Climate and Forests Sign-on Letter
American Lands Alliance, Washington, D.C.
American Lands, 726 7th Street, SE, Washington, D.C. 20003, 202/547-9400, 202/547-9213 fax,
wafcdc@americanlands.org, http://www.americanlands.org
March 22, 2000
Climate and Forests Sign-on Letter for Organizations Please mailto:erinq@teleport.com to sign on, with name, organization, city and state. Thanks
Mr. Roger Ballentine, Deputy Assistant to the President for Environmental Initiatives
March 22, 2000
Dear Mr. Ballentine:
We are writing to express our serious concerns about the U.S. position in the upcoming negotiations to develop land use, land use change, and forestry (LULUCF) rules under the Kyoto Protocol. We are concerned that the United States does not support strong, environmentally sound, land use and forestry rules. Lenient rules could result in a compromised Kyoto Protocol, which would not adequately address the need to reduce carbon emissions from their sources. Furthermore, lenient rules could threaten forest ecosystems and their biodiversity here and overseas by encouraging clearcutting, logging of old growth, conversion of natural forests to plantations, and other harmful logging practices.As you know, the wood products industry, represented by the American Forestry and Paper Association (AF&PA), has been calling for Kyoto rules that support business as usual forestry by awarding credits for activities such as producing wood products and chipping plantation trees for fuel. It is clear that the industry is not primarily concerned with reducing greenhouse gas emissions or maintaining ecological land management standards.We fear that the U.S. position, which seeks to credit the broadest range of forestry activities (including those stated by the AF&PA), could embrace these and other destructive practices. If the Kyoto rules sought by the U.S. credit questionable forestry practices, then more certain steps to reduce greenhouse gasses will be curtailed (such as reducing power plant and industrial emissions, strengthening CAFE standards for cars and trucks, and protecting and restoring native forests). Weak Kyoto forest rules will lead to fewer reductions in greenhouse gas emissions, less effective mitigation of climate change, and greater negative impacts on our forests.
We support strong rules in the Kyoto Protocol and in domestic legislation that will cut carbon emissions and place a high priority on protecting and restoring native forests. Before the discussions of these issues take place in the Australia Ministerial in April, 2000, we ask that the U.S. Administration take a proactive approach to reducing climate change and clarify its position to support the following:
1) Protection of Old Growth ForestsIn order for forest carbon sequestration to most effectively reduce the amount of atmospheric carbon dioxide, Kyoto land use rules must place the highest priority on protecting existing old growth and native late successional forests. Numerous scientists, such as Drs. Jerry Franklin and Mark Harmon, have found that the level of carbon storage increases with forest age. Conserving and restoring native old growth forest ecosystems is thus much more beneficial than logging mature stands and planting younger trees. Logging older forests releases substantial amounts of carbon that has been stored over hundreds of years. Younger replacement forests do not quickly sequester this carbon; most of it is released into the atmosphere. Besides sequestering massive amounts of carbon, old growth forests provide clean water and vital habitats for threatened and endangered species.2) Accounting for Harvested Timber as a 100% Carbon Emission
The U.S. should support the IPCC (Intergovernmental Panel on Climate Change) Guidelines on harvesting of timber, that recommend assuming that "all carbon in biomass harvested is oxidized in the removal year", that is, that the carbon in trees is considered to be 100% emitted at the time of harvest. International carbon sequestration accounting systems cannot adequately track short term sequestration in wood and paper products.3) Forest Restoration and Long>Rotation Timber ManagementRestoring degraded forests and moving to long rotations (e.g. 140 years) in privately>owned managed forests will benefit the forest ecosystems, the public, the climate, and timber production. We support using restoration and long rotations to greatly increase both the level of carbon sequestration and the quality of forest ecosystems on land currently under industrial timber management.4) Accurate and Symmetrical Accounting Rules
International rules are needed so that accounting and crediting for carbon sequestration projects are responsible, comprehensive and accurate. The rules must address, but not be limited to:
accurate and symmetrical accounting of carbon credits and debits; additionality; permanence; leakage; and the full life cycle of projects. Otherwise, Kyoto rules could foster increased logging of old growth forests, continued poor management of national forests, and conversion of other ecosystems to plantations. Please refer to the enclosed paper for details on the specific standards that should be adopted.5) Safeguards Against Plantations, Irresponsible Biomass Fuel Production, and Genetically Modified Trees
Land use change and forestry activities must not degrade, destroy, or create risks for existing native ecosystems. While production of biomass fuels can be appropriate in some situations, the conversion of native ecosystems into plantations for biomass production or for other purposes should not be encouraged or allowed under Kyoto rules. Plantations store relatively low amounts of carbon, fail to provide necessary wildlife habitat, and typically depend on short logging rotations and on chemicals that adversely impact biodiversity, water quality and soils. At present, the U.S. should oppose the use of genetically engineered trees in any Kyoto activities or projects because of the significant environmental risks associated with their use; among other things, the modified trees could disperse into native forests and harm other species.
6) Strong International Environmental Standards for All Forest Projects and Activities
Strong, environmental standards are absolutely necessary within the Kyoto Protocol for all forest projects and activities to protect environmental values such as native biodiversity and natural ecological processes. The enclosed paper provides a detailed explanation of appropriate standards.
Looking at the U.S. submissions on the Protocol, we can find no support for environmental standards, no support for criteria for sustainable development, and no support for consistency with other international environmental treaties.
Land use changes, including logging, account for up to 20 percent of annual carbon dioxide emissions. Over the past 150 years, forest conversion has been responsible for an estimated 30 percent of the excess carbon present in the atmosphere. But thankfully, the U.S. public overwhelmingly supports forest protection and will respond positively to an Administration that implements the Kyoto Protocol, while safeguarding the Ancient Forests, roadless areas, and other special places that people want to enjoy and leave for their children and grandchildren.
Business as usual forestry threatens our national and global forests. An analysis by the World Resources Institute suggests that four-fifths of the world's original forest cover has either been lost or significantly degraded by human activity. Every year another 16 million additional hectares are logged and forever lost to future generations of wildlife and people. Here in the U.S., forest health is critical to the survival of half of our endangered species.We urge you to make clear that the U.S. will work for Kyoto rules that do not credit business as usual forestry, but do protect and restore native forests and insure that the benefits of these and other natural ecosystems are undiminished for our generation and all generations to come.
Sincerely,