Sustainability Perspectives Insights for tomorrow’s business Issue 1. Carbon Management Overview................................................................ 2 What is the science?............................................. 8 What is the Voluntary Carbon Market?............. 25 Chicago Climate Exchange Over the Counter Market Offset Standards What is Carbon Trading?.....................................10 What does the future hold?............................... 33 Where we are today.............................................. 6 Perspectives on Offsetting................................ 34 What is the Compliance Carbon Market?...........14 Emissions Trading Schemes Clean Development Mechanism Joint Implementation Renewable Energy Credits Financial Context What does the future hold? What are the elements of a good carbon......... 36 management strategy? Carbon management best practice.................. 41 Final thoughts.................................................... 48 Further reading.................................................. 50 Glossary............................................................. 51 Overview This booklet will help you: • Understand the growing carbon trading market and the different schemes in operation today, including carbon offsetting • Develop and implement an effective carbon management strategy that benefits the bottom line and the environment by looking beyond carbon offsets. Where we are today The verdict is in: human activity is the primary driver of climate change and rising global temperatures through emissions of greenhouse gases. We are already witnessing some of the first effects of the changing climate: a warming world and rising oceans. Scientists estimate that once temperatures rise more than 2 degrees a ‘tipping point’ will be reached, triggering a chain of major effects over which we have no of control. The recent Fourth Assessment Report of the Intergovernmental Panel on Climate Change (IPCC) leaves no doubt that to avoid the most catastrophic effects of climate change, global greenhouse gas emissions must decline to roughly 80% below 1990 levels by 2050. Such large-scale emissions reductions require a move away from fossil fuel, significant improvements in energy efficiency, preservation of the world’s forests and a fundamental shift in government policies and economic practices to encourage the shift to a low-carbon economy. While this may appear daunting at first, reports suggest that about 70% of the reduction can be achieved with technologies available or near commercial now. Putting a price on carbon and building the environmental cost of emissions into the economic system are key to driving the necessary changes. This is where the carbon market comes in. The establishment of carbon trading encourages the development and adoption of behaviours and technologies that will enable us to supply the growing demand for energy without increasing emissions. Sustainability Perspectives 2 Understanding carbon trading and offsets What is carbon trading? A company may either be compelled or choose to take part in the carbon trading market as part of its carbon management strategy. Carbon trading is effectively an interaction between buyers and sellers trading the right to emit greenhouse gases. Mandatory government trading schemes, created as a result of the Kyoto protocol, are known as the compliance market. There are also an increasing number of organisations that are not legally required to reduce their emissions but wish to take action to do so. These organisations trade through the voluntary market, often using a mechanism known as offsetting. Carbon offsetting involves calculating your emissions and then purchasing ‘credits’ from emission reduction projects. These projects have prevented or removed an equivalent amount of carbon dioxide elsewhere. UK Govt DEFRA, http://www.defra.gov.uk/ The Compliance Carbon Market A number of schemes have been created to facilitate carbon trading. Allowance based schemes such as the European Union Emissions Trading Scheme are based on the right to produce a certain quantity of greenhouse gases up to a predetermined level. Project based schemes such as the Clean Development Mechanism are based on credits certifying that 1 tonne of carbon dioxide equivalent has been removed or saved from emission into the atmosphere. The essential requirement is that the savings are additional to those delivered through business as usual. The number of organisations required to participate in government mandated schemes is set to increase in the future with the introduction of the Carbon Reduction Commitment in the UK. Other national trading schemes are being introduced elsewhere. Sustainability Perspectives 3 The Voluntary Carbon Market The voluntary market has grown rapidly in the last few years, but still only represents 2% of the carbon market. The debate about the value and environmental benefits of some of the schemes in the voluntary sector continues, not helped by the large number of different accreditation and verification mechanisms available. In light of some of the concerns about investing in offset projects, it is important to understand what the objectives are in the context of a robust carbon management strategy to see what alternative emissions reduction opportunities exist. Developing an effective carbon management strategy: best practice beyond offsets Developing a carbon management strategy While organisations’ size and scope of operations may differ, the underlying process for developing a sound carbon management strategy remains the same: • Set the boundaries of the carbon emissions your business will measure • Conduct a full carbon inventory of your business operations based on these boundaries • Identify carbon-intensive activities that can be avoided • Reduce carbon emissions where possible and practical • Replace carbon-intensive energy sources with lower carbon ones • Explore alternatives to offsetting Beyond offsets: carbon management best practices Once an organization has been through the process of developing a carbon management strategy, the question remains of whether to voluntarily purchase offset credits or adopt other measures to reduce its carbon footprint. A number of best practice alternatives to offsetting can be considered, according to the objective. Sustainability Perspectives 4 Objective: Demonstrate to external stakeholders that actions are being undertaken to reduce emissions. Best practice: Inhouse emissions reductions achievements are externally accredited, and communicated. Objective: Meet self imposed targets of carbon reduction. Best practice: Use savings from energy efficiency programmes to invest in internal carbon reduction projects to drive additional savings. Objective: Motivate employees and encourage behaviour change. Best practice: Create a direct link between behaviour change and incentives Objective: Act as a good corporate citizen and enhance corporate reputation. Best Practice: Invest resources in terms of skills, time and money into closely aligned offset projects that support corporate objectives. Objective: Enhance brands or products by addressing consumers’ ethical and environmental concerns. Best practice: Invest in activities to reduce emissions generated outside the direct scope of the company’s operations by the products or services it provides. Objective: Risk mitigation: anticipation of the introduction of legislation, avoiding negative press. Best practice: Invest in internal emissions reduction schemes. Final thoughts Across all sectors of business, organisations committed to reducing their emissions beyond mandatory limits are finding: • Improved efficiency • Cost savings • Competitive advantage • Improved employee motivation • An enhanced reputation An effective approach to carbon management is not only the responsible thing to do, it also makes good business sense. Our carbon management discussion in this booklet provides a clear direction for organisations to address climate change at the scale required to make a difference, while keeping an eye on the bottom line. Sustainability Perspectives 5 Where we are today There is widespread agreement that the climate is changing and that this will significantly impact our lives and those of future generations unless urgent action is taken. Now that the majority of the scientific community has reached consensus on the potential impact and actions required to mitigate human induced global warming, the debate has moved to who should be responsible for taking action. 70% [1] of UK consumers believe that government should take the lead, and indeed some action is being taken with the establishment of carbon trading markets and mechanisms to limit industrial emissions. The majority of consumers also believe that business can have a large influence on limiting climate change. Despite being sceptical about some commercial ‘green’ claims, they want help differentiating environmentally sound products from others. Consumers themselves are torn between their aspirations as citizens to avoid climate change, and their individual desire to go on holiday, have the latest electronic goods and enjoy private transport. Rising food and fuel prices mean that the focus is shifting from global concerns to those closer to home, underlining the importance for sustainable and low carbon products and services to become mainstream choices. 78% [1] of consumers want companies to make it easier to buy low impact products. A key observation is that individuals are concerned with fairness, and seek reassurance that they are not the only people making sacrifices in order to effect a change. So the role for business is varied: from participating in government mandated carbon trading schemes, to minimising the impact of manufacturing operations, developing low carbon products and services, influencing consumer behaviour and giving them a sense of collective action as well as individual choice. In order to do any of these, a business first needs to understand its carbon footprint (described as how much greenhouse-inducing carbon dioxide a company is responsible for adding to the atmosphere as a result of its operations), identify how to effectively manage carbon and then communicate this in a compelling way to stakeholders. 1. Tipping point or turning point: social marketing and climate change, IPSOS MORI, July 2007 Sustainability Perspectives 6 As forward thinking companies began to understand their footprint, focus was inevitably drawn to the idea of creating a business whose operations added no net carbon to the atmosphere, generally referred to as achieving carbon neutrality. At its most basic, carbon neutrality means removing as much carbon dioxide from the atmosphere as you put in, achieving net zero emissions. This phrase gained popularity as several large organisations and brands announced their intention to become carbon neutral. Since it is almost impossible to have no net impact on the environment, they relied heavily on “offsetting” as a mechanism to achieve this. Offsetting involves paying another organization to reduce carbon emissions on your behalf. At the time this was helpful, energising the debate about the role organisations and individuals could play in addressing climate change. However, as universities, towns, individuals and brands now all claim to be carbon neutral, it has rapidly become apparent that very different assumptions and actions are being undertaken. As a result, both carbon neutrality and carbon offsetting have come under increasing scrutiny as questions are asked about exactly what they mean, and what they deliver. Phrases such as ‘carbon neutrality’ are viewed with some scepticism, and carbon offset schemes are being questioned as some fail to deliver the reductions they promised. Perhaps in order to regain credibility and trust, it is time to move on, and rephrase the debate and the solutions in terms of the climate and social science that underpin them. Sustainability Perspectives 7 What is the science? This guide is designed to help organisations understand the complexity of the carbon challenge and consider the most appropriate way to reduce their footprint through a robust carbon management strategy. Climate refers to the average weather experienced over a long period, and includes temperature, wind and rainfall patterns. The climate of the Earth is dynamic, and has changed many times throughout history. “ The scientific evidence is now overwhelming: climate change presents very serious global risks, and it demands an urgent global response” Stern review [2] The reality The recent Fourth Assessment Report of the Intergovernmental Panel on Climate Change (IPCC) [3] leaves no doubt that human activity is the primary driver of changes in climate through emissions of greenhouse gases. The accumulation of gases such as carbon dioxide (CO2) and methane (CH4) in the atmosphere strengthen the greenhouse effect, and are now at the highest level in history. According to the report, mean global temperatures are likely to rise between 1.1 and 6.4°C (with a best estimate of 1.8 to 4°C) above 1990 levels by the end of this century, depending on the level of emissions. Rising temperatures will trigger many other changes to the earth’s system: rising sea levels of between 20 and 60cm by the end of this century, continued melting of ice caps, glaciers and sea ice, changes in rainfall patterns, intensification of tropical cyclones and species extinction. Food and water supplies, human health, biodiversity and the economy will be affected, although the scale of impacts will vary considerably by region and vulnerability. The extent and severity of negative impacts will rise with temperatures. It is estimated that once temperatures rise more than 2°C a ‘tipping point’ will be reached, triggering a chain of major effects over which we have no of control, such as the acidification of oceans. 2. Stern review: The economics of climate change, HM treasury, UK government 2006 3. Climate change 2007: AR4 Synthesis report, IPCC Sustainability Perspectives 8 What needs to be done? In the absence of an effective international effort, emissions will continue to grow rapidly over the coming decades. To have a reasonable chance of keeping global temperature increases below 2°C, global emissions must peak in the next decade and then decline to roughly 80% below 1990 levels by 2050 if we are to avoid catastrophic climate change. Such large-scale emissions reductions require a move away from fossil fuel, significant improvements in energy efficiency, preserving the world’s natural carbon sinks i.e. forests and a fundamental shift in government policies and economic practices. Is it possible? The good news is yes- reports suggest that it is both economically and technically feasible. About 70% of the reduction can be achieved with technologies currently or nearly available. Energy efficiency alone could cut demand by 20% [4]. Adaptation is essential to reduce the effects of climatic changes that are already occuring as a result of historic emissions, but it cannot solve the problem. Mitigation is the only way to effectively curb climate change. Putting a price on carbon and building the environmental cost of emissions into the economic system is a key move to driving behavioural change. The establishment of carbon trading encourages the development and adoption of behaviours and technologies that will enable us to supply the growing demand of developing economies without increasing emissions. The next decade is crucial to delivering this change. In line with the Stern review [2] recommendations on the economic impact of climate change, postpon- ing action will make it more difficult and costly to reduce emissions in the future, as well as creating higher risks of severe climate change impacts. 4. Breaking the Climate Deadlock- a global deal for our low-carbon future. The Climate group, July 2008 2. Stern review: The economics of climate change, HM treasury, UK government 2006 Sustainability Perspectives 9 What is carbon trading? At a glance: The Facts: • Carbon markets are effectively an interaction between buyers and sellers trading the right to emit greenhouse gases. • Mandatory government schemes are known as the regulatory or compliance market. • Non-legislated trading occurs through the voluntary carbon market. • Allowance-based schemes are based on the right to produce a certain quantity of greenhouse gases. One allowance or credit equates to 1 tonne of carbon dioxide equivalent emitted into the atmosphere. • Project-based schemes are based on credits certifying that 1 tonne of carbon dioxide equivalent has been removed or saved from emission into the atmosphere. Outlook: • Schemes should be well managed to ensure the environmental benefits are realised. • Credits should be registered once created to ensure they are not sold to multiple buyers. • Credits can be traded several times before the final buyer retires them. “ The aim of the carbon market is to enable companies to manage the cost of pollution. A correctly functioning carbon market will penalise heavy polluters and incentivise reduced emissions, thus ensuring pollution can be managed at the lowest cost to society” Greger Flodin, Rabobank “ Price is the principle facilitator for behaviour change. You need to make it more financially viable to change behaviour than to buy yourself out of trouble” Simon Manley, Converging World Sustainability Perspectives 10 Development of the Kyoto Protocol 1988/ Intergovernmental Panel on Climate Change (IPCC) was established to help governments understand the science of climate change, key issues and their implications. 1992/ The IPCC and the United Nations (UN) established the United Nations Framework Convention in Climate Change (UNFCCC) and formally recognised the threat of climate change, establishing targets to limit greenhouse gases in the developed world to 1990 levels. These targets were not legally binding. 1997/ The Kyoto protocol was adopted by the UNFCCC and ratified by many countries. It created legally binding targets to reduce Greenhouse Gases (GHG) by 5% below 1990 levels by 2012. 2008/ Start of the Kyoto time frame. Currently 177 countries have ratified the treaty in addition to the European Union. 2012/ The end of the Kyoto protocol. The future of carbon trading after 2012 is currently under discussion. Sustainability Perspectives 11 Carbon trading is effectively an interaction between buyers and sellers trading the right to emit greenhouse gases. Mandatory government schemes have been created as a result of the Kyoto protocol, and are known as the compliance market. The scope of legislative schemes is largely limited to heavy industry and power generating companies at present, although there are moves to increase the number and type of organisations that will be included in compliance schemes in future. There are also an increasing number of organisations that wish to take action but are not legally required to do so. Engaging in voluntary schemes provides useful experience in measurement and strategic decision making, preparing an organisation for the time when government schemes expand and participation will become mandatory. These organisations trade through the voluntary market. The type of scheme and credits that can be bought are determined by the need to meet mandatory compliance or voluntary targets. There are two distinct mechanisms at work to bring about a reduction in carbon emissions under a carbon trading market. Allowance-based schemes are based on the right to produce a certain quantity of greenhouse gases. One allowance or credit equates to 1 tonne of carbon dioxide equivalent emitted into the atmosphere. This is relatively easy to measure, and technology and expertise are available to validate the quantities produced, although levels are less easy to predict in advance. Tradable rights to emit, called allowances, are distributed to producers of carbon pollution. Companies are free to trade allowances on the carbon market. Project-based schemes are based on credits certifying that 1 tonne of carbon dioxide equivalent has been removed or saved from emission into the atmosphere. Predicting and subsequently proving something has not happened is more complicated to measure, therefore elaborate control mechanisms have developed to verify these credits. The essential requirement is that the savings are additional to business as usual. For example, if an industry is legally required to reduce greenhouse gases, then any reductions made would be considered ‘business as usual’ and not generate credits. The easiest projects to classify are those that have no other income other than that generated by carbon credits, such as methane capture in landfill sites. Sustainability Perspectives 12 Both allowance and project-based schemes should be subject to external validation and verification processes in order to ensure that the environmental integrity of the scheme is maintained and actual reductions take place. Credits should also be registered with a central body to ensure they are only ‘retired’ once (removed from a central registry to keep track of overall emissions reductions) and not sold multiple times. 2.983 Total Global Markets 2.918 Total Regulated Markets 1.667 1.642 24,6 2006 65 Total Voluntary Markets 2007 Volume of carbon credits in Metric Tonnes of CO2 Source: World Bank [3] Ecosystem Marketplace and New Carbon Finance [4] Compliance buyers can only buy compliance credits in order to meet regulatory targets. Voluntary buyers can buy credits from the voluntary and/ or the compliance market (including those buyers who already participate in the compliance market and wish to buy voluntary credits). The voluntary market represents a tiny but rapidly growing portion of the overall carbon market. 4. Breaking the Climate Deadlock- a global deal for our low-carbon future. The Climate group, July 2008 Sustainability Perspectives 13 What is the compliance trading market? At a glance: The Facts: • Mandatory emissions reduction targets are set for countries, industries and companies. • Three main mechanisms were introduced under the Kyoto protocol: the Emissions Trading Scheme, Clean Development Mechanism and Joint Implementation. These mechanisms encourage sustainable development by technology transfer and investment, reducing emissions in other countries in a cost effective way, and encouraging private sector and developing countries to contribute to emissions reductions. • Emissions Trading Scheme (ETS): the largest scheme is the European ETS that trades in European Union Emissions Trading Scheme Allowances or EUAs. Companies which exceed their emissions target must offset the excess emissions by buying EUAs, or pay a fine. Setting an accurate and challenging cap for CO2 emissions is essential to maintaining the market price for carbon credits. • Clean Development Mechanism (CDM) projects are dominated by energy efficiency and renewable energy projects. The CDM requires emissions reductions to be in addition to savings achieved through business as usual. It allows companies in developed countries to invest their money where it will have greater impact than their own internal emissions reductions schemes. It provides an incentive for industries in developing countries to adopt cleaner technology. The credits produce are known as Certified Emissions Reductions or CERs. • Joint Implementation (JI) projects enable industrialized countries or companies to carry out projects in other developed countries and use them against their targets. Credits are known as Emissions Reduction Units or ERUs. • Renewable Energy Credits (RECs) can be used to achieve compliance targets. Outlook: • The scope and scale of compliance markets look set to increase as new trading schemes are established in other markets, and governments extend the scope of regulations to cover more businesses e.g. the Carbon Reduction Commitment in the UK. • Giving organisations the opportunity to profit from their actions is a powerful driver for the behavioural and systemic changes needed in industry to deliver emissions reductions. Indeed, increasing energy bills and the rising cost of raw materials means that making energy savings and investing in future technologies makes good business sense. Sustainability Perspectives 14 As part of international commitments to reduce greenhouse gas emissions, developed countries are allocated emissions allowances based on their agreed national reduction target. The government then allocates these allowances to industry using a ‘cap and trade’ control mechanism. The benefit of a ‘cap’ is that it sets an environmental outcome, and then the market sets the price accordingly. Each allowance unit is equivalent to one metric tonne of CO2. Allowances are distributed freely or through an auction in order to create market demand and establish the price for a credit within emissions trading schemes. Essentially allowances are set at a level just below business as usual and this sets the limit of a companies’ CO2 output or ‘cap’. Companies then have three mechanisms to achieve the target: • Make direct emissions reductions, through internal abatement or changing manufacturing processes, releasing surplus allowances which can be traded for profit on the carbon market through the Emissions Trading Scheme. • Buy extra allowances on the carbon market to cover excess emissions. • Buy credits by funding projects that remove the required amount of emissions in developing countries via the Clean Development Mechanism, or in developed countries via the Joint Implementation scheme (although the portion that can be offset this way is capped). SELLER Surplus credits SELLER Surplus credits BUYER Emissions cap Direct or through a broker Direct or through a broker ETS CDM /JI Carbon trading transactions CO2 emissions emissions over cap credits Sustainability Perspectives 15 Emissions trading schemes The European Union’s Emissions Trading Scheme (EU ETS) is the world’s biggest mandatory cap and trade system for carbon dioxide equivalents and it is growing fast. It represents 78% of the value of the world carbon trading market [5]. The cap is set at about 2 billion tonnes of carbon a year, which will decrease progressively overtime. The scheme covers some 12,000 energy intensive industrial plants across the EU. Other markets are developing compliance trading schemes, including Norway, Australia, Canada, Japan, and the Regional Greenhouse Gas Initiative in the US. “ The potential size and scope of a structured carbon emissions market in the US is unequivocally vast. It is certainly possible that the emissions markets could overtake all other commodity markets.” Bart Chilton, commissioner of the Commodity Futures Trading Commission, US [6] The allowances traded are known as European Union Emissions Trading Scheme Allowances or EUAs. Companies which exceed their emission target must offset the excess emissions by buying EUAs. To manage the trade in allowances, each country has a national emissions allowance registry detailing accounts of companies included the scheme. A complex market of brokers and electronic exchanges now exists where “forward contracts” are traded for delivery at a future date. Setting an accurate and challenging cap for CO2 emissions is essential to maintaining the market price for carbon credits. When allowances exceed emissions, the market reacts accordingly and the price of carbon drops. This reduces the financial incentive for companies to make reductions. One of the key challenges for industry is the uncertainty over the long term future of emissions trading schemes. It is difficult to factor in the financial implications of investing in energy efficient technologies if the future of trading the savings from these projects is uncertain. Currently carbon management is largely an accounting exercise, establishing the baseline for future reductions. However, it is beginning to appear on balance sheets as a significant liability for some companies involved in the compliance market. 5. State and trends of the carbon market 2008. World Bank report, Washington DC, May 2008 6. Carbon trading set to dominate commodities. Financial Times June 25, 2008 Sustainability Perspectives 16 UK Energy Companies: Energy companies in the UK were accused of making windfall profits of up to £1.3 billion from the over allocation of allowances at the start of the EU ETS, and then passing on some of those costs to consumers through their energy bills. According to a Radio 4 File on Four documentary [7] in April 2007 the EU ETS caps had been set far too high. A spokesperson from the campaign group Carbon Trade Watch said: “ This is one of the biggest scandals of the EU ETS. It was revealed that there had been massive over allocation of permits across the board in Europe. So companies and businesses had actually been allocated more permits than they actually needed.” This meant that energy generators not only had little to do to meet targets, they also had surplus permits that could be profitably traded. This surplus led to a crash in the price of carbon credits. In order to avoid this happening again, the government is planning to auction all of the allowances to large electricity providers, and set more stringent reduction targets in phase 3 of the EU ETS. The reality is that financial incentives are a more motivating mechanism than imposing carbon taxes in order to drive the behavioural and systemic changes needed in industry to deliver emissions reductions. Giving organisations the opportunity to profit from their actions is a powerful driver for change. Indeed, the current climate of increasing energy bills and rising cost of raw materials and resources means that making energy savings and investing in future technologies makes good business sense regardless of the impact on climate change. Is the EU ETS driving emissions reductions? A survey by Point Carbon in February 2008 showed that 62% of companies report reducing or planning to reduce emissions as a result of the ETS. However, the verification of these reductions has not yet taken place [8]. 7. Carbon Trading, File on Four BBC radio 4, June 25th 2008 8. Point Carbon (2008): Carbon 2008 - post 2012 is now. Røine, K., E. Tvinnereim and H. Hasselknippe (eds.) 60 page March 2008 Sustainability Perspectives 17 Focus on the Building Trade: Whilst the focus on energy efficiency seems a recent trend, some industries such as the building trade have been improving energy efficiency for decades. The key shift from measuring energy in kilowatt-hours to carbon dioxide in 2005 signalled the alignment with the climate change agenda. UK Government regulations require that by 2016 all new buildings will be ‘zero carbon’ over a year. This means that buildings will be so efficient in their energy use in terms of heating, cooling and water systems, that all their energy needs will be able to be met by renewable sources. Whilst the exact mechanism for this is still under debate, the principle is not. “ It is much more expensive to generate electricity than to save it.” John Tebbit, Industry Affairs Director Construction Product Association The housing analogy is a useful one when considering the different ways to achieve the end goal of emissions reduction. • Adding loft and water tank insulation and installing energy efficient light bulbs are quick solutions to reducing energy loss where costs are soon recovered. • Installing efficient boilers and double-glazing requires more capital investment, and will pay back in the longer term, but does not affect the appearance of the house significantly. • Installing solar panels, wind turbines or ground source heat pumps requires a lot of investment, a long time scale and affects the physical appearance of the property or garden. • Moving to a new eco-efficient house is a large financial commitment reliant on expectations that the cost of energy will rise significantly, and inefficient housing will be penalised. However all of these actions depend on how the building is used. For example, energy savings from installing double-glazing will be negated if the windows are left open when the heating is on. Education and behaviour changes are key to delivering the savings. Overcoming inertia is a big stumbling block and a carrot and stick combination of government regulation and financial subsidies and incentives are used to motivate householders to make these changes. In a similar way, there is a range of activities of different scales that a company can undertake to reduce emissions. Which of these is economically viable depends on the timescale and the external environment, as well as the receptiveness to change behaviour. The more a government can reassure companies that carbon trading and emissions reductions are here to stay- the more likely organisations are to invest in long term schemes. Sustainability Perspectives 18 Clean Development Mechanism (CDM) The Clean Development Mechanism (CDM) was designed to facilitate the flow of capital and technology to developing countries to enable them develop in a sustainable way. It has two main benefits: “ People who have been working in this sector for • It allows companies in developed countries to invest in schemes in de- many years have been veloping countries where the capital will generate more cost effective astounded by the speed and emissions reductions. scale of change. We should • It provides an incentive for industries in developing countries to adopt not underestimate what has cleaner technology that is not yet required by government legislation. been achieved as a result of the CDM” Emissions reductions under this scheme need to be independently verified Greger Flodin, Rabobank. by the UN in order to receive emissions credits known as Certified Emissions Reductions (CERs). The standards are well defined, and projects must comply with approved methodologies for calculating baseline emissions, monitoring progress, reporting and certifying results. Certified Emissions Reductions can be bought by companies meeting their compliance targets, but also by voluntary off setters. Gold Standard CERs generally attract a premium price due to limited supply of projects qualifying for the standard. Central to the Clean Development Mechanism scheme is the principle of additionality. Projects must reduce emissions by an amount that is additional to business as usual, or must demonstrate that the project could not have been completed without the income from selling offset credits. The type of project allowed under the scheme varies greatly. In 2007 the single biggest category of projects was energy efficiency and fuel switching (40% of volume supplied) followed by renewable energy (24%) and industrial gas emissions (17%). Other projects include agro-forestry and waste management [5]. These projects are dominated by China which issues 73% of the volume supplied, followed by India with 6%. The biggest greenhouse gas emissions source excluded from the CDM are deforestation and degradation projects. These areas were excluded from the CDM due to questions about lack of permanence, leakage (concerns that logging activity was merely displaced elsewhere) additionality and complexity of rights over land and associated income. Discussions are currently underway to develop methodologies that would allow Reduced Emissions from Deforestation and Degradation (REDD) projects in the CDM. There is currently only one reforestation project approved by the CDM [9]. 9. UNFCCC web site: CDM statistics 5. State and trends of the carbon market 2008. World Bank report, Washington DC, May 2008 Sustainability Perspectives 19 The variety of projects and difficulty in proving additionality means that some are inevitably better than others. This led to a series of exposés by the media, highlighting projects which generated huge profits as a result of participation in the CDM scheme. Whilst the amount of profit made may be disproportionate to the action, there is no doubt that a potent greenhouse gas was prevented from being emitted as a result of these projects. Aside from the question of such projects meeting the wider objectives of the CDM scheme, the opportunities for new large industrial gas projects are almost exhausted under current methodologies. Only two industrial gas abatement projects entered the pipeline in 2007 [5]. In their place, the number of clean energy projects are emerging as the most common type of CDM project. Another challenge is the degree to which projects realize the emissions reductions initially forecast. Research by IDEAcarbon [10],[11] showed that projects that have already started to issue UN certified credits are delivering 96% of the credits expected at project design stage. However, these figures are dominated by a small number of large projects dealing with industrial emissions. More than 300 smaller projects, including biomass in Brazil and landfill gas in South Africa, were only delivering 70% of what was promised. Ian Johnson, Chair of IDEAcarbon and former Vice President for Sustainable Development at the World Bank, said: “ Our analysis shows that the concern of many investors is justified – carbon projects are risky and until recently these risks have been underestimated. But, the analysis also highlights the enormous potential in this market. Well designed projects are delivering genuine emissions reductions at an increasing scale” Ian Johnson, Chair of IDEACarbon In order to reassure investors, IDEACarbon has developed an AAA rating scheme. This joins an increasing number of evaluation methods and standards over and above the CDM scheme requirements, of which the Gold Standard is generally acknowledged to be the highest. This identifies projects that deliver emissions reductions, as well as factoring in the community and social benefits of the project in the host country. The Gold Standard is endorsed by a number of NGOs. 5. State and trends of the carbon market 2008. World Bank report, Washington DC, May 2008 10. Carbon credit schemes fall 30% short of projections, report claims. Guardian, June 25th, 2008 11. IDEACarbon press release Sustainability Perspectives 20 The CDM has been criticized for a lengthy and expensive registration and approval process. Currently two thirds of projects are going through registration, which can take up to two years. However it is envisaged that the CDM will be reviewed, improved and reformed to encompass a broader range of smaller projects. As more experts are trained to process and verify applications, more projects will be released. Despite the criticism, there is little doubt that the CDM has been instrumental in creating the incentive for many emissions reductions projects that would not otherwise have taken place. For example, the opportunity for wind sector development in India was under discussion for many years, hampered by debates about the relatively high cost of wind energy for low-income consumers. The CDM gave the impetus for these plans to be implemented. Landfill methane capture is another example of emissions reductions that would not otherwise have taken place. Joint Implementation (JI) In contrast to CDM projects, Joint Implementation, or JI, projects enable industrialized countries or companies to jointly carry out emission reduction projects with other developed countries and use them against their targets. The same principle of additionality applies. The credits generated are called Emission Reduction Units or ERUs. The majority of the projects are in Russia (36%) and the Ukraine (33%), reflecting the opportunities in the oil, gas and power sectors. The volume of credits generated in the Joint Implementation sector has nearly tripled in 2007 and value has increased to $499 million [5]. The JI projects undertaken differ from the CDM. Projects targeting methane dominate the market (47% of volumes transacted), followed by renewable energy (37%) and industrial gas abatement (23%). This is a change from the pattern in 2006 when clean energy represented two thirds of the volume traded [5]. 5. State and trends of the carbon market 2008. World Bank report, Washington DC, May 2008 Sustainability Perspectives 21 Renewable Energy Credits (REC) These credits can be used to achieve compliance targets and can also be sold as voluntary offsets. They are created by the generation of one megawatt hour of electricity from a renewable source such as solar, wind, biomass or geothermal. Renewable Energy Credits enable organisations in developed countries to purchase renewable energy even if it is not locally available. The REC market operates separately to the carbon markets in countries such as the US, Canada, Europe and Australia. Financial context Financial trading of compliance credits is hugely complex and influenced by many factors. The market involves project developers, wholesalers, retailers, brokers as well as electronic energy and emissions exchanges such as the European Climate Exchange. CER credits (from the Clean Development Mechanism) can be substituted for EUAs to meet European Union Emissions Trading Scheme targets. To add complexity, trading is usually undertaken in forward and futures contracts, where the price is set now but allowances and payment don’t change hands until an agreed date in the future. Emission permits issued can be saved for subsequent years (banking), or future year’s permit allocations can be brought forward for use in the current year (borrowing). The lack of a link between the EU Emissions Trading Scheme and the United Nation’s Kyoto carbon offsets market is cited as a reason for the difference in price between CERs and EUAs, even though both have the same value for compliance in the EU market. It has recently been announced that the EU registry will be linked to the UN’s International Transaction Log in October of this year. This is expected to facilitate trade of issued CERs across Europe. The ranking of credits by price can be summarised as: EU Emissions Trading Scheme (EUA) CDM Certified Emissions Reductions (CER) Joint Implementation Emissions Reduction Units (ERU) Voluntary Emissions Reductions (VER) Chicago Climate Exchange Carbon Financial Instruments (CFI) Non - compliance credits for reference Sustainability Perspectives 22 What does the future hold? All United Nations Framework Convention on Climate Change (UNFCCC) member countries have agreed to negotiate a sucessor to the Kyoto protocol, giving some long term security to compliance trading schemes. Future regulation is expected to become more extensive. A number of regional or national trading schemes will be launched in the next few years. E.g. the first US cap and trade programme, the Regional Greenhouse Gas Initiative (RGGI) will begin in 2009. Creation of new trading markets, and increasing links between existing markets will drive demand for credits, however it is anticipated that many of the compliance buyers in existing markets may well have already bought a significant portion of the credits needed to meet their Kyoto targets. The price for credits is generally expected to rise in the future. However, the IEA (International Energy Agency) recently stated that the cost of carbon dioxide emissions would need to be at least $200 a tonne to deliver the incentive for industry to invest in radical new technologies such as hydrogen fuelled vehicles [12], vs a price for EUA of €25 today (Aug 2008). 12. IEA proposes much higher carbon offsets, Financial Times June 6th, 2008 Sustainability Perspectives 23 The European Commission is discussing Phase 3 of the EU ETS covering 2012 –2020 period. A number of lessons from phase 1 are being incorporated, including: • Tightening the cap for overall emissions for the EU to 21% below 2005 levels • Proposing to include the aviation sector (currently 3% of EU emissions) • Auctioning all allowances to the power sector by 2013 • Reducing the level of free allocation to zero in 2020 In the UK a new carbon trading scheme for non energy-intensive organisations is being introduced in 2010. The Carbon Reduction Commitment (CRC) scheme covers electricity and gas consumption for companies whose emissions fall outside Climate Change Agreements and the EU ETS, including large business and public sector organisations, such as universities, retailers, hotel chains and local authorities. Offsetting is specifically excluded from this legislation as the focus is on driving and rewarding end user efficiency. This is an interesting change in focus from the basic premise of the CDM where investment flows to the most cost effective emissions reductions projects, to investment being reallocated to the most effective emissions reduction projects. UK 2010: The Carbon Reduction Commitment (CRC) •The Carbon Reduction Commitment is a mandatory emissions trading scheme aimed at improving energy efficiency and reducing emissions. Companies whose energy use in 2008 is more than 6,000 MWH per half hour will need to purchase carbon allowances to cover their emissions. There will be an introductory three-year phase in which carbon allowances will be sold at a fixed price of £12/tCO2. In the second phase, there will be a cap on allowances, and all allowances will be auctioned. •The revenue raised will be recycled to participants proportional to their 2009 emissions adjusted by a bonus or penalty related to their performance in the CRC league table. An improved league table performance, translates into a direct financial return. An ‘early action’ metric will be developed to give some recognition to good energy management implemented before the start of the scheme. So the more energy you save, the more you earn. http://www.defra.gov.uk/ Sustainability Perspectives 24 What is the voluntary trading market? At a glance: The Facts: • The voluntary carbon market is growing rapidly and is expected to continue to do so in the future. • It consists of the Chicago Climate Exchange, a voluntary cap and trade scheme, and the wider Over The Counter (OTC) market of all other credits generated outside a regulatory system. • Voluntary credits are generated by a diverse range of projects of varying quality and scale in both the developed and developing world. These include renewable energy, reducing industrial emissions, community energy and efficiency projects, and biological sequestration. • Projects are generally considered to have a wider range of sustainability benefits than compliance projects, and are often smallscale community based initiatives. • Reduced Emissions from Deforestation and Degradation projects (REDD) are largely excluded from Kyoto markets; while this is under review, changes to the regulatory framework are not expected until 2012. • The majority of buyers are businesses, whose primary motivations are corporate responsibility and public relations/ branding. • A wide variety of standards exist: the highest quality is generally thought to be the Gold Standard VER. As the market evolves, it is expected that the VER (not Gold VER) will become the standard of choice. An industry body known as the International Carbon Reduction and Offset Alliance (ICROA) has been established to share best practice. Outlook: • The UK government will launch a quality assurance mark to guide voluntary offset purchasers, however it will limit the credits it recommends to those generated by compliance schemes at present. • Key principles in evaluating offset projects include: additionality, avoiding carbon leakage, permanence, verification, transparency avoiding double counting, immediacy and proportionality. The voluntary carbon market refers to all trade that is outside a regulatory market. It includes companies who wish to reduce carbon emissions over and above any legal obligation, as well as individuals wishing to offset emissions created by their personal lifestyle. Transactions in this market are generally referred to as offsetting. Offset buyers are not actually reducing emissions; they are only preventing a net increase. Sustainability Perspectives 25 Carbon offsetting involves calculating your emissions and then purchasing ‘credits’ from emission reduction projects. These projects have prevented or removed an equivalent amount of carbon dioxide elsewhere. UK Govt DEFRA, http://www.defra.gov.uk/ Voluntary buyers have a number of options to offset their emissions by purchasing credits from a number of sources: • Purchase credits generated for compliance schemes • The Chicago Climate Exchange (CCX) • Credits sold outside the regulatory market or CCX are generally referred to as the ‘voluntary offsets market’, increasingly known as the over the counter (OTC) market A report by Ecosystem Marketplace and New Carbon Finance [13] valued the international OTC market at $258 million in 2007. The total voluntary market was worth $331 million, representing only 2% of the overall market. The Chicago Climate Exchange (CCX) The Chicago Climate Exchange (CCX) is described on its website as: The world’s first and North America’s only active voluntary, legally binding integrated trading system to reduce emissions of all six major greenhouse gases (GHGs), with offset projects worldwide. [14] The Chicago Climate Exchange is a voluntary cap and trade scheme that incorporates both allowance based credits (generated as a result of the members emissions reductions), or projects based (from qualifying projects). Credits can also be sold to non-members as offsets. CCX Members make a voluntary commitment to meet annual GHG emission reduction targets. These are achieved through a legally binding compliance regime. CCX Members commit to a reduction schedule that requires year 2010 emission reductions to be at least 6% below baseline. The market is small, but growing, and transaction volume doubled from 2006 to 2007. 13. State of the Voluntary Carbon Markets 2008- New Carbon Finance and Ecosystem Marketplace, May 2008 14. Chicago Carbon Exchange website Sustainability Perspectives 26 Different types of offset projects 01/ Renewable energy Creating heat or power from renewable sources such as wind, biomass, solar, hydro, geothermal and . These are often large scale long term projects. 02/ Reducing Industrial Emissions Modifying existing or introducing new technology to reduce greenhouse gas emissions. Varying size and complexity including gas recovery or destruction, industrial energy efficiency, low energy lighting, fuel switching to natural gas or biomas briquettes. 03/ Community energy and emissions efficiencies Designed to change peoples behaviour by providing new tools or equipment with relevant education and incentives. Often involve community benefits as well, but as a consequence are difficult to measure and quantify. 04/ Biological sequestration Any land use change that increases vegetation or soil capture of carbon. Projects include: reforestation, afforestation and preventing deforestation. Sustainability Perspectives 27 The Over The Counter Market (OTC) Almost all credits sold in this market are generated by projects and are known as Voluntary Emissions Reduction (VERs). These credits are not regulated, verified or monitored in the same way as compliance credits and cannot be sold into the compliance markets. The market is growing rapidly, and trebled between 2006 and 2007. The types of projects that dominate the voluntary market are different from the regulatory market. Some argue that one of the main benefits of the voluntary market is to experiment with projects and methodologies outside the regulatory context. Projects are often small and community based with sustainable development benefits that can be difficult to quantify. In 2007 the OTC market was dominated by projects from renewable energy (31% of credits sold), energy efficiency (18%), forestry and land based projects (18%) and methane destruction (16%). This is a shift from the previous year when forestry was the biggest sector with 37% and industrial gas represented 20% of volume market share [13]. Many voluntary offset buyers seem to prefer obviously ‘green’ projects such as renewable energy rather than investing in industries that are generating GHG already such as HFC destruction projects. OTC projects are located primarily in Asia (39%) followed by North America (27%) [13]. This trend towards projects from developing markets reflects the opportunity to buy VERs from projects waiting to be approved under the CDM but which are already generating emissions reductions. 3% 3% 8% 19% 5% 4% 40% 6% 12% Transaction volume by type of emissions offset, TC 2007 Total institution Events % institution Product On site Commuting Electricity Business flights Source: Ecosystem Marketplace and New Carbon Finance [13] Other 13. State of the Voluntary Carbon Markets 2008- New Carbon Finance and Ecosystem Marketplace, May 2008 Sustainability Perspectives 28 Over 170 offset providers [15] have sprung up to meet increasing demand for carbon credits. Some of these companies are not-for-profit, but many are businesses, and the proportion of money actually passed on to the project itself varies greatly once profit and overheads have been considered. The majority of buyers in 2007 were private businesses (79%) of which two thirds intended to offset emissions immediately. The remaining third were bought for investment purposes. Credits often pass through a complex chain of buyers and brokers before reaching the final purchaser. 13% of credits were bought by NGOs, 5% by individuals and less than 1% by governments. Demand is driven by the EU and US, accounting for 84% of purchases [13]. The trend for companies to declare themselves ‘carbon neutral’- with no net carbon impact on the environment- has led to an increase in the number of companies buying to offset their total institutional emissions. Carbon neutrality has emerged as an increasingly popular idea for companies wishing to communicate to stakeholders that they are taking real and meaningful action to reduce their carbon footprint. However the term is somewhat misleading as carbon dioxide cannot be ‘neutralized’ once it is in the atmosphere, and in fact the intention is to equal the amount of emissions generated through investing in projects which absorb or sequester carbon dioxide elsewhere in the world, allowing a hypothetical zero to be calculated. Research also indicates that the primary motivation for buyers is corporate responsibility and public relations above anticipation of regulation and investment [13]. Therefore the quality of projects purchased is key, as buyers who are purchasing to improve corporate reputation do not want to be associated with dubious projects. As a result buyers are becoming more demanding, and requesting detailed information on the management, measurement and delivery of projects. In order to facilitate this, a proliferation of standards was launched in 2007; over twenty now exist in the market. Offset standards Research has identified that the top choice of standard planned to be used in 2008 are the Voluntary Carbon Standard (VCS), the Gold Standard, the VER+ and the Climate, Community and Biodiversity (CCB), and indicate that 87% of credits are third party verified [13]. 15. The ENDS guide to Carbon Offsets, 2008 13. State of the Voluntary Carbon Markets 2008- New Carbon Finance and Ecosystem Marketplace, May 2008 Sustainability Perspectives 29 Principle Voluntary Offset Standards Voluntary Carbon Standard http://www.v-c-s.org This aims to standardise and stimulate innovation in the offset market. Gold Standard VER www.cdmgoldstandard.org This only accepts renewable energy and energy efficiency projects that also deliver sustainable benefits. It specifically excludes forestry and land use projects. Originally designed by the WWF and other NGOs, businesses and governmental organisations to supplement CDM projects, it is also used to certify voluntary projects. Linked to VER Gold Standard Registry. VER+ This certifies both carbon neutrality and carbon offsets, based on CDM and JI methodology. Climate, Community and Biodiversity http://www.climate-standards.org A set of criteria applicable to CDM or voluntary projects, which allows land based carbon mitigation projects to be evaluated including their community and biodiversity benefits. The desire to reassert credibility of the voluntary sector after increasing coverage of carbon cowboy operators and their unscrupulous practices has also led to the formation of International Carbon Reduction and Offset Alliance. The ICROA code was developed by an international industry alliance to set the best practice benchmark for carbon reduction and offset services and products. It supports offsets certified under the Clean Development Mechanism, Joint Implementation, the Gold Standard, and Voluntary Carbon Standard. Spokesperson Edward Hanrahan said the intention was to: “ Show clear blue water between quality operators and non quality operators.” [16], [17] 16. New global offset trade group aims to clean up market, Business Green, June 9th, 2008 17. ICROA Programme and Policy Document Sustainability Perspectives 30 In addition to these standards, the UK Government has also launched guidelines on criteria that should be met for a project to receive a quality assurance mark in a scheme to be fully launched later this year. Companies will pay a fee to apply for the mark and a third party will audit the process. The inten- “ There is not yet clear tion is to focus more on the user end, ensuring that accurate calculations evidence that voluntary are used and transparent information is available so buyers know exactly credits offer a sufficient what they are being sold. Initial recommendations are that credits should be level of certainty to put the bought from the regulated market, including EU Allowances (EUA), Emis- government quality mark sions Reduction Units (ERUs) and Certified Emissions Reductions (CERs). against them.” The quality assurance mark is designed to reassure buyers in the UK that spokesperson, DEFRA environmental benefits will result from the investment: verifying the results of projects that are unregulated or outside the UK is not currently possible. The government has encouraged the voluntary carbon offset industry to coalesce around an industry standard with a view to potentially including voluntary projects in the quality assurance scheme at a later date. The code of best practice issued in Feb 2008 (DEFRA http://www.defra.gov.uk/), which forms the basis of the assurance mark, includes the following assessment criteria: • Additionality, meaning that the carbon savings must be in addition to reductions that would be made anyway • Avoiding carbon leakage, or emissions avoided on one site simply being moved somewhere else • Permanence, ensuring that emissions reductions were not put off until later • Verification systems, for emissions measurement and reductions by an independent body • Transparency, on the methodologies and procedures used • Avoiding double counting, ensuring that emissions counted in an offset product are not counted elsewhere, for example as savings through an emissions trading scheme The debate about the most appropriate criteria for evaluating offsets is likely to continue for some time, but other issues should also be considered: •Immediacy, purchasing offsets now that will not be realized for a long time •Proportionality, the Kyoto protocol supports the supplementary principle, which states that emissions trading should supplement emissions reductions taken by the company, but not exceed them. Sustainability Perspectives 31 Focus on Forestry: Reduced Emissions from Deforestation and Degradation projects (REDD) were largely excluded from Kyoto markets due to the difficulty in meeting many of the criteria above. For example, permanence is debated as trees will eventually die and emit CO2 back into the atmosphere unless a system of continuous replacement is built into the project. Avoided deforestation projects are often criticized for merely displacing logging activities elsewhere in a process known as leakage. Allocation of credits is complex as forest based communities are often put under pressure to sign over ownership when negotiating carbon rights. As a result only one REDD forestry project is included in the Clean Development Mechanism to date. Forestry projects have always been popular in the voluntary market due to the additional benefits of employment, biodiversity, watershed protection and habitat preservation. The concept is easily understood by consumers and can be linked to a basic knowledge of the carbon cycle from school days. Projects include reforestation (replanting previous forest) afforestation (forest where none existed before) and avoided deforestation (preventing existing forest being cut down). Since deforestation is responsible for 20% of global greenhouse gas emissions (source UNFCCC website), action clearly needs to be taken, and the role of REDD projects was discussed by the United Nations Framework Convention on Climate Change (UNFCCC) in Bali, Indonesia. A final decision on the regulatory markets has been deferred to 2009, but the official recognition of the need to reduce emissions from deforestation by encouraging voluntary action is expected to have a big impact on the voluntary market. The development of new technology will also boost confidence in forestry projects. A study by the World Research Institute [18] used satellite imagery to calculate forest cover loss and identify where conservation measures should be concentrated. • Merrill Lynch announced plans to invest in a REDD project in Indonesia, managed by Carbon Conservation. [19] • Marriott International has invested $2m in a deal with the Brazilian state of Amazonas that aims to secure 1.4m acres of rainforest. Participating hotels around the world will make cash contributions to offset the emissions associated with rooms and meetings. [20] 18. Groundbreaking study finds the ‘hotspots’ most responsible for deforestation. World Resources Institute, July 16, 2008 19. Merrill Lynch and Carbon Conservation sign first commercially financed avoided deforestation agreement. press release April 14th, 2008 20. Marriott and Brazilian State of Amazonas partner to protect rainforest. Press release April 7th, 2008. Sustainability Perspectives 32 What does the future hold? There is a risk that the development of regulations and standards in order to improve credibility of the voluntary market will slow down development and kill off smaller projects. This will reduce the speed and innovation of the market, which many feel is its strength. It is generally expected that there will be a consolidation of standards, and many feel that VERs will become the leading standard to guarantee carbon reduction. Smaller more niche standards will probably remain for specialist areas e.g. Plan Vivo standard for forestry projects. There are a number of possible futures for the voluntary market. Some argue that the increasing cost of credits will drive companies to find technological solutions to reduce emissions internally, and therefore the demand for voluntary offsets will decline. Others argue that the voluntary market will be incorporated into the compliance market, as the criteria, scope and scale of projects included in schemes such as the Clean Development Mechanism (CDM) increase. The CDM is currently considering how to incorporate forestry projects into its methodologies although this is unlikely to reach the market until 2012. Project developers may prefer to produce credits for regulated schemes as they generally earn a higher price. Another scenario is that inappropriate use of offsets by companies, coupled with negative coverage of some dubious-quality projects, will undermine confidence in the market as a whole. This will deter other companies from associating themselves with reductions schemes viewed as an easy way out of their own obligations. Despite these various scenarios, it is generally agreed that the voluntary carbon market will continue to grow in future. Companies and individuals will continue to invest in projects that have wider sustainability benefits, greater human interest and community benefits as well as delivering emissions reduction. However the onus remains on individual buyers to make informed choices and select high quality projects where the environmental benefits of the project are realized. Sustainability Perspectives 33 Perspectives on Offsetting Instead of acknowledging “ The offsetting mechanism “ Offsetting might be a part the uncomfortable but is fine as a means of of the story, but it is much necessary truth that we capping total emissions preferable to focus attention cannot responsibly persist and providing a trading on direct action by reducing with our current lifestyle, environment. It is the energy use or replacing climate-conscious people are application that has been energy sources” being encouraged to believe inappropriate. The price of Dax Lovegrove, WWF that with offset schemes they carbon is too low, and there can continue as they were, is a culture of zero guilt as long as they pay money to with no incentive to change absolve themselves of their behaviour” responsibility to the climate Simon Manley, Converging World Carbon Tradewatch “ “ I like to use the analogy that Given the scale and humanity is in a sinking complexity of the climate needed to get to a low carbon boat, with water pouring change challenge, we society, carbon offsetting through a huge hole in its see a continuing need is a start, but in the greater side. We have to fix the hole for voluntary regimes to scheme of things almost – the role of politicians and complement and extend irrelevant. The emphasis scientists. But we also have the impact of regulated should be on energy to bail the boat to buy time responses to climate change. reduction and efficiency, and for this to happen. Carbon The Carbon Neutral Company changing peoples behaviour” offsets are the boat–bailing. In the context of the actions Greger Flodin, Rabobank Let’s embrace them as a crucial transition tool” Mike Mason, Climate Care Sustainability Perspectives 34 The debate about the pros and cons of carbon offsetting generates a great deal of passion, and has raged long and hard. However, there are some key points to present on either side. FOR AGAINST • Emissions reductions occur where the cost is lowest, often in developing markets. Going for the ‘low hanging fruit’ means that the easiest savings are made first, delivering the most cost effective emissions reductions before moving onto longer term or more complex projects. • Offsetting is a distraction from the main task of reducing industrial emissions in developed countries. It enables companies to abdicate responsibility for reducing their own emissions. • Investment and technology are channelled to developing markets which otherwise would not have been available. • Offsets incentivise action in countries and companies that are not legally required to make emissions reductions by governments or industry bodies. • Businesses can use the price of offsets to influence internal financial decisions. • The voluntary carbon market provides people with a way of increasing awareness of their own carbon footprint, which may lead to changed behaviour. • Voluntary projects are often small scale and deliver additional sustainability and community benefits, often to the very poor. • Projects in the voluntary sector allow innovation and experimentation, which can then be applied to compliance markets. • It removes the incentive for a company to identify more complex and costly solutions to its own internal emissions production. • Offsetting is a one-off cost requiring neutralisation on an annual basis, but investing internal projects delivers long-term benefits. • It does not actually reduce an organisation’s emissions baseline in the developed world. • The voluntary carbon market is small and unlikely to have any significant impact in the long term. • The voluntary market reduces the pressure on governments to introduce new legislation to enforce emissions reduction. • Focus has shifted to making money rather than reducing emissions. • The quality of third-party voluntary offsets is difficult to verify compared to direct company action to reduce emissions. Sustainability Perspectives 35 What are the elements of a good carbon management strategy? At a glance: Outlook: Companies need to develop a robust strategy to manage carbon, including the following key steps: • Set Boundaries: clearly defining the scope of direct and indirect emissions included in the strategy. • Measure: conduct a transparent and verifiable analysis process to identify areas of greatest emissions within the chosen boundary. • Avoid: reconsider business processes, products and services to avoid high carbon activities such as business travel, or high carbon products. • Reduce: emissions should be reduced through energy efficiency measures. • Replace: high energy carbon sources with low energy ones, investigating renewable or onsite energy sources. • Explore offsetting and other alternatives. A robust and well-defined carbon management strategy is needed to identify the scope, scale and priority of reductions that are under an organisation’s control. Offsetting should be viewed as one of a number of options that are available to a company to reduce its footprint, however the general consensus from experts is that it should be used as a last resort. Regardless of the type or size of organisation, or the exact methodology or tools used, there are some basic principles that are valid for all carbon management strategies: • Set the boundaries of the carbon emissions your business will measure • Conduct a full carbon inventory of your business operations based on these boundaries • Identify carbon-intensive activities that can be avoided • Reduce carbon emissions where possible and practical • Replace carbon-intensive energy sources with lower carbon ones • Explore alternative solutions Sustainability Perspectives 36 Set the boundaries of the carbon emissions your business will measure A set of guidelines developed by the World Resources Institute and the World Business Council for Sustainable Development are outlined in the Greenhouse Gas (GHG) Protocol [21]. This is widely used as a tool to classify emissions as scope 1, 2 or 3. The GHG Protocol states that Scope 1 and 2 must be included in an organisations boundary when evaluating emissions in order to avoid double counting. The area most debated is scope 3 emissions from activities not directly controlled by the company e.g. employee commuting, business flights, product use and disposal, and carbon emissions generated by the supply chain. As a result reporting on Scope 3 is optional. Upstream Emissions Corporate emissions Downstream Emissions Production of electricity consumed On-site fuel combustion Distribution of products Production of raw materials Company-owned vehicles Retail Processing of purchased materials Business travel Product use Transport of purchased materials Employee commuting Product disposal Outsourced corporate support services Setting boundaries for carbon management scope 1 standard boundary for carbon management scope 2 ideal boundary for carbon management scope 3 21. www.GHG protocol.org Sustainability Perspectives 37 Most companies define their boundary as Scope 1&2 plus business travel from Scope 3. However, those who wish to demonstrate clear leadership on the climate agenda are finding that consumers and investors are increasingly expecting them to influence scope 3 emissions through their dealings with suppliers, contractors and retailers in order to justify a leadership position. Particular care should be taken to communicate goals in the context of the emissions included, and to choose something meaningful, proportionate and relevant to the stakeholders and their experience of the organisation. Measure: Conduct a full carbon inventory of your business operations based on these boundaries It is impractical for a company to collect data and analyse every aspect of its operations and emissions, especially when looking upstream and downstream. Organisations should conduct a transparent analysis process to show exactly what has been calculated and how, and findings should ideally be verified by a third party. Areas of risk and opportunity can then be identified in order to pr ioritise actions and investment areas. Wellestablished credible reporting mechanisms are critical for investor and stakeholder’s confidence in the process. Finally, realistic reduction targets should be set and agreed, with clear timescales and measures in place to track progress. Ideally the target selected should take business growth into account rather than an absolute target. Companies such as the Carbon Trust and Envirowise offer advice to UK businesses on calculating carbon footprints, waste management and reducing environmental impact. Timberland Clothing and shoe retailer Timberland discovered that 79% of the emissions from a lifecycle analysis of its footwear were derived from the livestock used in the production of leather. [22] Many companies strive to calculate every last emission so they can communicate a goal of ‘carbon neutrality’. Since the variety of assumptions and methodologies used to determine this end point is so great, the term is increasingly viewed with scepticism, and is becoming meaningless. 22. Getting to zero- defining corporate carbon neutrality. Forum for the Future, clear air- cool planet 2008 Sustainability Perspectives 38 Avoid: Identify carbon-intensive activities that can be avoided The first practical step should always be to avoid carbon intensive activities. This may involve re-evaluating strategies and business processes. Business travel is the most often cited example of avoided emissions. Less well-known measures could include phasing out carbon intensive products or services to simplify consumer’s choices. Consumers Favour Edited Choices In the World Environment Review, a survey of UK consumers [1] showed that consumers were, broadly speaking, in favour of editing out unsustainable choices by removing them from sale rather than complex financial measures to influence positive consumer choice. The research found high levels of support for banning incandescent light bulbs (78%) and only allowing water efficient shower heads to be sold in retail outlets (65%). Reduce: Reduce carbon emissions where possible and practical The next step is to reduce emissions by becoming as energy efficient as possible. This includes energy savings from switching off lights, installing building insulation and adopting more efficient manufacturing processes. The appeal of this particular step is that improving energy efficiency often goes hand in hand with cost savings. Given the rising cost of oil, this may become a key area of focus for businesses in the short term. Replace: Replace carbon-intensive energy sources with lower carbon ones For many businesses, there is a significant opportunity to replace high-energy carbon sources with low-energy sources. Many organisations purchase renewable energy either from the grid or through renewable energy certificates (although there are questions about additionality since power companies already have to provide renewable energy). Other companies are taking direct action and generating renewable electricity on site, or investing in combined heat and power technology to generate further energy sources. 1. Tipping point or turning point: social marketing and climate change, IPSOS MORI, July 2007 Sustainability Perspectives 39 London Fire Stations Eight London Fire Stations have installed solar photovoltaic panels on the roofs of existing buildings in order to reduce carbon emissions. The London Fire Brigade is undertaking a range of measures, including installing Combined Heat and Power units to service the stations’ hot water requirements, refreshing existing plant equipment including boilers, replacing inefficient lighting and introducing a new fleet of fire engines to meet EU emissions targets. The project was managed by Solarcentury [23] so that the buildings were functioning normally whilst the alterations took place. Explore alternative solutions At this stage, most carbon management strategies recommend offsetting. “ People simply cannot have a proper carbon management strategy without some element of offsetting. Of course, you must go through the hierarchy of options, such as measurement and reduction, and of course it cannot represent the only pillar of your strategy. But, for any individual or organisation, there will always be unavoidable emissions, and for those, voluntary offsetting is a worthwhile strategy. I have always approached offsetting from that position!” Jonathon Porritt, Forum for the Future [24] A number of experts suggest that a carbon management strategy must include offsetting, although many go on to qualify it by stating it should be used as a last resort. Given the scale of action required, every opportunity should be taken to reduce emissions. Organisations should expand their focus from their own footprint to looking at the broader impact of their supply chain and influence they have in society. Alternative strategies that offer reduction opportunities should be considered before offsetting, and even then, organisations should approach it in more creative and intelligent ways. 23. London Fire Brigade , solarcentury 24. Jonathon Porrit, Forum for the Future Sustainability Perspectives 40 Carbon management best practice Once an organisation has been through the process of developing a carbon management strategy, the question remains of whether to voluntarily purchase offset credits or not. In order to identify suitable alternatives, it is important to understand the motivation behind the desire to offset voluntarily. A range of reasons exist, including: • To demonstrate to external stakeholders that actions are being undertaken • To meet self imposed targets of carbon reduction • To motivate employees and encourage behaviour change • To act as a good corporate citizen and enhance corporate reputation • To enhance brands or products by addressing consumers ethical and environmental concerns • To educate the organisation and begin to engage in the management of carbon • Risk mitigation: anticipation of the introduction of legislation, avoiding negative press Clearly, some motivations are internal and some external, and this will influence the type and detail of action taken and the reporting required. When considering if offsetting should be part of a carbon management strategy, or if alternative solutions may be more effective, additional questions should be considered: • Is the organisation prepared to commit resources and skills to carbon reduction projects in house or through a third party? • How important is the potential PR of projects selected- either internally or externally? • How risk averse is the organisation? • Is external validation required? • How engaged and motivated are employees to participate in emissions reductions schemes? • How quickly do results need to be realised? At first sight the task of carbon management can seem overwhelming, but organisations can use basic information such as existing energy bills or travel costs to make decisions affecting their carbon footprint e.g. switch to renewable energy sources or change travel policies to reduce flying. Any savings from energy efficiencies could be reinvested in further carbon reduction programmes. Once the organisation has a clear picture of these issues, the following alternatives can be considered, all of which help educate the organisation and encourage engagement with the goal of carbon management. Sustainability Perspectives 41 Objective: Demonstrate to external stakeholders that action “ What businesses and consumers both share is a desire for one credible way to prove an organisation has reduced their carbon emissions year on year without the use of offsetting. The Carbon Trust standard is the only answer to this.” Tom Delay, chief executive of The Carbon Trust [25] The Carbon Trust Standard The Carbon Trust has launched a new green standard that certifies an organisation has genuinely reduced its carbon footprint and is committed to further reductions year on year. The Carbon Trust Standard covers only direct emissions from a company’s fuel and electricity use, as well as from business travel such as flights. It does not cover the emissions caused by a firm’s products, supply chain, or sites outside the UK. Companies pay up to £12,000 for the accreditation depending on their energy bill. There is no minimum reduction target. Companies can either demonstrate an annual decrease of 1 tonne of carbon dioxide, or make relative improvements in carbon emissions, such as compared to turnover, of 2.5% a year. Firms given the standard must continue to decrease their emissions in future, or lose their green status. Best practice: Inhouse emissions reductions achievements are externally accredited and communicated. 25. Carbon Trust aims to end greenwash by launching company standard, Guardian June 24th, 2008 Sustainability Perspectives 42 Objective: Meet self imposed targets of carbon reduction Any savings made from increased energy efficiency should be placed in a central fund. This can be used to invest in technology to further reduce emissions that would otherwise not be economically viable. This utilises the principle of additionality within the organisation i.e. the project would not have been possible without the investment, and consequently the energy saving are above and beyond business as usual. Institute of Public Policy Research: The Institute of Public Policy Research has recently reviewed its practices in order to reduce its environmental footprint. A range of measures is in place to directly reduce emissions, including reducing flights and raising staff awareness. The process of measuring the carbon footprint and investigating offsetting options highlighted a potential alternative: instigating an internal offsetting system. “ One option we are considering is an internal offsetting scheme where we would pay to ‘offset’ our emissions into a separate fund, which we would then use to make improvements to our office that would help us to reduce emissions. This way we could ensure that the money is being spent on genuine emission reduction projects and we could take actions which we would otherwise not have the budget to carry out. In addition, we could set the price of offsetting at a level that reflects the true cost of emitting carbon dioxide to the atmosphere - the social cost of carbon being a likely choice. Clearly, setting up a system such as this is a great deal more complicated and time–consuming than going through an offsetting company, but we think it could be an effective tool in reducing our total emissions” Jenny Bird IPPR Best practice: Use any savings from energy efficiency to invest in internal carbon reduction projects. Sustainability Perspectives 43 Objective: Motivate employees and encourage behaviour change Schemes can be developed to incentivise behaviour change in the form of rewards or penalties. Scottish and Southern Energy Since a centrally funded cost centre was set up for train travel, Scottish and Southern Energy has seen a two fold increase in train use, with large reductions in car and air travel. A £20 fine is charged for each flight which goes towards a carbon sequestration fund and ‘no fly’ months have been introduced. Sponsorship for these changes has come from the Chief Executive to underline the company commitment to reducing emissions. [26] Microsoft Microsoft introduced employee incentives to improve energy efficiency. Between 2004 and 2007 it saw a 22% improvement in the energy efficiency of its data centres. In one scheme business units were charged for the energy consumed by servers rather than the floor space they took up, which had previously led to the development of very dense power hungry servers that required a lot of cooling. This has incentivised business centres to make the servers more energy efficient. Yearly bonuses for managers are also dependent on year on year efficiency improvements [27] Best practice: Establish a direct link between behaviour change and rewards or penalties. 26. Making advances in carbon management. Best practise from carbon information leaders. IBM and Carbon Disclosure Project, 2008 27. Microsoft pays employees for energy efficiency improvements. Enviromental Leader, July 10th, 2008 Sustainability Perspectives 44 Objective: Act as a good corporate citizen and enhance corporate reputation It is possible to select projects that are more closely aligned to an organisation’s overall goals. In cases where carbon reduction projects closely align with a company’s strategic and philanthropic goals, it may be more beneficial for a company to directly engage instead of purchasing offsets through a third party. Third-party offset projects that claim to support additional community well-being are unlikely to be accredited by official standards. In contrast, projects directly undertaken or supported by a corporation can be ‘bundled’ together with other company-supported projects on other areas and used to generate carbon reduction credits. If it is possible to implement projects in such a way that it meets the organisation’s corporate goals, as well as generating offset credits, then a positive cycle of investment is created. Converging World The charity the Converging World has developed a new model to generate maximum benefit for communities in both the developed and developing world. “ Converging World offers a more ethical and effective alternative to offsetting.” Simon Manley, Converging World • The charity invests donor funds in clean energy projects e.g. wind turbines in India. Donations are matched through gearing from commercial lenders to raise more money. • The revenue from electricity generated is spent on reinvestment in more clean energy as well as funding development work for local communities in the host country. • Credits generated from the production of renewable energy are sold, and funds generated from retiring the carbon credits are used on projects to reduce carbon consumption in the UK. Best practice: Invest resources in terms of skills, time and money. Sustainability Perspectives 45 Objective: Enhance brands or products by addressing consumers’ ethical and environmental concerns “ It would be far better if companies used the money they have allocated for offsetting in a social entrepreneurship programme- using their own skills and expertise to address the problem by investing in programmes to change behaviour of consumers or employees.” Diana Verde Nieto, CEO and founder of Clownfish Organisations can use their skills and expertise to invest in product development and educational communications campaigns to encourage behavioural change by consumers. These changes may have far greater impact on energy efficiency than anything the product or service could achieve on its own. Ocado Supermarket Ocado, a UK online supermarket, has launched a new initiative to drive down consumer food waste. Up to 30% of food bought in the UK ends up in the bin, an inefficiency that results in higher carbon emissions relating to the production and transportation of wasted food. The unique business model means that consumers can be told at the checkout exactly how long groceries will stay fresh. Expiry dates will be printed on receipts so that meals can be planned to make sure that nothing goes to waste. Food waste awareness week combined an educational advertising campaign with online recipe suggestions for leftover food. Additional measures to reduce emissions include biodegradable carrier bags that can be returned to delivery drivers for recycling to new bags, and use of ‘Combined Heat and Power’ energy sources in distribution centres [28]. Best practice: Invest in activities to reduce emissions generated outside the direct scope of the company’s operations by the products or services it provides. 28. www.ocado.com Sustainability Perspectives 46 Objective: Risk mitigation: anticipation of the introduction of legislation, avoiding negative press Some companies have invested in credits on a voluntary basis in order to purchase them at a lower price. This is in anticipation of the introduction of legislation requiring them to participate in compliance schemes. In the UK, the legislation goes into effect in 2010 (see Carbon Reduction Commitment page 23) specifically excludes offsets as a means of achieving the target, so this strategy may not mitigate risks as expected. Best practice: Invest in internal emissions reduction schemes. Sustainability Perspectives 47 Final Thoughts Companies that respond to the real scale of action required to mitigate climate change are those that will be seen as future leaders. They will also be competitively positioned for long-term success. Where does offsetting fit in? In principle offsetting can deliver emissions reductions at the lowest cost to society. High quality projects can deliver environmental benefits. However, the misapplication of offsetting by organisations as a way to justify current business practises, combined with press reports on some poorly managed projects has meant that offsetting is viewed with increasing scepticism. The fact remains that buying credits to offset environmental impact is dealing with the consequences, not solving or avoiding them. In order to take real and meaningful action on climate change, an organisation should consider the following: Any action is better than none Carbon information management can seem overwhelming, but organisations can use basic information such as energy bills to make decisions affecting their carbon footprint e.g. using renewable energy, amending travel policies. Once some savings are realised, they can be reinvested to additional carbon reduction programmes. A significant step change in response is required Although a good start, small, incremental improvements are not enough to mitigate the effects of global climate change. To avert the heavy economic impact predicted if significant emission reductions don’t take place, organisations and governments should take direct responsibility for achieving carbon reductions recommended by scientific consensus. Globally, governments are moving to adopt mandatory emission reduction targets that affect more organisations A company that aligns itself with the new low carbon economy will have a competitive advantage over others who are slower to adapt. Carbon management requires looking beyond offsets For an organisation to realise the economic, bottom line benefits conferred on an efficiently operating, low carbon business, it must make changes in operational and business practices. Purchasing voluntary offsets outside the context of a robust carbon management strategy merely creates an additional cost to the business, instead of being used as a tool to deliver business benefits and drive further savings. Sustainability Perspectives 48 Consider offsetting as a last resort, in a considered and proportionate way If purchasing purely to offset emissions, use Gold Standard Credits to ensure that the environmental benefits of the project are realised. If the purpose of offsetting is to further overall corporate or brand objectives, then smaller scale projects can be selected where the investor organisation’s expertise is used to minimise risk. Leverage the skills and resources of the business to drive change Consider using employee skills and expertise to launch social entrepreneurship programmes that will influence behaviour change beyond the boundaries of the organisation. Across all sectors of business, from consumer goods to heavy industry, companies are committing to reduce their emissions beyond mandatory limits. Significantly, their financial results demonstrate that improved efficiency and changing business practises can also bring cost savings, competitive advantage and employee motivation as well as delivering environmental benefits. The approach to carbon management discussed in this document provides a clear direction for organizations to address climate change at the scale required to make a difference, while keeping an eye on the bottom line. Sustainability Perspectives 49 Further reading: What is the Compliance Carbon Market? 1. Carbon 2008 Post 2012 is now. Point Carbon report March 2008 2. State and trends of the carbon market, May 2008, World Bank What is the Voluntary Carbon Market? 1. State of the Voluntary Carbon Market 2008, New Carbon Finance and Ecosystem Marketplace May 2008 2. Making the Voluntary Carbon Market work for the poor. Forum for the Future, July 2008 3. Making sense of the Voluntary Carbon Markets, a comparison of Carbon Offset standards, WWF Feb 2008 Carbon management best practice 1. Getting to Zero- defining corporate carbon neutrality, Forum for the Future, 2008 2. Making Advances in Carbon Management. Best practise from Carbon Information Leaders. Carbon Disclosure Project and IBM. 3. The Carbon Trust three stage approach to developing a robust offsetting strategy Sustainability Perspectives 50 Glossary Additionality CER JI This principle dictates that emission reductions are Certified Emission Reduction. Joint Implementation. above those which would have occurred through A credit generated under the Clean Development A Kyoto Protocol initiative under which projects are business as usual i.e. additional to what would Mechanism (CDM) for the reduction of emissions established jointly between developed markets have occurred without the carbon credit incentive of greenhouse gases equal to one tonne of CO2e. to reduce greenhouse gas emissions generate credits called ERUs.. The credits generated go or investment. CFI to the investor country while the emission allow- Banking and borrowing Carbon Financial Instrument. ances of the host country are reduced by the same The ability to save emission permits issued in Credit generated through the Chicago Climate amount. one year for use in later years (banking), or bring Exchange. Each CFI covers the emission of 100 forward some of a future year’s permit allocation tonnes of CO2. Kyoto Protocol Participating countries agree to reduce carbon for use in the current year (borrowing). CO2e emissions by a set amount between 2008 and Carbon dioxide equivalent 2012. subject to a cap. Allowances are issued up to that Emissions trading Leakage cap, and those organisations emitting less than A market-based system for regulating the emission Activities designed to cut greenhouse gas emis- their quota can sell their excess permits to emitters of greenhouse gases. sions in one area lead to the emissions elsewhere. Cap and trade An emissions trading scheme where emissions are needing to buy extra to meet their quota. ERU Offsets Carbon dioxide equivalent, CO2e Emission Reduction Unit. Credits issued through projects such as the provi- A metric to express greenhouse gas potency rela- A credit generated by the Joint Implementation sion renewable energy to replace fossil fuel energy tive to Carbon Dioxide. Scheme (JI) for the reduction of emissions of which reduce overall emissions. By paying for greenhouse gases equal to one tonne of CO2e. emission reducing activities, individuals and organisations can use the resulting credits to offset Carbon footprint A calculation of the amount of greenhouse gas ETS their own emissions, either voluntarily or under emissions associated with the use of power, Emissions Trading Scheme. the rules of most emissions trading schemes. One offset credit equates to an emission reduction of transport, food and other consumption for an indi- one tonne of CO2. vidual, family or organisation. Expressed in units of EU ETS carbon dioxide equivalent. European Union Emissions Trading Scheme. Carbon neutral EUA Reduced Emissions from Deforestation and A claim that an organisation has no net emissions European Union Allowances. Degradation. of greenhouse gases from all its activities. Credits generated by the EU Emissions Trading REDD Carbon price Scheme. Each allowance carries the right to emit tCO2e, MtCO2e one tonne of carbon dioxide. Tonnes of carbon dioxide equivalent, millions of tonnes of carbon dioxide equivalent. Gases are The economic value placed on the emission of greenhouse gases into the atmosphere. The price GHG equated to Carbon Dioxide potency e.g. one million is designed to create a disincentive for emissions Greenhouse gases include: Carbon dioxide CO2, tonnes of emitted methane, is measured as 23 and incentive to avoid them. Methane CH4, Nitrous oxide N2O, Perfluorocar- million tonnes of CO2-equivalent, or 23 MtCO2e. bons PFCs, Hydrofluorocarbons HFCs, Sulphur CDM hexafuuride SF6, as well as indrect gases such as Clean Development Mechanism. SO2, Nox,CO and NMVOC A Kyoto Protocol initiative under which projects established in developing countries to reduce IPCC greenhouse gas emissions generate credits called Intergovernmental Panel on Climate Change. CERs. The projects include renewable energy gen- An international scientific panel informing the eration, reforestation and clean fuels switching. UNFCCC on the latest scientific evidence on climate change. Sustainability Perspectives 51 Linked by Clownfish is a communications agency dedicated to making sustainability tangible for business. We help brands to: Put sustainability at the heart of their business and build integrity into marketing; creating competitive advantage and engaging consumers. Improve credibility of communications by facilitating strategic partnerships with a wide range of stakeholders including NGO’s and key opinion formers. Make their brand more sustainable, future proof and profitable. We do this through creative strategy underpinned by rigorous research and a deep understanding of sustainability. By taking a holistic approach, grounded in real business needs, we can see the bigger picture; delivering strategies with a truly global perspective and genuine local focus. Clownfish is part of Isobar, the world’s largest digital marketing network. © 2008 Clownfish. All rights reserved AUTHOR Cherry Hirst Senior Strategist - Clownfish PHOTOGRAPHS www.freefoto.com ACKNOWLEDGEMENTS: We would like to acknowledge and appreciate the input and insight provided by the following individuals: Dax Lovegrove, WWF; Greger Flodin, Rabobank; Simon Manley, Converging World; Lila Preston, Generation Investment Management; John Tebbit, Construction Products Association; Tom Slater, DEFRA; Brian Rapose, DEFRA; Nick Rowcliffe, ENDS; Jenny Bird, IPPR; London: 17 -18 Hayward’s Place, London EC1R 0EQ New York: 3 Park Ave., 25th Floor, New York, NY 10016 +44 (0)20 7780 7030 - www.clownfish.co.uk Please consider the environment - Think before you print!
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