The other side of green? Carbon Market Watch report is technically and legally wrong
* KALIAWIRI REDD + Project
Regarding the report published on June 30, 2021 by Carbon Market Watch (CMW), in which it criticizes Colombia's carbon tax system and points out “two large-scale projects that aim to reduce deforestation in the Colombian Amazon are exaggerating its impact in millions of tons of CO2e ”, referencing the KALIAWIRI REDD + project, we allow ourselves to clarify the following:
THE REPORT MAKES ACCUSATIONS BASED ON PERCEPTIONS, IN ADDITION, IT DOES NOT KNOW THE REGULATION AND THE CONTEXT OF THEIR APPLICATION.
In this, it is indicated that they are not "... in a position to assess with sufficient certainty whether the use of these credits violates any regulation", however they launch accusations based on subjective perceptions without taking into account the norm and the context in which the it has been applied.
USE FALSE ARGUMENTS TO ENSURE THAT THE PROJECT BASELINE IS INFLATED. In this statement he uses three false arguments which we consider subjective, and which are inconsistent neither in the Colombian regulations nor in the approved emission reduction estimation methodologies. Declares that the baseline of the project is not nested, when the Colombian regulation establishes the following: The establishment of the baseline of the REDD + project from the NREF consists of the methodological reconstruction in the project area, demonstrating coherence with it. The methodological reconstruction is the calculation of GHG emissions expected in the REDD + Project area with the consistent use of the variables used in the NREF, based on the information provided by the SMByC: the definition of forest, global warming potentials, factors emissions by forest type, the history of deforestation data for the project area, its emission estimation method and its projection. The KALIAWIRI REDD + project has all the documents and data that support the use of the variables provided by the SMByC. Neither in the regulation nor in the methodologies of the standards indicate that the same deforestation rate of the reference area of the NREF should be used in the projects. Thus, the statement ignores the fact that deforestation rates for a FREL represent an average for an entire country or region, while for a project the estimate is more specific and precise and therefore they will differ and not because of this. , as the article wrongly states, “the project is inflated” since no one can compare the carbon units generated in initiatives with different deforestation rates.
LIE ABOUT THE VALIDATION AND VERIFICATION PROCESS. The report notes that: "The validation and PDD reports state that the project baseline was validated before regulation 1447 was published." The validation-verification reports and the information supported by RENARE prove that the project was validated in 2020.
UNKNOWN THE RULE OF MAXIMUM MITIGATION POTENTIAL. The report mentions that the results of the project are inflated because "it should have been limited to the maximum mitigation potential and the provisions of Article 40 of Resolution 1447 of 2018". Given this, we respond that all the information on the use of Maximum Mitigation Potential in the KALIAWIRI project is erroneous, since this rule only applies to projects that have validated their baseline before the issuance of this Resolution, that is, it does not apply to the case of KALIAWIRI since this project was validated in May 2020 as indicated in RENARE and in the Validation Report.
FALSE ACCUSES THE ALTERATION OF THE PROJECT DATA According to Carbon Market Watch, "If the project had been nested in Colombia's national and regional REDD + programs for the 2016-2019 period, it is estimated that it would have issued some 2 million fewer bonds than it actually issued." Once again, an accusation is raised that lacks logical sense, firstly because there is no national or regional program with verified credits since 2017 and also because the hypothetical reconstruction of the baseline with which the report compares non-existent projects and programs is technically incorrect, since that applies the deforestation rate of a country to a project, a methodology that is not regulated in Colombian legislation or in the methodologies of the approved standards.
IT DOES NOT KNOW THE BENEFITS TO THE COMMUNITIES. The report indicates that the issuance of the project certificates resulted in less tax collection and less international cooperation to combat climate change. These statements ignore the fact that precisely one of the impacts of the carbon tax is the transfer of direct climate finance to communities that encourages forest conservation practices in forests while direct transfers of resources are made to indigenous communities for improvement. of their quality of life. The article at no time inquires about these benefits that are caused thanks to the figure of the non-causation of the tax, which clearly shows the ignorance of the same by the authors of the report.
We hope these clarifications can echo to have complete information in relation to the development of REDD + projects that are being carried out, from the point of view of regulation in Colombia.
The country has shown that it is at the forefront and ahead of its neighboring countries in the Monitoring, Reporting and Verification System and also in the National Emissions Reduction Registry. The impact achieved by these projects in social and environmental matters is significant, and it becomes an engine for the Colombian carbon market to continue to grow and strengthen.
From BIOFIX CONSULTORÍA and in support of the seven reservations that comprise the KALIAWIRI REDD + project, we call for the technical coherence of the Carbon Market Watch report, which was never consulted and shows an investigation that subjectively undermines the environmental integrity of the programs certification and Colombian projects.