Submission Number: 00008
Received: 10/8/2010 3:24:10 AM
Commenter: Tim Schloendorn
Organization: South Pole Carbon Asset Management Ltd.
State: Outside the United States
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
Attachments: No Attachments
On a more subtle double counting risk:
There is another risk of macro-double counting when offsetting with credits sourced in developed countries:
- In case there is a federal / state / municipality reduction target in place, it must be assured that an offset acticity is not counted towards this target.
E.g. in Switzerland (as in many other countries) there is a national target in place. Forest carbon is counted towards this target. Therefore any voluntary offset project planting trees in Switzerland is double counted (towards the national goal and as voluntary offset). This is especially severe when the national target translates into demands towards heavy industry - In this case voluntary offsetting is releaving heavy industry from its obligations.
In the US there are several initatives on state / municipality level to reduce emissions. Offsets from these regions should only be eglible when the target is exceeded. This may be an issue in particular in California.
Consumers may be willing to contribute to the state level goal through their offsets, but this has to be stated clearly.
This issue lead the Australian Government to change its guidelines on offsetting recently to exclude all activities that are counted towards the national target. Our company is currently struggeling to find a way to allow for national offsets in Switzerland that do not constitute double counting - Wind Farms and Forestry offsets do not work.
We suggest to use a similar approach as the Australian Government: They issue a quality mark for offsets that fullfill certain criteria, in short:
- Measurement and Reduction of local emissions must happen first.
- Offsets are not double counted towards a national/regional target.
- Offsets from developing countries must follow internationally accepted standards, in particular the Voluntary Carbon Standard, The Gold Standard or the UNFCCC CDM.
We suggest to include an established standard such as the "Green House Gas Protocol" developed by the World Resource Institute as a guideline for measurement.