean, delivered water, thus both reducing industrial waste and enabling delivery to areas that currently have poor access for drinking.

 

Using Markets to Control Pollution

So-called “nutrient trading” covers the bulk of the quality side – although the boundaries between quantity and quality blur and overlap.

Most watersheds contain two types of polluters – “point” sources and “nonpoint” sources.

Point sources are the ones we hear about the most: industrial enterprises or urban waste treatment plants that directly pollute a watershed from a single pipe or point. Most point sources are regulated by the National Pollutant Discharge Elimination System (NPDES), and have been the cornerstone of water pollution control in the US since the passage of the CWA.

Nonpoint sources, on the other hand, account for a whopping 80% of the nitrogen and phosphorous that ends up in US waters – and most of these are unregulated, for a variety of political, social, economic, and logistical reasons.

These sources include farms, such as those that leached into the de la Motte’s watershed, as well as septic systems and new development whose pollution washes into a watershed over a diffuse area, usually in the form of run-off.

When run-off comes from agriculture, it’s called a “nutrient” – but it’s not the kind of nutrient your mother encourages you to eat with your Wheaties. Instead, these nutrients feed organisms that gobble up oxygen and lead to “dead zones” like those found in Europe’s Black Sea. Such dead zones have been labeled a greater threat to humanity than global warming by the Millennium Ecosystem Assessment, a United Nations-sponsored project that engaged over 1,300 scientists and is easily the most extensive research program to date focusing on ecosystems.

The technology for alleviating the problem of agricultural run-off is readily available. Farms can reduce their run-off by changing the way they till, plant, or fertilize – at a cost of about 1/65 of what factories in the developed world would pay to reduce their levels of pollution emissions, according to one study.

That’s where “nutrient trading” schemes come in. They put the reduction burden on factories and other point sources, but give them a chance to pay nonpoint polluters to reduce their pollution outtakes instead – so-called “point-nonpoint” transactions. In theory, industrial polluters will opt to pay farmers to reduce their pollution emissions along a river when those factories can’t afford to invest in technology to further limit their own discharges.

This is the current holy grail of water quality trading, but most activity remains “point-point” – partly because nonpoint sources are difficult to monitor, but also because it’s difficult to measure results. Also, non-regulated entities such as farms may be afraid of getting involved in voluntary schemes, no matter how lucrative, because they fear it will bring them into what they see as a regulatory boondoggle. In the weeks ahead, we will be addressing solutions on the table for addressing these and other issues.

 

The Beat Goes On

And there is, indeed, plenty on the table – with water schemes being proposed and implemented across Latin America, Asia, and Africa – as well as the United States, which got started in the early 1980’s with point-point effluent trading on Wisconsin’s Fox River and point-nonpoint trading on Colorado’s Dillon Reservoir.

In 1996, the US EPA formally threw its support behind these trading programs, and several state initiatives have followed suit: Michigan with draft rules for nutrient trading in 1999, followed by the Chesapeake Bay Program in 2001.

The Chesapeake Bay Program, a multi-jurisdictional partnership that is working to restore and protect the Bay and its many resources, encompasses the three Bay states (Maryland, Pennsylvania, and Virginia), the District of Columbia, and the US EPA. But rather than being a unified trading program across the entire watershed, it is more of a hodgepodge of efforts with each state running its own trading scheme.

In early 2003, the US EPA released its Water Quality Trading Policy, identifying general provisions the agency considers necessary for creating credible watershed-based trading programs. Over a decade in the making, this policy identifies the purpose, objectives and limitations of these and other trading opportunities. The EPA has even gone so far as to publish a map of trading programs in the US and a trading toolkit.

The policy is flexible by design, letting states, interstate agencies, and tribes develop their own trading programs that meet CWA requirements and localized needs. Critics, however, say it’s too flexible, failing to identify tradable pollutants and other basic parameters. This leaves the system undefined and fails to generate the kinds of certainty a true market requires.

 

Drivers for Water Quality Trading in the US

Two major factors in the mid to late 1990’s prompted not only the rapid increase of water quality trading programs in the US, but also a fundamental change in the way that water quality trading programs are developed and implemented. The first factor is the highly-publicized success of the Acid Rain Program, which demonstrated the efficacy of market mechanisms when coupled with proper government enforcement mechanisms. This convinced many policy makers that emissions trading could be applied to water pollution control.

The second factor is the increasing number of so-called “ TMDLs” (Total Maximum Daily Loads) being developed by states and US EPA as mandated by the CWA.

A TMDL is the maximum amount of pollution that a water body can assimilate without violating state water quality standards, and individual states determine the specific TMDLs for specific pollutants in specific bodies of water. TMDLs don’t just cover chemicals, but also things like temperature. In theory, they can act as de-facto caps for emissions in cap-and-trade water schemes, and approaches based on TMDLs and a handful of other tools are already being tested across the United States.

The calculations themselves are complex and the subject of much debate, but the existence of TDMLs identifies the sources and estimates the quantity of pollutants targeted for possible trading. This debate, in part, helps create the driver for a market – for in a well-structured market, the price of a pollutant will be tied to the actual amount of reduction necessary to meet the TMDL, and not to an arbitrary cap.

Water-quality trading can also occur on a “non-TMDL” waterbody (one that is not impaired or one that the government has not gotten around to developing a TMDL for), and trading can occur much sooner because nonpoint sources do not have to meet the TMDL minimum before a trade can occur. This is generally referred to as “pre-TMDL” trading.

This allowance was made because the TMDL minimum threshold may, in many cases, be too high and too expensive for nonpoint sources to meet, and could discourage them from pursuing a trade.

For a trade to occur in a TMDL waterbody, nonpoint sources must first meet their load allocation, then any additional amount of reduction they can accomplish can be sold to offset point source loads.

The TMDL trading unit is the specific pollutant identified in the TMDL. For example, in nitrogen TMDL, the unit is one pound of nitrogen removed from the waterbody; for a temperature TMDL, the unit is one degree of temperature lowered in the waterbody.

Despite the availability of these promising mechanisms, however, demand has been slow to materialize. For these markets to reach their true, enormous potential, awareness must be spread across both the private and public sectors – and to the community at large.

Next Week: Guest authors Mark Kieser and “Andrew” Feng Fang of Kieser & Associates analyze the framework within which water quality trading is evolving in the United States, and offer a round-up of projects underway across the country.

This introductory was compiled from essays submitted to Ecosystem Marketplace over the past two years, and we would like to thank Mark S. Kieser and “Andrew” Feng Fang of Kieser & Associates, Ricardo Bayon of EKO Asset Management Group, Amanda Hawn of New Forests, and regular Ecosystem Marketplace contributors Alice Kenny and Erik Ness.

Steve Zwick is managing editor of Ecosystem Marketplace. He can be reached at [email protected].

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Analysis: Why saving the world’s rainforests is good for the climate and the US economy

The 13th Conference of the Parties to the United Nations Framework Convention on Climate Change (COP 13) is more than a month behind us, but plenty of debate lies ahead as advocates and opponents of using forestry to combat climate change air their opinions in the lead up to COP 14 later this year in Poland and COP 15 next year in Denmark. Jeff Horowitz and Robert O’Sullivan of Avoided Deforestation Partners take stock of the Bali Roadmap and what it means for avoided deforestation.

25 January 2008 | In December, more than 10,000 politicians, scientists, NGO representatives, and academics inundated Bali, Indonesia, for two full weeks. The goal was to negotiate, lobby, and struggle through the increasingly complex web of international climate change policies. At the end of it all, an agreement was reached as part of the “Bali Action Plan” to spend two more years negotiating a future agreement that should include reducing deforestation in developing countries – something that currently accounts for a whopping 15 to 25 percent of global greenhouse gas emissions.

Critics have dismissed this round as being too technical and too soft on action, but a closer look at the Bali decisions shows that the event yielded significant decisions that will impact future US engagement in international climate policy and the future of millions of hectares of tropical forests. Surprisingly, this in turn becomes significant for US companies.

The US did not ratify the last treaty to address climate change – the 1997 Kyoto Protocol. The Clinton administration agreed to the text of the agreement in 1997, but the Bush administration pulled out before it became binding in the US, arguing that developing countries were not required to do enough to reduce their own emissions under the agreement, which meant this would hurt the US economy.

Despite the bashing it receives in some quarters in the US, the Kyoto Protocol was ratified by over 175 countries and is regarded as one of the most revolutionary and successful pieces of international environmental law ever passed. The treaty has created a multi-billion dollar market for trading emission-reduction credits and helped trigger billions of dollars of underlying investment into renewable energy and other projects in developing countries that reduce greenhouse gas emissions.

The Costs of Deforestation

The Kyoto Protocol did not, however, address the critically important issue of deforestation in developing countries, which contributes more carbon emissions than the entire world’s transportation sector. If these emissions are not reduced, then all the efforts of all those well-meaning people buying renewable power, driving a Prius, or turning down the thermostat this winter will come to naught.

And stopping deforestation is about more than just climate change. It’s about saving the homes and livelihood of indigenous people and preserving fragile swathes of biodiversity that have taken centuries to evolve. These are being permanently decimated at a rate that, if unabated, will wipe out Indonesia’s entire orangutan population in 20 years.

But the real damage is less visible. Loss of plant biodiversity, for example, disrupts the chemical composition of the atmosphere and, with it, weather patterns. There is some evidence linking reduced biodiversity and the resultant shifts in weather patterns to drought in Latin America, and we have all heard of the lost opportunities to find new medicines as valuable species perish.

The Bali Solution

The agreement on deforestation incorporated into the Bali Action Plan is remarkable as it offers hope that something will be done to stop this destruction. Equally important, the Bali outcomes contain a possible way forward to addressing concerns the US had with the Kyoto agreement.

First, a number of developing countries have stated in the Bali decisions that they may be willing to take action to reduce deforestation. Second, reducing emissions from deforestation is the most cost-effective way to reduce emissions globally. New technologies are not needed and deforestation can be reduced now.

One of the favored sources of finding the $10 billion or more per year it is estimated is required to significantly reduce deforestation is to expand the booming emissions trading market created by the Kyoto Protocol. If this increased supply is met by increased demand this expansion is good. Including deforestation in the emissions-trading market will reduce the overall costs of cutting emissions globally, making it a win-win situation for the economy and the world’s forests.

Many US companies are already faced with state-based legislation to reduce their emissions, with expectations that more federal legislation will follow. Most reductions need to happen domestically, and many cost-effective options are available. However, if US companies are able to partially use the international carbon market, they will be able to meet overall reduction targets more cost-effectively. This will help reduce the overall costs to the US economy that many fear – correctly or not – may be incurred if the US embraces emission caps.

The Bali Action Plan is significant as it opens the window to engage the US and US companies to become part of the global response to avert a climate catastrophe and save the world’s rainforests before they disappear forever.

Jeff Horowitz and Robert O’Sullivan are founding partners of Avoided Deforestation Partners (www.adpartners.org) an independent network and think tank on deforestation policy. Robert is also the Executive Director, North America for the consulting firm Climate Focus. AD Partners were intimately involved in the recent international treaty policy negotiations in Bali regarding the inclusion of provisions to use carbon trading to save tropical forests.

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Social Carbon Joins the Party

Brazilian NGO Ecolí³gica has been promoting the social benefits of carbon projects since long before “non-carbon” attributes became fashionable. Now, with voluntary carbon offset projects being judged (and priced) as much for their impact on local communities as for their impact on carbon emissions, they’re taking their methodology global by teaming up with international market players and joining the gaggle of standards with links to registries.

31 October 2008 | Rice grows in boat-shaped husks that taste nutty-soft when steamed to perfection – a treat most of us never get to enjoy (and those of us who do aren’t, as a rule, impressed). That’s good news for Ceramicas Reunidas, a family-owned Brazilian brick production company that recently earned carbon credits for switching its fuel from rainforest trees to discarded rice husks.

It’s a small project, designed to reduce emissions by just 16,000 tons of CO2 per year by switching from non-renewable biomass or fossil fuel to renewable biomass, but the focus of the project expands beyond sequestration to the human dimension. The fuel switch and technology upgrade was carried out in accordance with Social Carbon Methodology (SCM), a set of procedures designed over the past decade to promote carbon offset projects that contribute to sustainable development in local communities.

Like the better-known Climate, Community, and Biodiversity (CCB) Standards, SCM is not a stand-alone tool that defines agreed-upon methods for measuring carbon capture itself. That’s left to entities like the Voluntary Carbon Standard (VCS). Instead, SCM is a sustainability screen: it helps identify and promote “non-carbon” benefits flowing from projects that already meet the requirements of basic carbon standards.

“There will not be a separate certificate issued for Social Carbon credits and VCS credits,” says Stefano Merlin, the Italy-born economist who helped spearhead the development of SCM. “Instead, the Social Carbon designation will be embedded in a tag on the VCS certificate, so it may say ‘VCS/Social Carbon/001’ or something like that.”

“Social Carbon breaks sustainability into six ‘resources’ (see below), which is pretty comprehensive in terms of coverage of aspects of sustainability,” says Jochen Gassner, Director of Climate Neutral for German carbon broker First Climate. “They’ve got their indicators for all of these aspects, which is a good complementary assessment to what the normal standards such as VCS and VER+ do.”

Long-Time Coming

Although new on the global radar, the SCM has been in the works for roughly a decade.

“It evolved as a methodology before you had the concept of a formal standard like the VCS,” says Merlin, who in 2000 co-founded the Ecolí³gica Institute together with Brazilian agronomist Divaldo Rezende.

Ecolí³gica is a Brazilian non-governmental organization (NGO) that promotes sustainable solutions to environmental problems, and the methodology was created to monitor the Institute’s own projects.

“We started working on it in 1998, and it evolved over time,” says Merlin. “Only recently did we start calling it a standard, but it’s really a methodology.”

Today, Ecolí³gica administers the methodology, with projects being verified by third-party entities such as the Brazilian division of Germany’s TÃœV Nord.

CantorCO2e and TZ1: Taking it Global

More than 80 Latin American projects have so far become SCM-certified, but the methodology remained one of Brazil’s best-kept secrets until earlier this year, when Ecolí³gica and London-based project developer CantorCO2e launched the Social Carbon Company to develop projects around the world in accordance with SCM.

“The mission now is to expand beyond the boundaries of Brazil, and spread to as many organizations as possible,” says Merlin, adding that it’s easier to grow internationally with a global partner like Cantor, and that some of the profits from the company will be funneled back into Ecolí³gica. “The company licenses the Social Carbon Methodology to implement projects, and the Social Carbon Company is also a project developer utilizing the methodology.”

This week, Social Carbon and New Zealand-based environmental markets infrastructure provider TZ1 announced that TZ1 would act as the global registry for Social Carbon Credits – which are defined as carbon credits that have been validated under both SCM and a more basic standard, such as the VCS or even the Kyoto Protocol’s Clean Development Mechanism (CDM).

TZ1 is one of four registries selected to support VCS credits under a system that is still being put into place. It’s also the only registry that can initiate Social Carbon credits, but these credits can then be transferred to other registries acting in support of VCS once the four-registry system gets off the ground.

CCB and SCM

The challenge now is for Social Carbon is to differentiate itself from existing “co-benefit” standards like the CCB Standards and carve out its own niche in the market.

“Some areas of differentiation are obvious,” says Merlin. “For example, CCB is forestry-focused, while Social Carbon covers more technologies, like energy efficiency, fuel-switching, and small-scale hydro.”

But, while SCM has broader coverage than CCB in terms of carbon-reduction technologies, it has a narrower focus in terms of non-carbon benefits.

“You could argue that CCB focuses more on biodiversity than we do, while we focus more on sustainability,” says Merlin, adding that SCM does measure biodiversity, but sees it more as a resource that contributes to sustainable development than as an end in itself.

“Both methods are very comprehensive,” says Gassner. “We use both Social Carbon and CCB, depending on what type of project it is.”

Joanna Durbin, head of the CCB Alliance, agrees on the distinction – to a point.

“We come from a broad group of environmental NGOs, many of them concentrated on biodiversity,” she says. “Also, because we’re focused on land-based projects, biodiversity is a bigger issue, which it isn’t for energy projects.”

She emphasizes, however, that the CCB Standards do require proof of positive impact on communities, even if they don’t go into as much detail on how to foster sustainable livelihoods. She says the two initiatives don’t so much compete as they “fit together” – partly because of the slightly different focus, but also because one is a standard that focuses on results, while the other is a methodology that focuses on procedures.

“We’re not prescriptive about the methodology that a project uses,” she explains. “Rather, we say that a project has to demonstrate that it has identified the local stakeholders and gotten them involved, and that it has a net positive impact on local communities and has mitigated potential off-site negative impacts.”

The two are not mutually exclusive, and she believes we will one day see projects developed using Social Carbon Methodology that then get verified according to the CCB standard.

Stand-Alone or Alliance?

SCM also differs from CCB in its structure. While CCB is administered by a broad-based group of NGOs (the CCB Alliance), SCM is administered only by Ecolí³gica.

“That could make it difficult for SCM,” says Gassner. “There is some discussion of criteria for eligibility of standards that will be recognized by the International Carbon Reduction and Offset Alliance (ICROA), and the way the conversation is going, they will say that any approved standards should be governed either by an alliance or by a company that doesn’t have business interests other than the standard.”

Six Resources

SCM is built on the work of researchers Robert Chambers, Gordon Conway, and Ian Scoones, who defined what constitutes a sustainable livelihood. Scoones then came up with five different “resources” that contribute to sustainability (natural capital, economic or financial capital, human capital, social capital, and physical capital).

Merlin and his team adopted four of the resources for their methodology and then added two of their own: biodiversity (or technology, depending on the type of project) and carbon. They also decided to rate the availability of each resource in a particular region, and support projects that promote that availability (see “Social Carbon Guidelines”, right).

They define the resources as follows:

Biodiversity Resource The combination of species, ecosystems and genes that form the biological diversity present in any region. Relevant aspects of this component are the integrity of natural communities, the way people use and interact with biodiversity, the state of conservation, pressures and threats imposed on native species, and the existence of priority areas for conservation.

Natural Resource The stock of natural resources (eg soil, water, air, genetic resources) and environmental services (soil protection, maintenance of hydrological cycles, absorption of pollution, pest control, etc.) from which those resources derive.

Financial Resource The basic capital (money, credit/debt and other economic goods) available to people and organizations.

Human Resource The skill, knowledge and capacity for work that people possess, as well as good health.

Social Resources Work networks, social demands, social relations, relationships of trust, and association in social groups.

Carbon Resource The type of carbon project being developed.

Steve Zwick is Managing Editor of the Ecosystem Marketplace. He can be reached at [email protected].

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Building Biodiversity Business

Markets haven’t been kind to biodiversity – because its value lies outside our economic system. The Ecosystem Marketplace exists to change that, and we’re not alone. Earlier this year the International Union for Conservation of Nature (IUCN) teamed up with Shell International to examine evolving mechanisms and treaties for turning biodiversity into something markets can embrace rather than destroy.

Excerpted from “Building Biodiversity Business“, which is available both in hard copy ($30) and free download at the IUCN Web Site.

3 October 2008 | Biodiversity forms the foundation and fabric of life on earth but is eroding beneath the feet of human activity. In the poorest countries, the deterioration of the natural environment is making it increasingly difficult for millions of people to meet even bare subsistence needs. Equally, as countries prosper, society is becoming less tolerant of environmental damage and increasingly aware of the extent to which our economies depend on healthy and diverse ecosystems.

Successive international treaties and national strategies have committed governments to stem the tide of biodiversity loss. An imposing edifice of environmental policy is in place in most countries. As much as US$20 billion per year is raised from public finance and private philanthropy for global conservation activities – much of this money is used to maintain over 100,000 protected areas covering nearly 12 percent of the world’s land surface. Yet all this is not sufficient. The fact is that current efforts to conserve biodiversity are overwhelmed by the adverse impacts of growing human economies. Spending on protected areas remains deficient and undervalued ecosystem services are being eroded.

If current approaches to conservation are not sufficient, what more can be done? One answer is to harness the very market forces that are often blamed for biodiversity loss. The challenge is to re-orient the economic incentives that drive private investment, production and consumption, and to make biodiversity conservation a viable business proposition in its own right. In other words: building biodiversity business.

Biodiversity business is defined in this report as: ‘commercial enterprise that generates profits via activities which conserve biodiversity, use biological resources sustainably, and share the benefits arising from this use equitably’.

Getting Business on Board

This definition reflects the three over-arching goals of the United Nations Convention on Biological Diversity (CBD), which also calls for increased efforts to enlist the private sector in biodiversity conservation, sustainable use and equitable benefit sharing. In both the environmental and business communities, there is growing recognition of the potential to conserve biodiversity on a commercial basis. If even a small proportion of private capital flows, international trade and national economic output could be harnessed for biodiversity business, the resulting contribution to conservation would be enormous. Increased private investment in biodiversity business would have the greatest impact in developing nations, where the conservation funding gap is most extreme and where many critically endangered species and habitats are virtually unprotected today.

This report presents a snapshot of the emerging biodiversity business landscape, its constraints, opportunities and requirements. It is based on a 12-month study involving literature review, analysis and extensive consultation with practitioners, policy-makers, donors and commercial investors.

From a conservation perspective, a major attraction of biodiversity business is the potential to generate new and additional investment in conservation activities. At the same time, some people remain skeptical of the motives of the private sector; while others worry that market-based approaches may distort conservation priorities. Nevertheless, this report argues that not exploring what markets can deliver is no longer an option.

From a business perspective, the reasons to invest in biodiversity business are increasingly compelling. They are most obvious in cases where private profitability depends directly on the health of ecosystems – ecotourism ventures, for instance. Similarly, it is now recognized that greater variability in genes, species and ecosystems is associated with increased resilience and biological productivity in agriculture, ranching, forestry and marine fisheries. Even businesses in urban areas, lacking a direct interaction with the natural world, can be motivated by new policy incentives and changing consumer preferences to ‘go green’. Corporate action on biodiversity can help businesses distinguish themselves from competitors while also improving relations with investors, employees, local communities and others.

From Rural Poor to Green Entrepreneurs

New biodiversity business models may also help reduce rural poverty. While employment and skills development are a normal part of every business, biodiversity business has the added benefit that it often stimulates a flow of funds from relatively wealthy urban centers to the countryside, as well as from industrialized to developing nations. Growing markets for ecosystem services and for biodiversity-friendly energy, food, fiber and recreation should provide ample opportunities for rural entrepreneurship and employment.

Today, biodiversity conservation is mainly viewed by business as a risk or liability, rather than a potential profit centre. However, this perception is beginning to change. As public awareness of the global biodiversity crisis grows, an increasing number of companies see a business advantage in developing processes to integrate biodiversity into their operations, as well as seeking market-based solutions and opportunities. Furthermore, even with modest initial returns from most biodiversity business investments – in the range of 5 to 10 percent per annum – there are significant profits to be made as the sector grows from niche markets to mainstream business.

Biodiversity = Business Diversity

A broad spectrum of different sectors and models of biodiversity business are examined in detail in this report. Their status and trends are described, along with constraints and opportunities for investment.

Examples include organic agriculture and certified timber. By demonstrating the potential of more sustainable production practices, these businesses are showing the way forward for mainstream agriculture and industrial forestry – sectors historically responsible for significant biodiversity loss. Although accounting for less than 5 percent of the overall market today, the growth rate of sustainable or certified products is three to four times greater than the market average. The market for sustainably harvested timber and organic agriculture, for example, has been growing at double-digit rates.

Businesses that provide a range of ecosystem services in emerging markets such as water quality and watershed protection are also considered in the report. One major area of growth is the demand for climate mitigation services through ‘biocarbon’ – i.e. biomass-based carbon sequestration in forests and wetlands and through soil conservation.

Another biodiversity business is based on the search for new compounds, genes and organisms in the wild, known as bioprospecting, an industry that could be worth US$500 million by 2050. The report also examines ecotourism, sport hunting and fishing. The latter sectors are already large and growing: ecotourism is expanding at a rate of 20–30 percent per year as compared to 9 percent for tourism as a whole, while private expenditure on recreational hunting and fishing is estimated at US$70 billion per year in the USA alone.

Is Biodiversity Itself a Product?

Less conventional markets include biodiversity offsets, wetland mitigation, conservation easements and biodiversity banking. Such businesses can be based on either legislation or voluntary commitments that oblige companies to minimize the biodiversity loss resulting from their activities and to offset (compensate) for residual losses by restoring or enhancing comparable sites. Emerging experience in Australia, Brazil, South Africa and the United States has shown that such approaches can make a significant contribution to conservation efforts and generate substantial business opportunities for offset providers, although there are concerns about the environmental effectiveness of offsets.

One major hurdle facing all biodiversity businesses is developing practical indicators for measuring negative impacts and positive contributions to biodiversity. Experience in some countries shows that biodiversity assets, in the form of endangered species or natural habitat, can be registered, tracked and even traded under appropriate regulatory frameworks. Nevertheless, the world still lacks agreed standards, methods and indicators for valuing ecological assets and ecosystem services.

The Role of Government

The development of biodiversity business also depends on a conducive enabling environment, namely the framework of laws, regulations, taxes, subsidies, social norms and voluntary agreements within which companies operate. For businesses to value biodiversity, it must ultimately become more profitable to conserve biodiversity than to ignore or destroy it. A combination of increased rewards for conservation, increased penalties for biodiversity loss and increased information on the biodiversity performance of business will help to create a biodiversity-friendly economy.

In many countries, significant reform of the enabling environment may be required to enable biodiversity business to grow, particularly where existing policies are predicated on conservation of biodiversity by governments and charities, where the role of business in conservation is limited by law, or where policy incentives such as ‘perverse subsidies’ are causing continued harm to ecosystems.

Business and Conservation: Bridging the Knowledge Gap

Another constraint on biodiversity business is the lack of understanding between the worlds of business and nature conservation. Priorities, time scales and jargon all differ. Natural scientists often lack the financial acumen and consumer orientation of the private sector; conservationists typically lack business planning and management skills.

At the same time, most business people lack understanding of how their companies’ operations affect and are affected by biodiversity and ecosystem services, or how to manage biodiversity in their operations. In addition, the long-standing difficulties of integrating conservation and development agendas still remain. Nevertheless, new biodiversity business tools are being developed that can bring these worlds together and bridge gaps in planning, management and performance assessment.

Patient Capital: Finding the Money

Even with the best policies and tools in the world, biodiversity benefits will not materialize or be sustained unless biodiversity businesses survive long enough to become commercially viable. Access to patient capital for investment and expansion is a critical factor in the growth of biodiversity businesses. While most businesses depend on financial support from banks or investors to cover initial start-up costs, in the case of biodiversity businesses there may be a need for some grant finance or subsidies to help entrepreneurs get beyond the pilot and learning phase and to stimulate demand for commercial conservation services.

Various existing financing instruments have been adapted for biodiversity business, ranging from grants to debt and equity finance. The experience of early and on-going initiatives can help guide the choice of an appropriate financing blend for new biodiversity businesses. While most biodiversity fund managers seek co-financing and prefer debt finance to equity, a range of innovative financial solutions are being tested that combine commercial and non-commercial investors. The integration of financing with technical and business support is increasingly common and can help ensure that biodiversity business delivers significant conservation outcomes as it grows.

These are early days for biodiversity business and there is much to learn. One clear need is for an integrated approach to building biodiversity business, combining policy advice, technical assistance and innovative finance, at a vastly increased scale compared to current efforts.

The Biodiversity Business Facility

This report outlines a proposed Biodiversity Business Facility, which would function as:

• a think-tank, to address and influence the enabling environment and develop biodiversity business metrics
•a business incubator, to build capacity and provide technical assistance to support new biodiversity business ventures, and
•a funding mechanism, to invest in and secure co-finance for growing biodiversity businesses.

Although the eventual scope and form of such a Facility remains to be defined, its potential impact could be enormous. The first step is to assemble a portfolio of biodiversity business enterprise, in order to test, refine and demonstrate the viability of this new approach to conservation.

Around the world, there are mangrove forests that may soon be cleared to make way for shrimp farms, but which could instead be conserved through ‘payments for ecosystem services’ as natural fish hatcheries, storm buffers and water filtration systems. Similarly, there are thousands of fragments of degraded natural habitat that could be linked and restored, by means of biodiversity offsets, to form vital biological corridors for threatened species. And rural communities around the world could be supported to build the skills and networks necessary to market valuable non-timber forest products.

Pilot Projects

For such initiatives to flourish, for pro-biodiversity markets to develop, fixed ideas and institutional inertia need to be overcome. Experience is the best teacher and the coming years will be crucial to demonstrate, document and share the results of various market-based approaches to biodiversity conservation in different contexts.

Rhetoric is not sufficient. What is needed are more concrete examples of financially viable biodiversity businesses and functioning markets for ecosystem services. Only on the basis of practical experience will it be possible to convince all stakeholders – public and private – to work together to conserve biodiversity on a sustainable and commercial basis. The ultimate aim of this report is to promote more informed experimentation and investment, based on a clear understanding of what biodiversity business needs to thrive.

Joshua Bishop is Senior Adviser, Economics and Environment, at IUCN. His work focuses on how to promote economically efficient and more equitable approaches to nature conservation, while also presenting the case for conservation in economic terms. Prior to joining IUCN, Dr Bishop worked at the International Institute for Environment and Development in London, and as a consultant and staff member of several organisations in West Africa. A consistent theme of his work has been to enhance the contribution of nature conservation to poverty reduction through the use of economic tools and market-based mechanisms. Dr Bishop holds a BA from Yale University, an MPP from Harvard University, and a PhD from University College London.

Sachin Kapila is Group Biodiversity Adviser within the Sustainable Development Division of Shell International Limited. He has a broad range of experience encompassing strategy, project management and on-the-ground implementation, and a responsibility for establishing global biodiversity policy, developing appropriate tools and guidelines and managing / fostering relationships with key external organisations. Sachin came to Shell from one of the world’s largest environmental consultancies covering a variety of regions including Latin America, Africa, South-East Asia and the Middle East. He has a personal interest both in developing new and innovative approaches to conservation financing through market-based solutions and in methods of attracting investment through capital markets to deliver benefits to investors, the environment and local communities.

Frank Hicks has over 20 years of international development experience, the majority of which has been gleaned in developing countries. He is currently Director of the Business Development Facility at Forest Trends. Prior to this he founded and was President of Sustainable Development International, a Costa Rican organisation that provides consulting services on sustainable agriculture, agricultural certification, enterprise development, strategic planning, and development finance. He has also been Director of the Rainforest Alliance’s Sustainable Agriculture Program, and Vice President of Organic Commodity Products, an organic chocolate company, based in Costa Rica. Having been involved in promoting community-based eco-enterprises in various guises for many years, working on this report provided an exciting opportunity to analyse biodiversity business across a spectrum of industrial sectors and to feed information and insights into his work with Forest Trends.

Paul Mitchell is an independent consultant with over 15 years experience of management of environmental and social issues in the natural resources sector. His particular focus has been mining, aggregates and oil and gas in Europe, the Americas, Asia and Africa. In recent years he has worked closely with clients including the Energy and Biodiversity Initiative and the Business and Biodiversity Offset Program on guidance for companies that wish to improve their management of biodiversity. This report represents an opportunity for him to explore a complementary market-based approach and take a look at the ‘bigger picture’ of conserving biodiversity.

Francis Vorhies has over 20 years of international experience as a sustainability economist. In Johannesburg he set up Eco Plus, an innovative consultancy focused on business, economics and the environment, and in Nairobi he worked for the African Wildlife Foundation under a United Nations Development Programme (UNDP) / Global Environment Facility (GEF) grant to build biodiversity economics capacity in the forestry sector. In Geneva, Dr Vorhies established new global programmes on economics and business for IUCN, and in Oxford he was the chief executive officer of the European affiliate of the Earthwatch Institute. In early 2005, Dr Vorhies followed his wife’s career back to Geneva and founded Earthmind, a not-for-profit sustainability network. His interest in this publication is based on his belief that capitalist tools can help us to conserve biodiversity.

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Recovery Credits: Protection or Passing the Buck?

The US federal government has implemented a new scheme that pays private landowners to conserve species currently finding sanctuary on federal lands. Though similar to existing mitigation banking programs, critics say the new scheme lacks the controls needed to be effective. The Ecosystem Marketplace takes a hard look at the new market for Recovery Credits.

18 March 2008 | Peculiar as life has been for the golden-cheeked warbler, it recently may have become downright precarious. Singing its theme song, “buzz, lazy-dazy,” this endangered bird family inadvertently made its primary home in what later morphed into one of the largest heavy-artillery Army training sites in the United States in Fort Hood, Texas.

As bombs exploded and armored tanks scorched the earth across the 220,000-acre Army training base, the migratory songbird nested inside 66,000 bucolic acres the Army set aside for it as part of the Army’s responsibility under the Endangered Species Act.

But its lazy-dazy days of protection there are coming to a close. Fort Hood piloted a new protocol over the past year and a half called the “Recovery Crediting System“, which enables the federal government to shift its responsibility to adjacent private landowners – for a price.

The feds liken the scheme to existing mitigation banking projects, which make it possible for landowners to shift responsibility for species conservation among each other, thus enabling development while supporting endangered species.

Recovery crediting makes it easier for government agencies to shift their responsibilities to the private sector by engaging in a streamlined version of the practice – a move that could have major implications for conservation, because the federal government currently provides the nation’s largest protection for endangered species.

The feds argue that privatizing conservation in this way will promote efficient conservation, but critics say the streamlining has gone too far, and warn that a dearth of checks and balances makes it difficult to know if the species are actually being protected – hardly a recipe for a clear, transparent, and fair market.

 

The Battle Lines

Program supporters say the presence of endangered species should not hamstring government efforts to fulfill vital missions such as training men and women to defend their nation. “The army is in the business of managing endangered species land,” says Robert Wagner, PhD., a quantitative ecologist who provided consultation work for Fort Polk’s model program. “But it doesn’t want to be.”

Detractors, including Kieran Suckling, policy director for the national environmental group Center for Biological Diversity, calls the recovery program a “classic example of doublespeak.”

“Recovery,” he says, “does not typically involve destruction. But this program enables the destruction of public lands that until now have protected endangered wildlife.”

Interviews with biologists that shepherded the recovery crediting system through – as well as stakeholders who could benefit from it and environmentalists evaluating it – paint a picture of a program rife with possibilities but short on accountability.

It could fork over a windfall of taxpayer dollars to lucky landowners living adjacent to federal lands, but it appears less likely to steer significant business to the conservation bankers whose expertise lies in brokering deals between land developers constrained by endangered species and the environmental organizations that protect them.

 

The Latest Environmental Market

In terms of structure if not accountability, the recovery crediting system stands as the latest in a line of recent initiatives that encourage the private sector to help solve environmental problems that have long stymied government bureaucracies. It combines government oversight, financial incentives and private entrepreneurship to create a new environmental market whose goal is to protect a rare natural asset while freeing up valuable land.

This initiative was generally modeled after its slightly senior brother, conservation banking, and its older cousin, wetland mitigation banking.

Wetland mitigation banks date back to the early 1990s and are actual wetlands created, restored or enhanced by private companies or government agencies. Designed to comply with the federal Clean Water Act’s mandate of no net loss of wetlands, these banks allow developers to buy credits from wetland banks to replace marshes they destroy on private land.

Similarly, conservation banks, which began in the mid 1990s, allow developers to fulfill requirements under the Endangered Species Act to mitigate the effect their projects have on sensitive privately-owned land by purchasing “credits” at off-site locations where similar habitat is preserved in perpetuity.

 

The Logic behind Recovery Credits

Since 73 percent of the land in the contiguous United States is privately-owned according to the latest government figures, it appears sensible to enlist private landowners as partners in conservation by making it practical and financially viable.

The novelty of the proposed recovery crediting program is that it fosters this type of trade-off for at-risk-species on federal rather than private landholdings. Section 7 of the Endangered Species Act requires federal agencies to protect threatened and endangered species and ensure that their actions do not jeopardize listed species or destroy or adversely modify critical habitat. This has generally been interpreted to mean that the federal government protects endangered species on its own land where the species reside, as the Army had done in Fort Hood.

The new recovery crediting system will offer federal agencies such as the Army flexibility to offset the impact of their actions on threatened and endangered species found on federal lands by undertaking short-term or permanent conservation actions on non-federal lands, says Fish and Wildlife Service (FWS) spokesperson Valerie Fellows.

As the private sector does with wetland trading and conservation banking, Federal agencies can use the recovery crediting system to create a “bank” of credits accrued through beneficial conservation actions undertaken on non-federal lands. A federal agency can develop and store these conservation credits for use at a later time to offset the impacts of its actions on federal lands. Credits must be used to benefit the same species for which they were accrued.

In the pilot recovery crediting system tested at Fort Hood in Texas, the US Army funded habitat conservation and restoration projects for endangered golden-cheeked warblers with willing landowners on more than seven thousand acres of private land surrounding the military base. The FWS worked with the Department of Defense, the Texas State Department of Agriculture and other agencies.

“We’ll consult and ensure that the program is not likely to cause jeopardy and ensure that it provides a net benefit to the species,” says John Fay, an FWS biologist who shepherded the pilot program through the assessment process.

“If we’re sloppy,” he adds, “there could be some risk.”

 

Not Conservation Banking

Conservation policy in the United States for the last century has been built around the “irrefutable fact that we have a high degree of control over what happens on federal land and a low degree of control over private land,” says Suckling. “Therefore, we hold our federal land to a higher standard.”

The recovery crediting system promotes transferring this accountability from public to private control. If private landowners participating in the recovery crediting system are sufficiently regulated and monitored, golden-cheeked warblers and other endangered species may thrive.

“Whether a program like this is good or bad is largely dependent on how it is implemented,” says Robert Wagner, who provided consultation work for the model program at Fort Polk.

But under the program’s current design, say environmentalists as well as some conservation bankers set to profit from it, essential oversight needed to make the program an environmental and market success appears lacking.

“I have no doubt that there’s a potential market here,” says Wayne White, a retired FWS field supervisor and current project leader for Wildlands, Inc., one of the largest conservation banking businesses in the nation. “The disconnect is that the government is establishing credits similar to conservation banking while using an absolutely different and very weak standard…that undercuts real conservation.”

 

Where’s the Validation?

The differences between conservation banking and the new recovery crediting system are far greater, he added, than the distinction that the former involves private land while the latter involves land that is publicly-owned. Management and monitoring plans designating specific outcomes are required under conservation banking. The same degree of management accountability is not required under the recovery crediting program.

Another difference is that conservation banks provide non-wasting endowments to cover any future or unforeseen expenses. This type of future financial obligation is not spelled out under the recovery crediting program and could prove difficult due to the strain under which state and federal budgets operate.

Finally, conservation banks typically turn adapted properties over to environmental groups and other third parties for long-term monitoring and upkeep. In contrast, private landowners participating in the recovery crediting program retain control of their properties even though they may have limited experience and expertise in protecting endangered species.

“This is like letting the fox into the chicken coup,” White says.

 

Fast Track to Failure?

White and Suckling stand among approximately 100 stakeholders who filed comments evaluating the new recovery crediting system. Despite their concerns, the recovery crediting program has jumped hurdles that might otherwise slow down a proposal with implications this great. The U.S. Fish and Wildlife Service began piloting the program in Fort Hood in late 2006, says Wagner. It solicited public comment on November 2, 2007, and closed the comment period the following month.

Environmentalists complain that it is virtually impossible to assess the Fort Hood program’s degree of success because the FWS signed the conservation agreement under Texas state law, which offers unusually strong protection for private landowners, including strict confidentiality agreements.

Specifically, the Texas Parks and Wildlife Code, Section 12.0251, “prohibits (it) from disclosing certain information related to the location, species identification or quantity of animal or plant life located on privately owned land that is subject 5 to a Wildlife Management Plan.” In other words, information cannot be disclosed that would fully assess whether golden-cheeked warblers are thriving on land where recovery credits have been paid out.

“Why all these evasive maneuvers and secrecy if this is actually a beneficial program?” Suckling asks.

Nonetheless, Fay says he expects to see the new program up and running by June. By characterizing the recovery crediting system as “guidance” that does no more than offer an interpretation of Section 7 of the Endangered Species Act, “it doesn’t break new ground; it’s just a novel application” Fay says. “So it’s a done deal.”

“There is no doubt that there is a potential market (for this program),” says White. “I just hope that they’ll be smart enough to raise its criteria to the elevation of conservation banking.”

Alice Kenny is a prize-winning science writer and a regular contributor to the Ecosystem Marketplace. She may be reached at [email protected].

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Ecosystem Farming

Following its success with an innovative "Working for Water" program, South Africa has begun experimenting with a whole new approach to conservation and restoration; an approach that has scientists "mapping" ecosystem services and land-users "farming" them. The Ecosystem Marketplace takes a closer look at these recent developments and considers whether or not "trading" will be the next new verb for ecosystem services in the RSA. The photo looked like it came from Mars: a reddish, dry riverbed running beneath yellowed marshlands and brown hills. Even the sky, where white streaks striated a pale blue horizon, looked parched. The printer had run out of blue ink. The result was a photograph version of South Africa's Gariep River that looked decidedly thirsty. And yet, embedded as it was in a document entitled, "Working for Wetlands, South Africa," the unintended photograph seemed strikingly appropriate, even prescient. It read like a warning: take care of South Africa's wetlands or the Gariep Basin may, itself, run out of blue in the decades ahead. South Africa is a dry country and recent climate projections suggest that much of the nation will grow drier in the years to come. By 2025, according to a recent WWF document, "the country's water requirements will outstrip supply unless urgent steps are taken to manage the resource more sustainably." Fortunately, South Africans are taking steps to conserve their water resources and, notably, they are using an ecosystem service-based approach to fuel their progress. Protecting watershed services in South Africa has, in fact, become the catalyst for a whole new approach to conservation and restoration in the country, an approach that some in the business are calling 'ecosystem farming.' Ecosystem farming is interesting because it implies a very different approach to a long recognized environmental conundrum: biodiversity conservation and people's need to earn a living from their land don't always coincide. In the United States, the government generally has resolved this conflict by paying farmers to take their land out of production. In South Africa, both public and private interests are currently testing the feasibility of paying landowners and laborers to do the opposite, i.e. to put land into a new form of production – one geared towards ecosystem services. Against this backdrop, the recently published 'ecosystem services map' of the country's Gariep Basin is especially intriguing. Could the project – a product of the Millennium Ecosystem Assessment (MA), a four-year international effort to assess the state of Earth's ecosystems – represent a road-map, not just for the development of the Gariep Basin, but also for the whole of South Africa and, by extension, for the rest of the world?

A New Kind of Map

The Gariep is not only the longest river in South Africa, it is also among the most important and most heavily regulated. Large dams and complicated transfer schemes knit together over 665,000 square kilometers of catchment, as the river flows from the mountain nation of Lesotho through Gauteng Province and on into the arid western reaches of South Africa and Namibia. On its way, the Gariep system supplies water to Johannesburg, the economic hub of Southern Africa, fuels South Africa's "grain basket" (where food for approximately 70% of the nation is produced), and supports two international biodiversity hotspots. Given its ecological and economic importance, the Gariep Basin is, in many ways, just the sort of place in need of an ecosystem services map. And so it was that, in 2000, The Gariep Basin Millennium Ecosystem Assessment was born. Broadly speaking, the aim of the project was to provide a map that would be useful to policy-makers balancing the trade-offs associated with the protection and use of ecosystem services at the local, national and regional scales. Toward this end, the scientists used models and participatory methods to assess the location and "irreplaceability" of three types of ecosystem service in the basin: water services; food and fuel production; and services linked to biodiversity. Water reaches were assigned classifications ranging from A to F, according to their level of ecological integrity and industrial/agricultural function. 'A' regions of the river carried proposals for strict management practices that would support biodiversity in a near natural state. In descending order, Bs, Cs and Ds allowed for successively greater alterations of natural flow, water quality and temperature. Finally, recommendations were made that Es and Fs – stretches of the river so modified by human activity that their function potentially was impaired irreversibly – should be restored to D level when and where possible, but that some reaches of the river should be treated as sacrificial "workhorses" for industrial, agricultural and municipal water needs. Once the basin's present water resources had been mapped, the researchers next used models to forecast attainable classifications for each area in the future. This second map thus described the 'restoration capacity' of the catchment over the course of five years, charting a path toward an increased net flow of watershed services to a variety of sectors. A similar approach was taken in the mapping of biodiversity and food production services. The basin was gridded and each cell, representing a piece of land, was ranked according to the level of service it provided in three areas – the production of protein, cereal and biodiversity. "We used the notion of irreplaceability to assign comparable values to areas of land," explains the report. "Irreplaceability is a measure of how important the features that an area contains are to the achievement of a stated goal." In the case of the Basin, the scientists defined their goals as the provision of the nutritional needs (in terms of protein and calories) of 70% of South Africa's population and the preservation of a baseline measure of biodiversity. The resulting map, in which areas with high irreplaceability values look like bright spots on an electricity grid, indicates those regions that should be managed most carefully for each of the respective services. Importantly, the map also reveals regions of overlap, where the same geographic area provides irreplaceable services in terms of both biodiversity and food production. It is in these "ecosystem service hotspots," stress the scientists, that different management practices should be considered most carefully, with decision processes that weigh trade-offs explicitly and pricing policies that reflect the full cost of the land being used. While the project's managers are quick to point out that, "framing a question of ecosystem services only as an economic issue has several shortcomings," they also acknowledge that market forces can play an especially important role in assigning values to services in areas where the trade-offs between two or more management regimes must be considered. The basic notion of economics, of course, is that economic forces give price signals that, because they are continually revised, are an especially useful means of assigning and tracking value in dynamic systems. Thus, it is in the basin's most irreplaceable 'ecosystem service hotspots' that market-based conservation mechanisms may have a role to play: "We are currently exploring markets for ecosystem services," says Christo Fabricius, one of the lead investigators on the project, "but there are no examples in South Africa, that I know of, where this has been successfully implemented…yet."

Brick by Brick, Tree by Tree

While true market-based conservation programs per se aren't up and running in South Africa, a suite of public works programs is laying the foundations upon which they might soon be built. Throughout the 20th century, public works projects generally focused on regulating rivers – through dams, dikes or irrigation schemes – in ways that made them less natural. In the first decade of the 21st century, South Africa has been widely recognized for turning this paradigm on its ear through a program called 'Working for Water'. By restoring watersheds to their 'natural' state, South Africans are harvesting the benefits of ecosystem services while simultaneously providing jobs to their nation's poor. Invasive species suck up a great deal of water in South Africa – a single eucalyptus can use up to 400 liters of water in a day. Consequently, their removal immediately increases the amount of water available to recharge water tables. Recognizing that two of the country's wrongs – unemployment and water-scarcity – might make a right, the South African government began paying people to clear invasive species out of river catchments in 1996. They called the program Working for Water and, in the decade since its inception, they have watched it grow from strength to strength. Click here for more on WfW. Now, Working for Water's impact is rippling ever wider through a series of spin-off programs: Working for Wetlands opened up shop in 2000 to restore the water filtration services of native marsh habitat; likewise, Working on Fire began dispatching crews to sustain healthy forests/veld and prevent wildfires last year; and a new program near Port Elizabeth, called Working for Woodlands, is beginning to restore pastoral lands to sustain biodiversity and sequester carbon. Taken as a whole, the projects constitute not only the largest conservation program on the African continent, but also a sea-change in terms of the recognition of the value of the services provided by healthy ecosystems. "Programmes like Working for Wetlands, Working on Fire, and Working for Woodlands, not only provide 'value' and employment because of their pro-poor policies, but also engender a conservation ethic amongst their workforce," says Val Charlton, Advocacy Coordinator of the Working on Fire Programme. "We could use more programmes like this – with lots of synergy and potential income generation possibilities based on land-users acting responsibly, looking after their land." The idea that land-users might not only act as stewards of the ecosystem services flowing from their land but also benefit financially from doing so is the win-win goal of modern conservation – the environmentalist's version, so to speak, of having one's cake and eating it too. In the case of South Africa, however, the idea is that land-users are, at the same time, baking more cakes. This, in a nutshell, is the basic notion behind ecosystem farming. And so, importantly, the new programs in South Africa are not only mapping and harvesting ecosystem services like soil protection, water delivery and carbon sequestration, they are also investigating the long-term economic returns that might convince private stake-holders to invest in increasing them. Those at Working on Fire, for instance, are stating their case to private agricultural and silvicultural enterprises. "The commercial sectors of Forestry and Agriculture suffer extensive financial loss as uncontrolled fires destroy crops, plantations, buildings and equipment," reads the program's website. "As this project aims to provide direct benefits to private sector bodies, it is expected that this sector will in return, support the venture." Working for Woodlands, meanwhile, is investigating potential income streams to entice private and communal land-users to undertake restoration work on their land. "Ultimately the aim is to remunerate the land-user for delivering services such as biodiversity conservation and the protection and maintenance of ecosystem functions – i.e. erosion/soil regimes, water delivery and quality and –the most talked about one at the moment—carbon sequestration," says Christo Marais, the Executive Manager of Strategic Partnerships at South Africa's Working for Water Programme. Working for Water and its sister programs – because they are seeded and sustained by government money rather than by direct payments from the users of their services – are not true market-based mechanisms, but rather an excellent example of how innovative public programs can create positive synergies between poverty alleviation and ecosystem restoration. Nonetheless, as the programs explore new funding streams in the private sector and begin to cultivate the notion of ecosystem farming among landowners, they are inching South Africa ever closer to the widespread deployment of market-based conservation. Experts in the field, however, warn that, before the 'mapping' and 'farming' of ecosystem services can actually generate 'trading' in South Africa, uncharted and tricky waters have yet to be navigated.

Here be sea-monsters?

"South Africa is a mix of both first and third world economies, with all the challenges associated with such," says Charlton of Working on Fire. "At the third world level, poverty is dire, and it is extraordinarily difficult to preach ecosystem services approaches to an audience that is starving – they are not thinking about tomorrow, only the meal that needs to be put on the table today. Thus the first challenge is to make conservation meaningful to the poor." Charlton's point is an important one. In a country where 8 million people still lack access to safe drinking water, the notion of farming the resource for others is a foreign, even absurd, idea. "Although Payments for Environmental Services (PES) are understood as a market based mechanism, in most instances in this country and region poor communities are providing environmental services without compensation and these are typical cases of market failure and a lack of bargaining power in the transaction of services," says Paula Nimpuno of the Ford Foundation. "[Our] current work with Resource Africa has the intention of mapping but also of improving our understanding of how to make the ecosystem market approach benefit the poor." Bread and butter politics reign supreme among the poorest of the poor in South Africa. If they are to succeed, market-based conservation mechanisms like the users-pay approach to ecosystem farming described above (also known as a PES or ESP model) must justify their relevance in these starkest of terms. Equally important, they must make sure the poor can access buyers for the services they render and that they can negotiate with them on equitable grounds. Click here for more on PES programs and the rural poor.

It is not all Poverty

Although poverty is perhaps the most pressing issue relating to ecosystem services in South Africa, it is worth noting that 83% of the country is privately owned, much of it by white landholders who are not impoverished. What of market mechanisms in these areas? Mark Botha, of the Conservation Unit at the Botanical Society of SA, cautions that important conservation opportunities are likely to be missed if these parties are not welcomed to the table. "Tenure and ownership are well defined in the private areas, and there are opportunities to link specific payments to well defined management actions (biodiversity friendly land use, increased run-off, increased carbon storage). However, international NGOs and donors are not prepared to test PES with this politically marginal and not-poverty stricken group," says Botha, who has looked carefully at the PES approach in South Africa. "The focus on poverty and communities has taken us away from some more direct PES opportunities." Evidence exists to suggest that Botha is right in looking closely at private, as well as communal, land-users. Private landholders in the country have had the right to use and manage the wildlife on their land for the last several decades, and the result, according to the Millennium Assessment "has been a doubling of protected land as well as increased economic benefits." Clearly, private property owners are well positioned, and perhaps ready, to take up the challenge of ecosystem farming on a much wider scale than anyone else.

The Voyage Ahead

Finding the synergies between poverty alleviation and ecosystem service conservation, while at the same time ensuring market-access to both economically and politically marginalized populations, is the next challenge for South Africa as it moves from mapping and farming its ecosystem services, through to trading them. Tied up as this challenge is in the past as well as the future, striking the right balance will be neither simple nor easy. History has shown, however, that it would be a mistake to count out this particular nation's possibility of success simply because of political, social and economic complexities. When it comes to the successful navigation of troubled waters, there may be no better boat to follow than that flying the green, black and yellow flag of the New South Africa. Amanda Hawn is the Assistant Editor of The Ecosystem Marketplace, she may be reached at [email protected].

WWF Guide to Voluntary Carbon Standards

The voluntary carbon market has spawned more than twenty offset standards over the past year – enough to keep even the most diligent market participants feeling a bit overwhelmed. WWF has responded with a 105-page guide to the ten standards that have been around the longest, and the Ecosystem Marketplace takes stock of their efforts.

13 March 2008 | Anyone struggling to keep up with the slew of new carbon offset standards proliferating across the voluntary world will find it worth their while to download the WWF’s recently-released 105-page brochure Making Sense of the Voluntary Carbon Market: A Comparison of Carbon Offset Standards (pdf). It’s a clearly-written document that delivers on its promise of comparing voluntary standards – and although it doesn’t necessarily “make sense” of the voluntary market, it does provide a good primer for beginners and an adequate refresher for veterans.

As the title implies, the meat of the document is its analysis and comparison of ten voluntary standards currently in existence – a difficult task, because each standard has different objectives. The three authors (Anja Kollmuss and Clifford Polycarp of the Stockholm Environment Institute and Helge Zink of Tricorona) deal with this by using the Kyoto Protocol’s Clean Development Mechanism (CDM) as the benchmark standard against which the voluntary standards are measured – an iffy premise, as critics of the CDM can attest, and as the authors themselves make quite clear.

“Although the CDM additionality tool is well respected, it does not guarantee that only additional projects are approved,” they write early on. “Recent reports have shown that despite the fact that the additionality tool is required for all CDM projects, it is likely that a significant number of non-additional projects are registered.”

Analysis and Objectivity

The authors have also bent over backwards in their efforts to remain objective – despite WWF’s own involvement in and vocal support of the Gold Standard.

“The report itself needed to be as neutral as possible, and having a credible, neutral report was in WWF’s own interest,” says Kollmuss. “If WWF wanted to publish an advocacy piece, they could have done it in-house.”

The authors do leave room for their own subjective analysis – which they clearly label and delineate from the objective treatment that comprises the bulk of the document.

“I found the whole field is so complex that you can’t really make simplistic conclusions,” says Kollmuss. “There is no way to come up with a perfect standard because the way you define perfect depends on what your goal is—at the same time I wanted a space where I could write my opinions but wanted to make sure readers knew they were our opinions.”

Laying the Foundation

They also chose not to wade directly into the sticky territory of direct comparisons until providing a simple but dense summary of the CDM itself, and the result is an introductory section that serves as a tremendous aid if you understand the basics but aren’t clear on, say, the interplay between voluntary and compliance markets, or how exactly a project is designed and implemented, or when to call an offset a credit, and visa-versa.

The basic information on standards is woven into the narrative of the first half of the document itself – so, before giving you a chapter on each standard, they deliver chapters on concepts like “Additionality and Baseline Methodologies”, and then, within this, sub-chapters on “Additionality Requirements for Each Standard” and “Baseline Requirements for Each Standard”.

This provides a solid foundation from which to segue into a discussion of implementation procedures, and finally into the detailed analysis of each standard on its own – a section that takes up roughly half the document and wraps up with a summary matrix.

“The matrix was a little bit artificial,” says Kollmuss. “It took a long time for us to pull it together because we needed to go into quite a bit of detail to really divvy out what the differences are.”

Steve Zwick is managing editor of Ecosystem Marketplace. He can be reached at s[email protected].

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California Leading: New Thinking on Carbon Accounting

For four years California has been quietly developing a set of greenhouse gas emission accounting standards and a climate registry. Now it has come up with ideas on how to measure and account for the climate impact of forests. This work could one day have repercussions on carbon trading across the US and the world. The Ecosystem Marketplace takes a closer look. With Europe's newfound emphasis on carbon markets, with the impending entry into force of the Kyoto Protocol, and with the launch of the European Union's Emissions Trading System (ETS) in January of 2005, it comes as a bit of a surprise that some fundamental developments relating to the establishment of carbon markets appear to be coming from a country -the US- that steadfastly refuses to sign the Kyoto accord, and a state -California- that does not yet have (and is not currently planning) an emissions trading system. Although the US has been characterized as a climate laggard by many observers, there is a little-known initiative in California -the California Climate Action Registry- that has for three years been providing leading-edge thinking on issues of carbon accounting and emissions registries; issues that will likely prove instrumental in the creation of emissions trading regimes like those being put in place in Europe, Japan, Australia, and many other countries around the world. Indeed, on at least one issue -forest-related carbon and sequestration- the Registry has already begun to have an impact far beyond California's borders. In US politics, California has a history of instigating back-door revolutions: the sort of political change that happens when and from whence it is least expected. After all, the state is so big, and its approach to a variety of issues (especially environment) so progressive, that the California tail often wags the US dog: witness emissions standards for automobiles, anti-tobacco legislation, among others. So perhaps it isn't all that surprising that California, through the Climate Action Registry, should also be providing leadership on climate change. Still, for those interested in environmental markets, understanding the California Registry and its achievements is a worthwhile undertaking.

History of the Registry

The California Climate Action Registry was established by California law as a non-profit voluntary registry for greenhouse gas (GHG) emissions with a view to protecting and rewarding any early action companies might take in reducing greenhouse gas emissions. Diane Wittenberg, the Registry's President, puts it rather simply: "We are," she says, "a voluntary but rigorous registry that can help companies and others establish greenhouse gas emissions baselines against which any future reduction requirements may be applied. Additionally, all our registered emissions are third party certified and made publicly available through our web site (www.climateregistry.org)." The idea for the registry, she explains, started at the grassroots (or, if you prefer, at the point source) when a few companies in California went to the state government in 2000 saying they wanted to reduce their carbon emissions, but that, before doing so, they wanted some assurances from the state that their actions would not harm them down the line if a climate regulatory regime was established. Specifically, they said they wanted the state to protect their baselines and give them some sort of credit -should a regulatory system be put in place- for their early actions. They also wanted the state to help them gain recognition for their actions. The result of these requests was a law, California Senate Bill 1771 (SB 1771), and its amendments (e.g. SB 527) which were approved at the end of 2001. Together, these laws establish the California Registry and charge it with the following functions and responsibilities:

  • To enable the voluntary recording of GHG (greenhouse gas) emissions in a consistent certified format;
  • To qualify third-party organizations that have the capability to certify reported baseline emissions;
  • To maintain a record of all certified GHG emissions baselines and emissions results;
  • To adopt industry-specific reporting metrics;
  • To encourage voluntary actions to increase energy efficiency and reduce GHG emissions;
  • To provide participants with referrals to approved providers for technical assistance and advice on programs to monitor, estimate, calculate, report, and certify GHG emissions; establish emissions reduction goals; and improve energy efficiency;
  • To recognize, publicize, and promote participants;
  • To recruit broad participation from all economic sectors and regions of the state; and
  • To provide additional services for participants such as workshops, training seminars, and "best practices" exchanges.

From the point of view of business, what is interesting about the law is that, in return for participation in the Registry, the state of California undertakes to "offer its best efforts to ensure that participants receive appropriate consideration for early actions in the event of any future state, federal or international greenhouse gas regulatory scheme." In short, California promises to throw its considerable political weight behind carbon market leaders; not to mention provide them with some level of environmental recognition.

Carbon Accounting Standards

From the point of view of markets, what is interesting about the law and California's Registry is that early on, its creators realized that in order to give credit to the State's "climate leaders", they needed to set up the accounting systems, the reporting mechanisms, and the certification/verification mechanisms that would enable them to ensure that emissions were being, in fact, reduced, and to compare these reductions to those of others; to, in other words, differentiate between the apples and the lemons. As a result, since the passage of that law, the California Registry has spent a considerable amount of time and technical expertise to establish a set of protocols that enable companies to measure, report, and certify their emissions. These have recently been supplemented by two industry-specific emissions reporting and certification protocols: one for the power/utility industry sector, and one for the forestry sector. According to Peter Miller -a Senior Scientist at the Natural Resources Defense Council and a member of the Registry Board- what California's registry is trying to do is essentially establish the generally agreed accounting principles for carbon; the sort of ability to measure and verify emissions that will ultimately enable those emissions to be freely traded and marketed. "The closest analogy I can think of for the Registry," he says, "is the Financial Accounting Standards Board (FASB) which establishes the standards by which all company finances in the US are judged." It is these standards, he adds, that allow companies to be analyzed, understood, and ultimately traded. In a similar fashion, he expects that the standards being developed and tested by California's Climate Action Registry will ultimately enable not only carbon trading mechanisms, but also effective greenhouse gas regulatory regimes. "After all," he says, "you can't manage what you can't count." To which one might add: neither can you trade what you can't count.

The Benefits of Being Voluntary

The work that the California registry is undertaking may be innovative, but what makes it even more interesting is how this work is being undertaken. For instance, while the negotiations surrounding the Kyoto Protocol have been largely governmental (with NGOs and companies, it is true, working in the background and/or shouting from the sidelines), the California registry involves industry, government, and non-profits as integral parts of their work. To give but a few examples: representatives of government, industry, and NGOs all sit on the Registry's Board, have largely equal powers, and participate actively in the development of protocols, standards, and workplans. Additionally, the Registry has a membership structure that includes companies like Pacific Gas and Electric, Eastman Kodak, and BP, as well as NGOs like the Union of Concerned Scientists, the Natural Resources Defense Council, and Environmental Defense, together with local governments such as the City of San Francisco, the City of Los Angeles, and the City of San Diego. Wendy Puling, Director of Environmental Policy for Pacific Gas and Electric (PG&E), one of the State's largest power companies, says that from the perspective of a large company, the registry process has been a success. "We are a charter member of the Registry," she says, "and have been supportive of the concept since its inception." She explains that PG&E joined the registry for a variety of reasons, including: to get a better sense of their own emissions, to better understand how the measurement protocols work, to prepare for a more carbon-constrained future, and to influence the development of emissions protocols for the power sector. Puling continued: "We believe there will be some sort of regulatory structure on carbon in place in the US within the next 10 years. Now our crystal ball isn't any better than anyone else's, but we think this is the direction we are headed in, and if and when that happens, we want to be ready." She further explains that PG&E supports market based solutions to the carbon problem and has therefore been very happy with the way the Registry has allowed them to understand and experiment, in a non-threatening way, with the sorts of information they will need to provide as climate change regulations develop worldwide. "Being voluntary," says NRDC's Miller, "does have its benefits. If the process was too legal, we wouldn't be able to focus on doing just what is right. As it is, we've been showing that large companies, cities, and environmental groups can work together in reasonable and effective ways to address the climate problem." He notes that to the extent that the Registry has been successful, it has been largely due to the fact that it conducts its business "in an atmosphere that is open and not highly politicized or charged."

Going Beyond California

Miller further believes that the impact of the California registry will go -indeed has already gone- well beyond the state's boundaries. Already, he says, the Registry is working closely with the World Economic Forum on their on their global greenhouse gas registry, and he believes that ultimately the principles established by the California registry will be adopted and adapted by other US states, by other countries, and possibly even lead to creation of national and international carbon accounting standards sometime in the future. Agreeing with PG&E's Puling, he predicts: "Eventually, the US will have a regulatory regime for greenhouse gases. It may not be as broad or as good as some might wish, but I think it will inevitably involve some sort of trading. When and if that happens, the standards being developed in California will become increasingly important." Wittenberg agrees and points out that the Registry is already working closely with states that are exploring regulatory approaches to climate change in both the Northeast and Northwest of the US. "I could easily see California's work on the Registry," she says, "have an impact at the national level across the US." She also explains that some of the Registry's participants are not limiting themselves to only reporting on their emissions in California, but are also using the Registry's protocols to report on their national, or even global, emissions. "Kodak," she says, "is an example of a company that recently joined the Registry and is planning on using our protocols to report on its global emissions." One area where the Registry's work is already having national -and maybe even international- repercussions is in the measurement of carbon emissions and reductions from forestry projects.

The Forestry Protocols

As anyone involved with the Kyoto negotiating process will tell you, the issue of how (or even whether) emissions reductions credits from forests should be included in any carbon trading scheme is exceedingly difficult and contentious (see overviews of the case for and against forest sinks at https://ecosystemmarketplace.com/news/article.feat.027.php and https://ecosystemmarketplace.com/news/article.feat.018.php respectively). But while the Kyoto crowd continues to endlessly debate the whys, wherefores, and hows of forestry projects and their relationship to carbon emissions, the California Climate Action Registry recently approved a series of protocols and standards that go a long way towards resolving many of the long-standing disputes surrounding this issue. According to Michelle Passero, Director of Policy Initiatives at the Pacific Forest Trust, a non-profit environmental group that was closely involved in the preparation of the forestry protocols, the decision to look at the carbon implications of forests was actually taken by the government of California in law SB 812. This law, which was enacted in January of 2003, called on the Registry to "adopt procedures and protocols, including specified criteria, for the monitoring, estimating, calculating, reporting, and certifying of carbon stores and carbon emissions resulting from the conservation and conservation-based management of native forest reservoirs in California." After an exhaustive process that took over a year and a half and involved consultations and reviews with a wide range of experts, non-profits, other stakeholders, and even a series of public reviews, the Registry's Board approved the new protocols in October of 2004. "Addressing the issue of forests and their relation to climate change is important," says Passero, "because forests are the world's second largest source of anthropogenic greenhouse emissions; largely through deforestation. In other words, they are a part of the problem and so should also be a part of the solution." The idea behind the protocols, she adds, has always been to provide incentives for landowners in California to protect, maintain, or enhance forest cover. "We wanted," Passero explains, "for California's forests to provide both climate benefits, as well as benefits to biodiversity and to the people on the ground."

Key Provisions on Forests

Like all of the Registry's protocols, the Forestry protocols are quite thorough and rigorous. Indeed they are composed of three different protocols: (i) the Forest Sector Protocol which helps forest companies measure and report on their emissions of greenhouse gases from biological sources at the entity level (the aptly-named General Reporting Protocol looks at non-biological emissions at the entity level); (ii) the Forest Project Protocol which looks at the biological emissions of GHGs at the project, as opposed to entity, level; and (iii) the Forest Certification Protocol, which explains how information provided on biological emissions of GHGs from forestry entities and projects is to be verified and certified (all these protocols are available at http://www.climateregistry.org/PROTOCOLS/ ). Some of the key provisions of the forest protocols attempt to address many of the contentious issues related to sequestration that have come up during the Kyoto negotiations, including:

  • Additionality: For carbon stocks or emissions to be registered in the California Registry, the underlying forest activities must go beyond existing legal requirements, and they must truly be new. At the same time, anyone wishing to register emissions reductions from a forestry project must first have registered their emissions at the company or entity-wide level.
  • Permanent risk mitigation: According to the protocol, all eligible forestlands will have to be dedicated to forest use permanently through a deed restriction that is granted in perpetuity – i.e. through a conservation easement.
  • Net carbon stocks: The protocols set out a series of models to establish a baseline of carbon storage, and then provide steps that need to be taken to more precisely track the net gains and losses to the system. The Registry argues that their protocols provide a practical methodology that makes economic sense for landowners, while reliably reflecting the benefits to the atmosphere of proper forest management.
  • Native forests: Registration of forest carbon stocks and emissions must promote and maintain native forest types.

In addition to the above, the Registry's protocols go far beyond the current Kyoto thinking (and well beyond what the CDM currently allows), by accepting GHG reductions from three distinct types of forest projects:

  1. Conservation-based Forest Management: Forest projects that are based on the commercial or noncommercial harvest and regeneration of native trees and employ natural forest management practices;
  2. Reforestation: Forest projects that are based on the restoration of native tree cover on lands that were previously forested, but have been out of tree cover for a minimum of ten years; and
  3. Conservation: Forest projects that are based on specific actions to prevent the conversion of native forests to a non-forest use, such as agriculture or other commercial development.

Balancing Accuracy and Cost

Although NRDC's Miller believes that the above provisions make the Registry's Forestry Protocols extremely innovative -he in fact believes they are the first attempt by any organization anywhere to provide a rigorous yet practical system for measuring not just emissions of CO2 from forests, but also their role in sequestration- he does admit that in order to make the protocols workable, some shortcuts needed to be taken. For instance, he explains, the protocols do not address issues of "below-ground" CO2, the carbon dioxide that can be stored or emitted in forest soils. And this is no small omission, for he says that there can be twice as much carbon in the soils as in the atmosphere. "The problem," he says, "is that there is no easy or manageable way to measure these things. They are extremely heterogeneous and measurement/studies can be extremely expensive." He also says that the Protocols could have required registrants to certify reductions every year (instead of every five as the Protocols require) and to sample every tree every year, but he believes such onerous restrictions would have been counter-productive. "In other words," he explains, "we were constantly struggling with the issue of how much accuracy to require at what cost. In the end, I think we struck the right balance." So what now? Miller says the registry is currently in discussions with a number of forest companies about pilot projects that use the forest protocols, so these should be put to the test shortly. The Forest Trust's Passero, for her part, says that she would like to see other organizations take advantage of the Registry's work on forestry, particularly within the US. She adds that the protocols are very compatible with existing systems and are easily replicable. In other words, she believes they can export well. "Although the protocols were designed for California," she says, "95% of them can carry to other states and countries." Indeed, in a recent move, the Chicago Climate Exchange -a US-based carbon trading system- announced that as of November, 2004 it would accept emissions and reductions calculated using the Registry's forestry protocols for trading on its market, and added that it was in discussions with the Registry to further harmonize the two organization's reporting and certification requirements. It is also worth noting that the announcement was in fact made at the most recent meeting of the International Emissions Trading Association (IETA) in Zurich, Switzerland, so clearly the California Climate Action Registry is developing a solid international, as well as national, profile.

In Praise of Standards

This was to be expected. After all, it is precisely as a result of the growing interest in environmental markets worldwide, that people are beginning to pay closer attention to carbon metrics and accounting standards. As markets spread, people are coming to the realization that all markets -be they environmental or not- rely heavily on trust, standardization, and verification for their effective operation. Markets just can't function if people don't know what they are buying, if they can't measure what is being traded, and if there is no third party verification and certification of quality. So, again, in retrospect and with the benefit of hindsight, perhaps it should come as no surprise that players in the global carbon markets are beginning to gravitate towards the California Climate Action Registry and its set of coherent standards for measuring, reporting, and verifying emissions of greenhouse gases. That such standards are to be found in a perceived climate laggard such as the US matters less than the fact that they exist and that they are perceived as rigorous, credible, and most importantly, workable. Accountants and accounting standards may be much maligned, but they are nonetheless essential; even -or perhaps especially- when it comes to environmental markets. Ricardo Bayon is the Managing Editor of the Ecosystem Marketplace. He can be reached at [email protected].

The BioCarbon Fund

In keeping with its track record as an innovator of carbon markets, the World Bank recently launched the BioCarbon Fund, a fund designed to deliver cost-effective certificates of emission reductions while promoting additional social and environmental benefits, including land restoration, biodiversity conservation, and the improvement of local livelihoods. Benoit Bosquet tells us about this new fund and about some of the lessons the World Bank has learned in its four years of experience with carbon markets.

The World Bank Buys Carbon Credits on Behalf of Companies and Governments

Four years ago, the World Bank embarked on an interesting and innovative journey designed to stimulate and catalyze the emerging markets in carbon credits. First, the Bank helped create Prototype Carbon Fund (PCF), a leader in the field whose capital of US$ 180 million is today almost totally committed. Since then the Bank has been involved in the creation of the Netherlands Clean Development Facility, the Community Development Carbon Fund, the Italian Carbon Fund, and, as of May, the BioCarbon fund. A new facility created by the government of The Netherlands will become operational by mid-2004 and be co-managed by the World Bank and the International Finance Corporation. All together the World Bank is managing about US$ 410 million in carbon funds, a volume which is expected to grow to over US$ 500 million within a year as existing funds develop and new funds come on line. All the funds are featured at www.carbonfinance.org. Created by private companies and governments and administered by the World Bank, these funds invest in projects that mitigate climate change in client countries of the World Bank. Acting as a trustee on behalf of the contributors (called Participants), the Bank buys a volume of greenhouse gas emission reductions (also referred to as "carbon credits"). These emission reductions can either be used to help companies and governments meet their obligations under emerging regulatory regimes (e.g. the UN Framework Convention on Climate Change, UNFCCC, and its Kyoto Protocol) or can be traded on the emerging carbon markets. All credits come from projects undertaken in the framework of the Clean Development Mechanism (CDM) in developing countries or Joint Implementation (JI) in countries with economies in transition. Each fund has a different set of private and/or public Participants, its own specific objectives, project portfolio criteria, and a separate governance structure. The funds only pay for the credits when the emission reductions are verified or, in the case of the BioCarbon Fund, when it is established that the tons of carbon have effectively been sequestered in vegetation or in the soil.

Bringing the Carbon Market to Rural Areas

What sets the BioCarbon Fund aside as a trail-blazing and far-reaching initiative is that it is aimed at catalyzing "sinks projects", i.e. activities which sequester and conserve carbon in ecosystems and agriculture, and which are also referred to in Kyoto jargon as projects related to land use, land-use change and forestry (LULUCF). Although land-use changes are responsible for roughly 20 percent of global greenhouse gas emissions and one-third of total greenhouse gas build-up in the atmosphere, the use of LULUCF for mitigating climate change has been the subject of heated controversy. As a result, very few LULUCF projects have been undertaken to date. Despite a flurry of activity in the years 1996-1999, the share of LULUCF in total volume of carbon transacted between 2000 and 2003 was merely 9 percent, and only 7 percent when the last two years -2002-2003- are considered. The declining role of sinks and sequestration in carbon markets is due in large measure to the opposition of a number of environmental NGOs, which have been concerned with the potential social and environmental risks of the use of carbon sinks to meet Kyoto obligations. Now that the Parties to the UNFCCC have effectively addressed these risks and provided some guidance on the matter (see below), we believe the market for sinks is likely to grow. This could be good news for people living in rural areas throughout the developing world since, for them, sinks are really the only available entry into the carbon market. The reality is that though people living in rural areas lack the energy infrastructure to participate in the CDM, they nonetheless manage large natural resource bases -most notably land and forests- and their land use decisions can have large impacts on the global climate. For example, conversion of forest to agriculture releases carbon to the atmosphere, while afforestation of degraded agricultural land sequesters carbon out of the atmosphere and stores it in vegetation and soils. For these populations, payments per ton of carbon not emitted or sequestered can create incentives to improve land and forest management, with resulting benefits for both the local and global environments (e.g. reduction of soil erosion, habitat restoration), as well as significant improvements in people's livelihoods (e.g. higher soil fertility, adoption of new techniques).

The BioCarbon Fund Makes Business Sense

The BioCarbon Fund was officially opened to Participant contributions in November of 2003, and started operations in May of 2004 with capital of US$ 12.5 million contributed by the governments of Canada and Italy, Okinawa Electric, Tokyo Electric, and Eco-Carbone, a French project developer. It is expected that the capital will grow to US$ 20-30 million by the end of 2005. The BioCarbon Fund is attractive to companies and governments in search of affordable ways to meet their obligations under cap-and-trade regimes, as well as to trading and financial institutions for the following reasons:

  1. The Fund outcome price of greenhouse gas emission reductions delivered to the Participants is predicted to be less than US$ 5 per ton of carbon dioxide equivalent (t CO2e). This is much lower than current marginal greenhouse gas pollution abatement costs in the OECD. Additionally, a significant proportion of the emission reductions purchased by the BioCarbon Fund are intended to be fully compatible with the rules of the Kyoto Protocol's Marrakech Accords and related texts on the use of afforestation and reforestation in the Kyoto Protocol's CDM.
  2. Through the BioCarbon Fund, Participants can acquire a unique insight into the creation and implementation of carbon sink projects. Including sinks in a company's or government's climate change mitigation portfolio is important as it diversifies risks and taps into a source of greenhouse gas emission reductions that are intended to remain competitive for some time to come. The Marrakesh Accords adopted in 2001 capped the amount of CDM sinks credits Annex I countries can use to meet their Kyoto obligations at 1 percent of 1990 emissions, which means that supply will greatly exceed demand, with a depressing effect on prices, until at least 2012, i.e. the end of the first commitment period, for which the rules have been set. To illustrate excess supply, the BioCarbon Fund has received over 100 project proposals. These projects could supply a volume of emission reductions several orders of magnitude greater than what the BioCarbon Fund can acquire at its expected levels of capitalization, putting prices in the US$ 3-4/t CO2e range. Besides, these prices are payable upon delivery of the emission reductions (not in advance).
  3. Finally, buyers of emission reductions from the BioCarbon Fund improve their image as socially and environmentally responsible carbon buyers. A ton of carbon acquired through the BioCarbon Fund and preserved for the long term, has the same atmospheric effect as a ton of emission reductions achieved by an industrial project, but it also delivers important ancillary benefits at the local level. The fund is designed to ensure that developing countries, including some of the poorest countries, have an opportunity to benefit from carbon finance in forestry, agriculture and land management. So the emission reductions supplied by the BioCarbon Fund will have substantial additional benefits, including improving local rural livelihoods and alleviating rural poverty.

CoP9 and the Permanence Question

Clearly the issue of using sinks and sequestration to meet climate change obligations is a thorny one. In particular, the challenge for sinks is to prove that they can be sustained in the long term -to become "permanent"- and have a climate impact that is truly equivalent to that of emission reductions from energy projects. This issue was partially resolved at the 9th Session of the Conference of the Parties to the UNFCCC (CoP9), which took place in December 2003 in Milan, Italy. To a certain extent, the draft decision reached at CoP9 confirms what the World Bank had anticipated in designing the BioCarbon Fund: the need to manage the risk of non-permanence by relying on credits which have a validity limited in time and are periodically verified. Specifically the rules resolve the controversial permanence issue by allowing credits for afforestation and reforestation projects for up to 60 years, subject to verification and certification of continued storage of carbon every 5 years. In a way, the CoP9 decision is more favorable than anticipated, since earlier proposals limited the validity of temporary credits from 5 to 35 years maximum. An important aspect of the CoP9 decision is that it focused the minds on the endgame, on the need to replace the temporary credits at a maximum of 60 years. Would the buyers of temporary credits through the BioCarbon Fund have to replace their credits, thereby endorsing an open liability and the need to purchase the same credit twice? If so, would the price per ton remain affordable? To manage this replacement risk, the BioCarbon Fund will cover the eventual replacement of the temporary credits by the purchase, on a cash forward basis, of certificates of permanent emission reductions generated from energy projects in World Bank-managed carbon funds other than the BioCarbon Fund. By paying a low price upfront for the delivery of permanent emission reductions after 2012 (there is not yet a market for such emission reductions), Participants can cover their replacement risk at an affordable cost.

Markets for The BioCarbon Fund

Governments and companies can join the BioCarbon Fund with a minimum contribution of US$ 2.5 million, which is paid either at the time of joining or on a draw-down schedule over about 10 years. Only accredited investors as established by United States securities legislation are allowed to participate. In Europe, the BioCarbon Fund faces the challenge that certificates from CDM and JI sinks projects are excluded from the European Trading Scheme (ETS) until 2008, so demand is limited (see article on EU ETS here ). Nonetheless, the ETS does not cover all sectors and may not be sufficient for Europe to meet its commitments under the Kyoto Protocol. Complementary action will almost certainly be needed if Europe is to meet its obligations. And to do this, European governments are allowed to use CDM and JI sinks to fulfill their Kyoto obligations. For this reason, it is expected that several European governments will find the BioCarbon Fund an investment of choice. In Japan the World Bank is marketing the BioCarbon Fund in collaboration with two agents, Natsource Japan and Mitsui/CO2e.com. Beside Okinawa Electric and Tokyo Electric, other companies have expressed interest in participating in the fund and are reviewing the legal and financial documents. These include Chugoku Electric, Fuji Photo Film, Hokkaido Electric, Idemitsu Kosan, Kyushu Oil, Japan Energy, NTT Data and Tohoku Electric. By contrast, the BioCarbon Fund has not made any significant inroads into the North American markets, principally due to the rejection by the United States of the Kyoto Protocol, and the remaining uncertainty as to how Canada plans to meet its Kyoto targets. This fact notwithstanding, we believe that initiatives like the BioCarbon Fund will in the future become increasingly important ways for companies and governments to mitigate climate change at a cost that is affordable, and in a way that is respectful of people and the ecosystems to which they belong.

Beyond BioCarbon: The Lessons Learned

By being innovative, taking risks, and helping catalyze initiatives such as the BioCarbon Fund, the World Bank has been instrumental in pushing the envelope of carbon finance. In doing this, we have learned many lessons about carbon finance. These include:

  • Although our economies are carbon constrained, the carbon markets -and the CDM and JI especially- are still small business. As our latest carbon market survey reveals, only about 300 million tons of carbon dioxide equivalent have been exchanged since 1998 (see http://carbonfinance.org/pcf/Home_Main.cfm). The market needs to grow to become sustainable. Demand must increase before large private banks become involved. The advent of the European Trading Scheme is the best hope to date, which is why it is important that the "linking directive" between the European Trading Scheme and the CDM and JI provide for as much flexibility as possible.
  • The "CDM and JI window of opportunity" is closing fast. The lead times before CDM and JI projects generate their first emission reductions are long: it takes time to identify and formulate a project, register it with the CDM Executive Board, finance it, build it, and finally to receive the first credit delivery. A project identified in 2004 may not generate its first credit until 2009-2010, leaving only 2-3 years before the end of the first commitment period (2012).
  • Unless a special effort is made, the carbon market will bypass small-scale projects in less attractive countries and focus instead on large-scale operations in a few select countries (e.g. India, China, Romania). The World Bank, in partnership with the International Emissions Trading Association, has created the Community Development Carbon Fund to address this challenge.
  • Capacity to prepare, promote and implement CDM and JI projects is still lacking in host countries. And yet, real projects are the best way to build capacity. First-of-a-kind transactions are therefore a key to unlocking the CDM and JI potential. Through CF-assist, the World Bank is building the institutional and operational capacity of host countries to engage in the carbon market. Meanwhile, the World Bank continues to demonstrate how to prepare CDM and JI projects in sectors likely to generate large numbers of carbon credits.

More information about the BioCarbon Fund and the other World Bank carbon finance activities can be found at www.carbonfinance.org or by contacting Ms. Anita Gordon, Senior Communications Officer, at [email protected]. Benoí®t Bosquet is Senior Natural Resources Management Specialist at the World Bank's Carbon Finance Business

Conservation Banking: Moving Beyond California

The creation of “conservation banks” may be changing the way private landowners in the US view endangered species and their habitat. In an article commissioned by The Ecosystem Marketplace, Jessica Fox draws some lessons from the experience of conservation banking in California and uses this information to predict where there may be further growth in the practice. For years private property owners in the United States have spent a great deal of energy making sure that rare and endangered species do not make a home on their land. Damaging shrubs, stomping on seedlings, disposing of nests, and removing trees are all regular activities in some quarters. But there is a form of reason behind this seeming madness: Landowners behave this way in an attempt to avoid land use restrictions that result from the presence of plants and animals protected by the U.S. Endangered Species Act (ESA). After all, if federally protected species are on your land, you may be required to pay large sums of money to mitigate impacts to their habitat. It’s better -some landowners believe- to destroy the habitat before anyone knows it is there. But is it really? Thanks to the growth of a practice known as conservation banking, landowners now need to consider that some of their colleagues and neighbors have found ways to get paid as much as $125,000 an acre for endangered species habitat. This ability of private property owners to receive financial returns in exchange for protecting rare species marks a turning point in the history of biodiversity conservation in the US. For the first time, landowners are being rewarded for taking pro-active steps to conserve species. And, since the majority of habitat for rare species in the United States is on private property, engaging the participation of non-governmental landowners in stewardship activities is essential if conservation is ultimately to be achieved. The way the system works is, briefly, as follows: Before a developer builds a road, builds a house, or otherwise does something that might harm an endangered species, the ESA requires that they first obtain an “incidental take” permit from the US Fish and Wildlife Service (FWS). This, in turn, means that they must put together a Habitat Conservation Plan (HCP) that usually requires them to mitigate or compensate for the damage to the species being harmed. Traditionally, developers mitigate for the damages by purchasing new property or modifying existing landholdings that can support the impacted species. The investment required to site these areas is significant and land management responsibilities are heavy as the habitat must be continually maintained, usually unsuccessfully. Both the wildlife and developers are thankful that there is finally another solution. Developers are now finding that they would rather buy “mitigation credits” from a so-called “conservation bank” that has already achieved the mitigation and has obtained approval from the Fish and Wildlife Service to sell these “mitigation credits”. The ability to create conservation banks and sell credits in exchange for protecting habitat is providing the financial incentive necessary to commit land to conservation. Research has found that conservation banks already protect nearly 25 endangered species and cover some 40,000 acres (Fox, J. Nino-murcia, A. In review. The Status of Species Conservation Banking in the U.S.: A Benchmark Study). While the concept is still in it infancy, its influence -not least in the financial sphere- is growing: In California, for example, a landowner has received $125,000 for protecting habitat for a small bird called Least Bell’s Vireo. In Texas, a rancher is actively selling credits for $5,000 per acre of Golden-cheeked warbler habitat on his family ranch. There are even a few landowners in South Carolina that are optimistically asking $250,000 for protecting a breeding pair of red-cockaded woodpeckers. On the legal and institutional front, however, things are moving at a relatively slow pace. For example, although California was the first state to establish guidelines for the creation of conservation banks in 1995, Federal guidance on the subject did not appear until nearly a decade later, in 2003. (The important elements of the federal guidance were recently described by Bauer, Fox, and Bean1 and are noted in Box 1). And yet, despite the time lag, many hope that the release of Federal Conservation Banking Guidance will cultivate a growth in the practice and ultimately lead to the recovery of endangered species, or at least to more effective compensation for habitat impacts.

 BOX 1

Important Elements of a Conservation Bank

  • Protects habitat for at least one rare species (listed as endangered, threatened, or candidate under the United States Endangered Species Act)
  • Permanently Protects habitat
  • Large enough to be ecologically stable
  • Backed by a banking agreement signed by the U.S. Fish and Wildlife Service.
  • Long-term funding via an endowment fund
  • Habitat is protected prior to impacts
  • Credit prices governed by the open market
 

Since California has benefited from guidance for nearly a decade, it is not surprising that nearly all of the approximately 40 existing conservation banks are in that state. Meanwhile, the impact of the federal guidance on the growth of banking in the rest of the United States has not yet been observed. However, a better understanding of the elements that have allowed banking to be so successful in the West may help foretell the potential success of banks elsewhere. In this vein, there are several factors that have fostered the accelerated growth of banking in California. These include: strong enforcement of biodiversity protection laws, the presence of rare species, demographics, and support from state and federal agencies. These primary elements, discussed in more detail below, will govern the future success of conservation banking across the United States and potentially around the world. Enforcement of Biodiversity Laws. The demand for credits ultimately depends on the enforcement of biodiversity protection laws that require mitigation of impacts to species. In the US, the federal Endangered Species Act is the primary tool to allow this, although state laws can also enforce mitigation requirements. In the absence of this enforcement, compensation for habitat impacts is unlikely to occur and the pool of credit buyers will be limited or absent altogether. Take, for example, the case of endangered plants in the US. With the exception of Hawaii there is a general lack of enforcement related to impacts on endangered plants across the United States. As a result, there are very few credit buyers seeking plant credits, which could, in turn, explain why there are only two conservation banks based solely on a plant (the Pima Pineapple Cactus). The importance of enforcement is also highlighted by the fact that in California, enforcement of both federal and state laws is strong which means that developers are continually seeking mitigation alternatives. This creates a steady stream of species credit seekers, and therefore businesses have arisen to provide a supply for this demand. In other states, where enforcement of laws is weak, the demand for credits will be limited; even if a bank is established it is unlikely to be financially successful. Number of Rare Species. The presence of species listed under the Endangered Species Act as threatened, endangered, or candidate is necessary to establish a conservation bank. With nearly 300 federally ‘listed’ species and an additional 50 state protected species, California has ample opportunities to site conservation banks. Hawaii is the only state with more listed species than California. In areas of the United States where there are few rare species, opportunities for establishing banks will be comparatively low. For example, North Dakota currently has only 8 listed species and Alaska only 11. And the Alaskan species are mostly migratory marine species which are not particularly suited to conservation banking. By contrast, in Tennessee, Alabama, Texas, and Florida there are many federally listed animals and therefore ample opportunities to establish markets in species credits and conservation banks. Demographics and Value of Real Estate. Urban development is active in California and ecological features are continually being sacrificed to build houses, roads, and golf courses. This means that developers are constantly looking for quick and effective ways to mitigate the ecological impacts of their activities. And, since credits sold by conservation banks are pre-approved by the agencies as legitimate and allow developers to simply buy their way out of a liability leaving the long-term habitat management responsibility up to the bank owner, they can be particularly attractive. Likewise, the high price of land in California means buying credits from an existing bank is even more attractive when compared to independently purchasing property for the purpose of habitat conservation. The combination of active development and expensive land has created a firm demand for species credits in California. A few other states with some of the same demographics and real estate characteristics include Texas, Florida, North Carolina, and Illinois. Agency Support. The level of support for conservation banking from agency staff is important for establishing banking agreements. In general, local field offices rather than the regional offices of the Fish and Wildlife service play the biggest role in negotiating, supporting, and approving banking agreements. In some cases, there is a lack of support simply because agency staff have never processed a banking agreement and don’t have the resources or interest to see a banking agreement through to completion. Part of the lack of enthusiasm may stem from underlying resistance to conservation banking as a viable strategy for reducing impacts on species. However, in areas where there are energetic biologists who believe in the ecological potential of banking, banks tend to be actively established and identified. Without at least one proponent at the field office who can shepherd the project through its various steps, push the paperwork, and champion the project to the regional office, it can be extremely difficult to get a banking agreement processed. In California, the state has benefited from guidance on conservation banking for nearly 10 years and the concept has enjoyed overall support by the relevant agency staff. All field offices in California, for instance, are familiar with banking and the process to get an agreement established. In contrast, it was only recently that field offices in the mid-western US even heard of conservation banking. Outside of California, the number of agency staff that know the details of the federal guidance on conservation banking and are prepared to establish a banking agreement is limited. This suggests that the process could strongly benefit from a concerted effort by the Fish and Wildlife Service to ‘kick-off’, promote, and implement the federal guidance, as well as from an increase in landowners seeking to establish banks.

 BOX 2

Factors Influencing Growth of Conservation Banking

  • Presence of listed species
  • Development activities and resulting demand for credits
  • Price of alternative mitigation options (price of habitat)
  • Level of enforcement of the Endangered Species Act
  • The presence of a state ESA that enforces the Federal ESA
  • Support for banking from FWS field office
  • Resources allocated at FWS to promote federal policy
 

Given all of the above, it is likely that conservation banking will mimic the growth pattern of wetland banking; where the release of the federal guidance in 1995 trailed the initiation of the practice and spurred a swift increase in the number of banks established. Experience indicates that areas of the United States that, like California, share some of the elements described above are primed for a rapid growth in the establishment and use of conservation banks. This allows us to predict that we are likely to see conservation banking grow in places like Texas, Florida, Alabama, and other areas of the Southeast and Midwest. The ability for conservation banking to extend beyond U.S. borders, on the other hand, may be limited by a lack of biodiversity protection laws, ill-defined property rights, and controlled markets limiting credit transactions. However, banking may be successful in those countries where property ownership is clear, government enforcement of habitat impacts is consistent, and free markets are allowed to determine credit transactions. As the various elements that encourage and support conservation banking become better understood, we may see landowners change the way they feel about endangered species. The rancher who previously proactively destroyed seedlings may decide to give the seedlings a chance and reduce the number of cattle grazing on his property. Similarly, the electric utility that originally planned to build a new power plant may decide to convert the property into a habitat reserve. And Departments of Transportation may realize that their so-called “surplus” property holds real financial value if it is placed under a conservation easement. In other words, efforts may be undertaken to protect habitat and endangered species because -for the first time in US history- that habitat and those species will hold financial value on the open market. So, the next time a private landowner considers stomping on the nest of an endangered bird, he or she may want to look again at all the options to see if that really is the most prudent and rational financial choice. Jessica Fox is a Senior Associate at EPRIsolutions, a division of the Electric Power Research Institute (EPRI) in Palo Alto, California. She can be reached at [email protected].


1 Bauer, M., Fox, J., Bean, M.. 2004. Landowners Bank on Conservation: The U.S. Fish and Wildlife Service’s Guidance on Conservation Banking. Environmental Law Reporter. August: V 34 pp 10717-10722

The BioCarbon Fund

 

17 November 2004 | Four years ago, the World Bank embarked on an interesting and innovative journey designed to stimulate and catalyze the emerging markets in carbon credits. First, the Bank helped create Prototype Carbon Fund (PCF), a leader in the field whose capital of US$ 180 million is today almost totally committed. Since then the Bank has been involved in the creation of the Netherlands Clean Development Facility, the Community Development Carbon Fund, the Italian Carbon Fund, and, as of May, the BioCarbon fund. A new facility created by the government of The Netherlands will become operational by mid-2004 and be co-managed by the World Bank and the International Finance Corporation. All together the World Bank is managing about US$ 410 million in carbon funds, a volume which is expected to grow to over US$ 500 million within a year as existing funds develop and new funds come on line. All the funds are featured at www.carbonfinance.org. Created by private companies and governments and administered by the World Bank, these funds invest in projects that mitigate climate change in client countries of the World Bank. Acting as a trustee on behalf of the contributors (called Participants), the Bank buys a volume of greenhouse gas emission reductions (also referred to as “carbon credits”). These emission reductions can either be used to help companies and governments meet their obligations under emerging regulatory regimes (e.g. the UN Framework Convention on Climate Change, UNFCCC, and its Kyoto Protocol) or can be traded on the emerging carbon markets. All credits come from projects undertaken in the framework of the Clean Development Mechanism (CDM) in developing countries or Joint Implementation (JI) in countries with economies in transition. Each fund has a different set of private and/or public Participants, its own specific objectives, project portfolio criteria, and a separate governance structure. The funds only pay for the credits when the emission reductions are verified or, in the case of the BioCarbon Fund, when it is established that the tons of carbon have effectively been sequestered in vegetation or in the soil.

Bringing the Carbon Market to Rural Areas

What sets the BioCarbon Fund aside as a trail-blazing and far-reaching initiative is that it is aimed at catalyzing “sinks projects”, i.e. activities which sequester and conserve carbon in ecosystems and agriculture, and which are also referred to in Kyoto jargon as projects related to land use, land-use change and forestry (LULUCF). Although land-use changes are responsible for roughly 20 percent of global greenhouse gas emissions and one-third of total greenhouse gas build-up in the atmosphere, the use of LULUCF for mitigating climate change has been the subject of heated controversy. As a result, very few LULUCF projects have been undertaken to date. Despite a flurry of activity in the years 1996-1999, the share of LULUCF in total volume of carbon transacted between 2000 and 2003 was merely 9 percent, and only 7 percent when the last two years -2002-2003- are considered. The declining role of sinks and sequestration in carbon markets is due in large measure to the opposition of a number of environmental NGOs, which have been concerned with the potential social and environmental risks of the use of carbon sinks to meet Kyoto obligations. Now that the Parties to the UNFCCC have effectively addressed these risks and provided some guidance on the matter (see below), we believe the market for sinks is likely to grow. This could be good news for people living in rural areas throughout the developing world since, for them, sinks are really the only available entry into the carbon market. The reality is that though people living in rural areas lack the energy infrastructure to participate in the CDM, they nonetheless manage large natural resource bases -most notably land and forests- and their land use decisions can have large impacts on the global climate. For example, conversion of forest to agriculture releases carbon to the atmosphere, while afforestation of degraded agricultural land sequesters carbon out of the atmosphere and stores it in vegetation and soils. For these populations, payments per ton of carbon not emitted or sequestered can create incentives to improve land and forest management, with resulting benefits for both the local and global environments (e.g. reduction of soil erosion, habitat restoration), as well as significant improvements in people’s livelihoods (e.g. higher soil fertility, adoption of new techniques).

The BioCarbon Fund Makes Business Sense

The BioCarbon Fund was officially opened to Participant contributions in November of 2003, and started operations in May of 2004 with capital of US$ 12.5 million contributed by the governments of Canada and Italy, Okinawa Electric, Tokyo Electric, and Eco-Carbone, a French project developer. It is expected that the capital will grow to US$ 20-30 million by the end of 2005. The BioCarbon Fund is attractive to companies and governments in search of affordable ways to meet their obligations under cap-and-trade regimes, as well as to trading and financial institutions for the following reasons:

  1. The Fund outcome price of greenhouse gas emission reductions delivered to the Participants is predicted to be less than US$ 5 per ton of carbon dioxide equivalent (t CO2e). This is much lower than current marginal greenhouse gas pollution abatement costs in the OECD. Additionally, a significant proportion of the emission reductions purchased by the BioCarbon Fund are intended to be fully compatible with the rules of the Kyoto Protocol’s Marrakech Accords and related texts on the use of afforestation and reforestation in the Kyoto Protocol’s CDM.

 

  • Through the BioCarbon Fund, Participants can acquire a unique insight into the creation and implementation of carbon sink projects. Including sinks in a company’s or government’s climate change mitigation portfolio is important as it diversifies risks and taps into a source of greenhouse gas emission reductions that are intended to remain competitive for some time to come. The Marrakesh Accords adopted in 2001 capped the amount of CDM sinks credits Annex I countries can use to meet their Kyoto obligations at 1 percent of 1990 emissions, which means that supply will greatly exceed demand, with a depressing effect on prices, until at least 2012, i.e. the end of the first commitment period, for which the rules have been set. To illustrate excess supply, the BioCarbon Fund has received over 100 project proposals. These projects could supply a volume of emission reductions several orders of magnitude greater than what the BioCarbon Fund can acquire at its expected levels of capitalization, putting prices in the US$ 3-4/t CO2e range. Besides, these prices are payable upon delivery of the emission reductions (not in advance).
  • Finally, buyers of emission reductions from the BioCarbon Fund improve their image as socially and environmentally responsible carbon buyers. A ton of carbon acquired through the BioCarbon Fund and preserved for the long term, has the same atmospheric effect as a ton of emission reductions achieved by an industrial project, but it also delivers important ancillary benefits at the local level. The fund is designed to ensure that developing countries, including some of the poorest countries, have an opportunity to benefit from carbon finance in forestry, agriculture and land management. So the emission reductions supplied by the BioCarbon Fund will have substantial additional benefits, including improving local rural livelihoods and alleviating rural poverty.
    CoP9 and the Permanence Question

    Clearly the issue of using sinks and sequestration to meet climate change obligations is a thorny one. In particular, the challenge for sinks is to prove that they can be sustained in the long term -to become “permanent”- and have a climate impact that is truly equivalent to that of emission reductions from energy projects. This issue was partially resolved at the 9th Session of the Conference of the Parties to the UNFCCC (CoP9), which took place in December 2003 in Milan, Italy. To a certain extent, the draft decision reached at CoP9 confirms what the World Bank had anticipated in designing the BioCarbon Fund: the need to manage the risk of non-permanence by relying on credits which have a validity limited in time and are periodically verified. Specifically the rules resolve the controversial permanence issue by allowing credits for afforestation and reforestation projects for up to 60 years, subject to verification and certification of continued storage of carbon every 5 years. In a way, the CoP9 decision is more favorable than anticipated, since earlier proposals limited the validity of temporary credits from 5 to 35 years maximum. An important aspect of the CoP9 decision is that it focused the minds on the endgame, on the need to replace the temporary credits at a maximum of 60 years. Would the buyers of temporary credits through the BioCarbon Fund have to replace their credits, thereby endorsing an open liability and the need to purchase the same credit twice? If so, would the price per ton remain affordable? To manage this replacement risk, the BioCarbon Fund will cover the eventual replacement of the temporary credits by the purchase, on a cash forward basis, of certificates of permanent emission reductions generated from energy projects in World Bank-managed carbon funds other than the BioCarbon Fund. By paying a low price upfront for the delivery of permanent emission reductions after 2012 (there is not yet a market for such emission reductions), Participants can cover their replacement risk at an affordable cost.

    Markets for The BioCarbon Fund

    Governments and companies can join the BioCarbon Fund with a minimum contribution of US$ 2.5 million, which is paid either at the time of joining or on a draw-down schedule over about 10 years. Only accredited investors as established by United States securities legislation are allowed to participate. In Europe, the BioCarbon Fund faces the challenge that certificates from CDM and JI sinks projects are excluded from the European Trading Scheme (ETS) until 2008, so demand is limited (see article on EU ETS here ). Nonetheless, the ETS does not cover all sectors and may not be sufficient for Europe to meet its commitments under the Kyoto Protocol. Complementary action will almost certainly be needed if Europe is to meet its obligations. And to do this, European governments are allowed to use CDM and JI sinks to fulfill their Kyoto obligations. For this reason, it is expected that several European governments will find the BioCarbon Fund an investment of choice. In Japan the World Bank is marketing the BioCarbon Fund in collaboration with two agents, Natsource Japan and Mitsui/CO2e.com. Beside Okinawa Electric and Tokyo Electric, other companies have expressed interest in participating in the fund and are reviewing the legal and financial documents. These include Chugoku Electric, Fuji Photo Film, Hokkaido Electric, Idemitsu Kosan, Kyushu Oil, Japan Energy, NTT Data and Tohoku Electric. By contrast, the BioCarbon Fund has not made any significant inroads into the North American markets, principally due to the rejection by the United States of the Kyoto Protocol, and the remaining uncertainty as to how Canada plans to meet its Kyoto targets. This fact notwithstanding, we believe that initiatives like the BioCarbon Fund will in the future become increasingly important ways for companies and governments to mitigate climate change at a cost that is affordable, and in a way that is respectful of people and the ecosystems to which they belong.

    Beyond BioCarbon: The Lessons Learned

    By being innovative, taking risks, and helping catalyze initiatives such as the BioCarbon Fund, the World Bank has been instrumental in pushing the envelope of carbon finance. In doing this, we have learned many lessons about carbon finance. These include:

    1. Although our economies are carbon constrained, the carbon markets -and the CDM and JI especially- are still small business. As our latest carbon market survey reveals, only about 300 million tons of carbon dioxide equivalent have been exchanged since 1998 (see http://carbonfinance.org/pcf/Home_Main.cfm). The market needs to grow to become sustainable. Demand must increase before large private banks become involved. The advent of the European Trading Scheme is the best hope to date, which is why it is important that the “linking directive” between the European Trading Scheme and the CDM and JI provide for as much flexibility as possible.

     

  • The “CDM and JI window of opportunity” is closing fast. The lead times before CDM and JI projects generate their first emission reductions are long: it takes time to identify and formulate a project, register it with the CDM Executive Board, finance it, build it, and finally to receive the first credit delivery. A project identified in 2004 may not generate its first credit until 2009-2010, leaving only 2-3 years before the end of the first commitment period (2012).
  • Unless a special effort is made, the carbon market will bypass small-scale projects in less attractive countries and focus instead on large-scale operations in a few select countries (e.g. India, China, Romania). The World Bank, in partnership with the International Emissions Trading Association, has created the Community Development Carbon Fund to address this challenge.
  • Capacity to prepare, promote and implement CDM and JI projects is still lacking in host countries. And yet, real projects are the best way to build capacity. First-of-a-kind transactions are therefore a key to unlocking the CDM and JI potential. Through CF-assist, the World Bank is building the institutional and operational capacity of host countries to engage in the carbon market. Meanwhile, the World Bank continues to demonstrate how to prepare CDM and JI projects in sectors likely to generate large numbers of carbon credits.More information about the BioCarbon Fund and the other World Bank carbon finance activities can be found at www.carbonfinance.org or by contacting Ms. Anita Gordon, Senior Communications Officer, at [email protected]. Benoît Bosquet is Senior Natural Resources Management Specialist at the World Bank’s Carbon Finance Business

 

New Regulations could mean Big Business for US Mitigation Bankers?

A bill passed by the US Congress calls on the US Army Corps of Engineers to prepare new regulations on wetlands mitigation and mitigation banking, regulations that could mean huge increases in business for mitigation bankers in the US. One observer calls these new regulations “the most significant piece of legislation to come out in the short-lived history of the mitigation banking industry.” John Ryan, the President of Land and Water Resources Inc. in Chicago, Illinois, is the perfect example of how environmental markets are transforming the way people do business in the US. In Ryan’s particular case, not only has his business been radically transformed, but so has his life, his career, and even his legacy. Ryan, you see, comes from a long line of earth moving contractors based in southern Wisconsin. His father was an earth-moving contractor, as were his grandfather, and his great grandfather. In fact, Ryan Inc., the company that bears his family’s name, is still one of the largest earth moving companies in the US. Ten years ago, however, Ryan left his family’s profitable business to set up a construction company of a very different sort: one that builds, maintains, protects, and restores ecosystems, or, to be more precise, wetlands. He is able to make a living building wetlands because of a unique environmental market that exists in the US that is sometimes referred to as “mitigation banking”, or “wetlands mitigation banking.” The system works roughly like this: Whenever a developer wants to impact a wetland, the US Clean Water Act says they need to obtain a permit for this work from the US Army Corps of Engineers. In issuing that permit, the Corps is supposed to look first at whether the damage is truly necessary. Then, if it determines that the damage is indeed necessary, the Corps is supposed to require that the developer minimize any potential harm to the wetland. Finally, where damage is unavoidable, the developer is required to compensate (or mitigate) for this damage by restoring a former wetland, enhancing a degraded wetland, creating a new wetland, or, in some very rare cases, preserving an existing wetland. The law states that developers can fulfill this “compensatory mitigation” themselves (usually at or near the development site), or they can pay third parties to do this in their stead. If they decide to pay someone else to do the work for them, they have several options: (1) They can buy “wetland credits” from a mitigation bank, usually a for-profit entity that “creates, enhances, or restores” a wetland and then is allowed by the Corps to sell credits for these wetlands -measured in acres- to needy developers. (This is how Ryan makes a living.); or (2) they can pay fees established by the Corps to public entities or private not-for-profit organizations that, in agreement with the Corps, use the money to “protect, enhance, or restore” wetlands. These are known as “in-lieu-fee” arrangements; or (3) They can pay a third party that is neither a mitigation bank nor an in-lieu fee provider to undertake the mitigation. These are referred to as “ad-hoc” arrangements. [For more on mitigation banking, see the attached article] As a result of these requirements for wetlands mitigation, there has developed in the US a burgeoning market for wetlands mitigation. Indeed, a report by the Environmental Law Institute (http://www2.eli.org/wmb/index.html) estimates that between 1992 and 2002 there has been a 376 percent increase in the number of private wetlands banks in the US. They estimate that in 2002 there were 219 approved banks, with some 95 more pending approval. Although no one knows for sure, the market for environmental mitigation in the US is almost certainly worth hundreds of millions -perhaps even billions- of dollars. That is the market that John Ryan moved into when he left his family’s business way back in 1990. As he describes it, the idea to go from earth-mover to earth-saver came in the form of an epiphany born of frustration. “In doing the earth moving work,” he says, “it always seemed that we negotiated a contract to do some building and then the people would say, ‘Well, gee, we’ll get started just as soon as we can get our wetlands permits sorted out.’ And when people said that, we knew it would be six months to a year before the work would begin. Then, when the work began, we were asked to help build this small wetland on-site. After a bit of this I woke up one night thinking to myself that it would be better for everyone concerned -the developers, the contractors, the environment- if we were to build a small number of real functioning wetlands instead of a large number of small pieces of wet dirt. The very next day I started talking to people, brewing the idea for my company.” He adds that the transformation hasn’t been easy. “It was a gamble,” he comments. “I sold my shares in my family company’s stock, a successful company, and invested in a new business that no one knew existed.” He says he got strange looks and no doubt his family was mortified, but as it turns out, the gamble paid off. His company now owns 22 mitigation banks across the country and does a comfortable $5-6 million dollars in business a year. He says he is quite happy the way things are going. As well he should be. Not only has the mitigation banking business grown considerably since Ryan opened his business, but now some observers believe it is poised to grow even more rapidly, thanks largely to a bill that was passed by the US Congress in December of 2003. George Kelly, the Managing Director of Environmental Banc and Exchange LLC (EBX), a mitigation banking company based in Maryland, calls the bill “the most significant piece of legislation to come out in the short-lived history of the mitigation banking industry.” The bill he praises so highly is, oddly enough, the National Defense Authorization Act for Fiscal Year 2004, and the language in question comes in Section 314 (http://www.congress.gov/cgi-bin/cpquery/?&dbname=cp108&&r_n=hr354.108&sel=TOC_249908&). It calls on the Army Corps of Engineers to “issue regulations establishing performance standards and criteria for use? of on-site, off-site, and in-lieu fee mitigation and mitigation banking” by two years after the passage of the act, in other words by December 2005. The real bombshell, however, comes a few lines later, when the law states that the regulatory standards and criteria shall seek to do three things: First, they “shall maximize available credits and opportunities for mitigation.” Secondly, they shall “provide flexibility for regional variations in wetland conditions, functions, and values.” Most importantly for the mitigation bankers, however, the bill finally says that the regulations shall “apply equivalent standards and criteria to each type of compensatory mitigation.” The reason that Kelly, Ryan, and other mitigation bankers are excited about this law is that they see it as helping correct a fundamental problem with the way wetlands mitigation is conducted in the US; a problem that directly affects their profit margins and -they argue- the environmental integrity of the entire mitigation process. It all goes back to the various mitigation options that are open to developers intent on impacting a wetland. As was discussed above, developers have essentially four options: they can do the mitigation themselves, they can pay a bank to mitigate, they can enter into in-lieu fee arrangements and pay the government or a non-profit to mitigate, or they can get someone else to do the mitigation. From the perspective of the developer, all of these options are the same, they all allow the developer to continue building, they all fulfill a regulatory requirement. As far as they are concerned, they will look for the cheapest, easiest, and most expedient option. As far as the Army Corps of Engineers is concerned, however, each of these options is treated differently. If a developer decides to do the mitigation on its own, they are required to submit plans to the Corps for approval, but once they receive this approval, they can go ahead and damage a wetland before any mitigation is undertaken. Also, they are not held to stringent ecological standards in terms of wetland quality, wetland function, etc. Sometimes the result isn’t even monitored to ensure that it exists several years later. In-lieu-fee arrangements, likewise, are held to relatively lax standards. To participate in an in-lieu-fee arrangement, it used to be that the public agency or non-profit simply had to say that they were going to mitigate, they would then receive approval by the corps and they could begin collecting the money. There was no real oversight on how the money was used, and there were no real biological standards that projects were expected to uphold (though guidelines were issued in 2000 that address some of these issues). As a result, says Ryan, there have been cases where money was being collected by in-lieu-fee providers “in hope and prayer” that wetlands would someday, somehow be protected, enhanced, or restored. There were even cases where the money collected by in-lieu-fee arrangements went, not to a wetland, but rather to education, research and the like. “Education and research are great,” says Ryan, “but they don’t directly protect wetlands.” By contrast, mitigation banks are usually held to the strictest of standards. Not only do they usually have to complete their projects before being able to sell credits, but completion of the project generally requires that they establish conservation easements legally setting aside their land in perpetuity, and that they set aside a substantial amount of cash, a form of bond, to ensure the project’s long-term viability. In addition, mitigation banks tend to be closely watched by the Army Corps of Engineers and are, by law, forced to meet a pretty strict set of ecological standards. By way of example, Ryan explains that mitigation banks need to reduce the amount of exotic species on their wetlands to 5% or less, whereas other mitigation arrangements can get away with having as much as 20% exotic species. “And each percentage point,” he adds, “adds a tremendous amount of work and cost.” Craig Denisoff, the Vice President for Government Affairs and New Project Development at Wildlands Inc., a California-based mitigation banking company, who is currently serving as President of the National Mitigation Banking Association (NMBA), says that these differences in treatment have artificially held back the mitigation banking industry. “Because we are held to such high biological, financial, and legal requirements,” he says, “we just cannot compete with other forms of mitigation. They can often afford to charge thousands of dollars less per acre than we can? Besides, they can be up and running right away whereas it can often take us 2 to 3 years to get permitted? And to make matters worse, the government imposes all kinds of capricious restrictions on mitigation bankers; restrictions on the size of our projects, restrictions on who can purchase credits from mitigation banks, restrictions on the use of fines and other mitigation money for mitigation banks, among others.” For all these reasons, he estimates that private, for-profit, mitigation banks today make up only about 6% of all the mitigation done in the US. “I would guess,” he says, “that in-lieu-fee arrangements account for about 4% of the industry, while mitigation done by individuals, usually for their own projects, accounts for the other 90%.” Beyond being bad for the industry, Denisoff argues, the current set-up is bad for wetlands and bad for the environment. He explains that when the standards are low, the job is often done badly. “In fact,” he adds, “the Government Accounting Office (GAO) did a study recently which found that the system for in-lieu-fee arrangements is not working? And we have seen time and time again that permitee-responsible mitigation [where a developer is responsible for their own mitigation] is also not working. It is not tracked, there are no provisions for long-term stewardship, and the performance standards are low.” Denisoff says that mitigation bankers see the new regulations being drafted by the Corps as an important opportunity to “level the playing field”, not by lowering standards, but by raising all of them up to the levels currently applied to mitigation banks. To the “94% of people in this business that have lower standards than we do” Denisoff has one thing to say: “Stop playing in the minor leagues and come join us in the major league.” Rich Mogensen, who preceded Denisoff as President of the NMBA and is Director for the Mid-Atlantic Region at the EarthMark Companies, believes that any new regulations that that apply equivalent standards across all forms of mitigation will strongly stimulate the US mitigation banking industry. “I know of no definitive study,” he says, “that estimates how much mitigation is done by private banks as opposed to other actors. If I had to hazard a guess, however, I would say that mitigation banks account for less than 15% of the mitigation market. But if mitigation standards are all brought up to the same level, and if there is follow-through and enforcement, this will definitely change. If that happens I think we could easily see, within 3 to 5 years, a situation where private mitigation banks make up 50% of the market.” And what does the Army Corps of Engineers say about all this? According to David Olson, one of the people working on the new regulations at the Corps, it is still too early to say much about the new regulations. The drafting hasn’t even begun. “At this stage,” he says, “we are in the process of doing some early scoping to see what the regulations should contain. We have talked to the National Mitigation Banking Association; we have talked to people involved in in-lieu-fee arrangements such as the Virginia Chapter of the Nature Conservancy. And we are talking to others. We are also talking to the legislators who drafted the [DOD appropriations] bill to get a better sense of the law’s intent. So we are still just gathering ideas.” He explains that after an initial round of consultations, a draft of the regulations will go to several other government agencies, including the Environmental Protection Agency (EPA), the Fish and Wildlife Service (US FWS), the National Oceanic and Atmospheric Administration (NOAA), among others. The regulations will also go through a consultation process managed by the government’s Office of Management and Budget (OMB) before being released for comment by the interested public. All in all, they should, he says, be ready in time for the December 2005 deadline. The slow and arduous process of drafting the new regulations doesn’t daunt John Ryan. He’s seen it all before. “I was involved in the consultations surrounding many of the regulations that exist in this industry,” he recounts. He first went to Washington to talk about differences in mitigation standards back in 1999 and remembers that when he started in the business, there weren’t really any rules whatsoever. “Rules,” he says, “take time.” Regardless of how long they take to write, Ryan is convinced the new regulations will be good for his business. But more importantly, he says, they will be good for the environment. He explains that over the years he has seen many bad mitigation sites: wetlands that were squeezed, as it were, in between buildings or shopping malls; wetlands built where they don’t make sense; wetlands that were built by developers who then leave without providing for its ongoing survival. His stories are legion. Mitigation done badly, he concludes, doesn’t help anyone. And no one -least of all John Ryan, a man who gambled his entire family legacy to turn wetlands protection into a business- wants to see mitigation done badly. “When I was a dirt mover,” he muses, “I looked on wetlands as soft spots that needed to be dug out and filled in with good solid stuff. They were nothing but bad pieces of dirt that needed to be dealt with. Now I understand the beauty, the values, the services they provide. Now I am happy to be leaving behind a living legacy of wetlands that will still be there long after I’m gone.” In short, Ryan wants mitigation done right and he expects that whatever regulations the Army Corps of Engineers eventually comes up with, they will do at least that. Beyond that he hopes that they will also help strengthen and sustain an industry that has radically transformed his life and his environment.