Carbon Offsets and the Regulated and Voluntary Carbon Markets.
By Audrey Macleay and Jon Buick
Prepared: February 2008
“Our everyday actions consume energy and produce carbon emissions, for example,
driving a car, heating a home or flying. Offsetting is a way of compensating for the
emissions produced by an equivalent carbon saving” (Defra, 2007)
Introduction
It is commonly accepted today that increasing concentrations of the gases which are
believed to increase the incidence of global warming effects, or greenhouse gases
(GHGs) in the atmosphere since the Industrial Revolutions is leading to global
warming and climate change. With the publication of the Intergovernmental Panel on
Climate Change’s fourth report at the beginning of this month coming to the
conclusion that it is “very likely”, or over 90% certain that human actions are
responisble for this change, the scientific evidence for this claim is continuing to
mount.(IPCC 2007) How to tackle climate change is one of the biggest questions of
the current age.
Carbon Offsetting and becoming Carbon Neutral are phrases which we hear more
and more commonly in the media and are set to be the new environmental buzzwords of 2007. But what do they really mean? Are they practical solutions to
Climate Change? Or will the attempt to absolve our guilt by paying an extra £10 to
an offsetting company when embarking on a trans-atlantic flight simply stall the
public from taking positive action to tackle climate change?
What is a carbon offset?
When you fly, drive your car or heat your home you consume energy, the production
of which leads to emissions of greenhouse gases. A carbon offset is an equivalent
emissions reduction which takes place elsewhere that is used to balance out the
overall volume of greenhouse gases in the atmosphere. Emissions reductions are
normally generated through projects that reduce emissions beyond the level that
would have occurred without under a ‘business as usual’ scenario.
1. Overview of the Carbon Market
Background
In 1992 the United Nations Framework Convention on Climate Change (UNFCCC)
recognised that international action was needed to reduce greenhouse gas
emissions, so as to avoid catastrophic runaway climate change. After two and a half
years of intense negotiations, the Kyoto Protocol was adopted at the third
Conference of the Parties to the UNFCCC (COP 3) in Kyoto, Japan, on 11 December
1997. It recognised the “common but differentiated” responsibilities that countries
had to reduce their emissions. The Protocol provided industrialized countries with
targets to reduce emissions during the period 2008-2012. In 2005 these targets
became legally binding on countries that had ratified the Protocol. Developed
countries which have targets under Kyoto are referred to as Annex 1 countries.
There are six greenhouse gases which are regulated under the Kyoto protocol. For
reporting purposes these are all give a global warming potential equivalent to one
tonne of CO2, called CO2e
[insert table of equivalents]
Emissions Trading
Under the Kyoto protocol it is not necessary for all the emissions reductions to be
achieved at home i.e. by fuel switching (e.g. coal to gas-fired energy generation) or
through energy efficiency programmes. The protocol allows countries which have
exceeded their targets on emissions reductions to sell their remaining allowances to
other countries. This form of emissions trading is solely a government-togovernment activity and the unit of trade is the Assigned Amount Unit (AAU). This is
the back-bone of the carbon market, so called as carbon dioxide is the most common
greenhouse gas. All other greenhouse gases are expressed as CO 2e (carbon dioxide
equivalents).
Countries not able to meet their commitments will be able to "buy" compliance but
the price may be steep. If there is low availability of excess credits then the cost is
likely to be high. The rationale is therefore that governments will be under more
pressure to invest in energy efficiency and renewable energy development.
So, in essence the Kyoto protocol embodies a “cap-and-trade” system whereby on
average, the Annex 1 countries will reduce their emissions by 5.2% below their 1990
baseline in the 2008-2012 crediting period.
Clean Development Mechanism and Joint Implementation
There is yet another way in which countries can achieve compliance with Kyoto and
that is by making investments in clean technology projects overseas and claiming
the emissions reductions against their own targets.
Emissions reductions projects are developed in non-Annex 1 countries and these
credits are sold to the Annex 1 countries to count against their reductions targets.
This is called the Clean Development Mechanism (CDM) and CDM credits are called
Certified Emissions Reductions (CERs), whereby 1 CER is equivalent to 1 metric
tonne of CO2e. Where this happens between two Annex 1 countries it is called Joint
Implementation (JI). Any JI project which takes place must not be counted against
the host countries’ emissions reduction targets. JI credits are called Emission
Reductions Units (ERUs).
Creating credits in this way allows for emissions reductions to be achieved at a much
lower cost. This was thought to be especially important for countries which already
had very good performances in respect to the use of renewable energy and energy
efficiency programmes such as Sweden.
Registration of projects to the CDM is an incredibly lengthy and bureaucratic process
and has lead to a slow development of projects under this scheme. However, things
are beginning to settle and many more projects are being registered.
Types of projects typically registered to the CDM initially were things such as HFC-23
destruction in production of xxx, where high volumes of credits could be created and
traded at low set-up cost.
The CDM fell under some criticism when it was suggested that some projects
registered under it, namely those involved in HFC-23 destruction, were not truly
additional (for an explanation of additionality see below). It was suggested that
operations were set up solely to create the HFC-23, so that they could set up
projects to destroy it, and then be able to sell huge volumes of CERs. Regulations
were considerably tightened following this (NewScientist 2007).
European Union Emissions Trading Scheme
European Union members have assigned a proportion of their targets to industry and
electricity generators within their countries. Emissions are divided amongst
industries and companies through each country’s National Allocation Plan. These
companies can trade their allowances (EUAs) amongst each other through the
European Union Emissions Trading Scheme (EUETS).
The EUETS is a cap and trade scheme – ie the total amount of allowances is fixed.
This means that if industrial output increases (or emissions rise) the market price of
allowances will rise due to increased demand and reduced supply.
Linking EUETS & CDM
Companies will be allowed to use CERs and ERUs credits to help achieve their targets
in the EUETS. There will be some limits put on the amount of CERs that can be used
to meet targets but nevertheless, it is expected that demand will outstrip supply.
Furthermore the actual computer system to be used for bringing CERs into the
EUETS has not been established yet – which is leading to market uncertainty.
Figure 1. Graph to show the growth of project based carbon
emissions reduction transactions (Capoor & Ambrosi 2007)
2 The Voluntary Carbon Market
The voluntary carbon market, although tiny in comparison, has many parallels with
the compliance market. It is primarily aimed at individuals, businesses and
organisations which do not have binding targets under the Kyoto protocol.
In order to offset carbon emissions a company or an individual can purchase
emissions reductions credits. These credits can take a number of forms and are
generated by projects which either reduce the amount of greenhouse gases (GHGs)
from entering the atmosphere or attempt to sequester GHGs which are already
present in the atmosphere. In order to qualify as an offset however, the reductions
need to be considered as additional to what would have happened in a business-asusual situation. This is known as ‘additionality’. (Defra 2007) It is this additionality
which is crucial in determining a good-quality offset.
Individuals can offset their personal emissions which result from lighting and heating
their homes and from transport. Most individuals who currently offset their emissions
do so through an independent offsetting company or alongside a product or service
at the point of sale, for example, when purchasing an airline flight, if this is offered
as an additional charge on the price of the flight.
Businesses are becoming more interested in becoming carbon neutral or to offer
carbon neutral products for a number of reasons such as wishing to improve their
Corporate and Social Responsibility standing or improve their brand image.
The voluntary market is characterized by much smaller projects than the CDM, and
in general have a stronger sustainable development aspect, leading to additional
improvements over and above emissions reduction, also improving the lives of the
local communities. This is largely due to the non-compliance aspect of the market,
and in order to sell credits to organisations which are under no obligation to buy
credits, it is desirable to have a communicable story to go along with the offset. As
well as forestry projects they can also include energy efficiency projects such as
funding energy efficient lightbulbs in the tourism sector in Jamaica, wind farms in
China and India to efficient cook stoves in Ghana.
One of the most redeeming features of the voluntary market is it’s ability to
innovate. With the CDM being heavily bureaucratic, often it is the voluntary market,
unbound by it’s regulations which drives change and the incorporation of new project
and technology types to become eligible for carbon finance. An example of this is the
work that Adam Harvey of Pioneer Carbon has done in devising a methodology for
calculating the emissions reductions generated by the reduction in use of nonrenewable biomass in cooking stoves. This Voluntary Cooking Stoves Methodology has
been approved by the Gold Standard and much of the work was directly transferred
to the CDM Methodology on Small Scale Cooking. This was a great move forward in
allowing innovative stoves projects to be eligible for carbon finance.
Summary of the carbon markets and credits
The Compliance Market
- allowance based credits – EU ETS, CCX, Kyoto Allowances (Assigned Amount
Units – AAUs)
- project based credits – GS-CDM, CDM, JI
The Voluntary Market
- project based credits – CCX, VCS, GS-VER, VER+
Market composition of the Clean Development Mechanisms (CDM) and the
Voluntary Carbon Market (VCM).
Cerdits traded by project type In the CDM
13
13
6
5
3
2
34
9
2 5
7
1
Project type
other
hydro
wind
biomass
other Renewables
EE + Fuel switch
Agro-frorestry
Coal
Mine
Methane
Land Fill Gas
Animal Waste
HFC
N2O
Percentage
market
13
6
5
3
2
9
1
7
5
2
34
13
of
CDM share of volumes contracted in 2006 (Adapted from Capoor and Ambrosi 2007)
Cerdits traded by project type in the VCM
5 33
20
36
33
Project type
Mixed other
Forestry
Renewable
Industrial Gas
EE
Methane
Percentage
market
3
36
33
20
5
3
of
Transaction by project type in the VCM
2007 (Adapted from Hamiltion et al 2007)
3. Project Principles
Additionality
If projects can demonstrate that they are generating reductions that would not have
happened without interaction with the carbon market then they can be said to be
additional. The concept of additionality is what underpins the concept of offsetting
but “Never has so much been said about a topic by so many, without ever agreeing
on a common vocabulary, and the goals of the conversation.” Dr Mark C Trexler,
presetation at additionality side Event COP – 10 in Buenos Aires (2004)(Texler et al
2006).
The five additionality tests as described by the World Resource Institute (WRI) /
World Business Council for Sustainable Development (WBCSD).





Investment: Finical barriers overcome
Technology: Reduced emissions from technology used
Regulatory: Emissions exceed government regulation
Common Practice: Would not have occurred under ‘business as usual’
Timing: Project did not commence prior to support from carbon investment.
The trade-off with the stringency of additionality testing is that if the requirements
for inclusion are too strict additional projects will fail to gain backing or lost
opportunities. If however additionality testing is too lenient then projects that are not
substantially different form business or additional will qualify for funding giving rise
to “phantom reductions” (Trexler et al 2006).
Double Counting.
CDM projects and voluntary projects which are accredited to the more robust
voluntary market standards can not take place in countries which have targets under
the Kyoto protocol.
This is because any emissions reductions which take place in that country would
already be counted towards their own emissions reductions targets. If those
emissions were then sold again as an offset, they would in fact have been double
counted. Furthermore if the country in which the emissions reduction took place,
exceeded their reduction target then they would actually be able to sell the credits
back on to the open market.
Permanence
Emissions reductions must be permanent to be environmentally beneficial. The issue
of permanence is of concern in bio-sequestration projects as they need long time
scales to incorporate carbon into the biosphere. Companies offering pre-pay
voluntary credits from forestry projects often protect against problems of
permanence by creating extra bio-sequestration capacity to cover any shortfall. It is
therefore not a case of how much CO2 one tree can sequester, as all trees will die
eventually, giving up CO2 back to the atmosphere, but to permanently re-forest an
area of woodland which will self re-generate when it reaches maturity.
Leakage
A standard component of project design is a leakage assessment. Leakage occurs if a
project activity causes displacement so carbon emissions are reduced in the project
area but increase in a different location as a consequence. Leakage is always project
specific and is addressed when required.
Suppressed Demand
In time, we would hope that all communities will be given access to the basic energy
services that many of us already enjoy elsewhere in the world. It makes no economic
or environmental sense to allow this development to happen in a non-sustainable
way. It is much better, and normally much more cost effective, to intercept the path
of development and divert it to a sustainable, low-carbon route, rather than let it
proceed in an unsustainable way.
On this basis many carbon offset projects support renewables and energy efficient
projects in communities that are still at a low level of development. In these cases
the baseline uses a projected increase in emissions over time – using energy data
from elsewhere in the economy as a baseline.
Ex-ante & Ex-post accounting and project vintage
Ex-ante carbon credits are sold before the emissions reductions actually occur, this
reduces the up front payments required but increase the risk as leakage and
problems of permanence may occur. Ex-ante project accounting involves the selling
of carbon credits after the emissions reductions have occurred. Selling carbon credits
after they have occurred ensures delivery of genuine reductions, however the
increased initial cost means that this is not the favoured approach to project funding.
Project vintage refers to the time scale over which the emissions reductions occur.
4. Project types
Renewable energy
Most commonly wind generation, solar, bio-fuels and micro-hydro.
Example: Wind farms in India by The Converging World. Solar energy projects
undertaken in Nigeria by the Solar Electric Light Fund.
Energy efficiency and reduction
Any project that reduces dependence on fossil fuels or bio-fuel demand through
technological improvements, technology transfer and behavioural change.
Examples: Climate Cares treadle pump project in India. Energy Efficient light bulbs
and fuel efficient boilers in India by carbonfootprint.com. Retro fitting of two-stoke
engines in mini-taxis in the Philippines by Carbon Clear.
Energy from waste
The generation of energy from waste. These projects recapture or produce energy
that would not have been utilised.
Examples: Biogas from animal waste in Kenya by Carbon Clear. Conversion of animal
waste to methane by anaerobic digestion by TerraPass in the US.
GHG destruction
The destruction of GHG that would have previously been allowed to enter the
atmosphere. These projects often involve the conversion of highly potent GHG into
less potent gases with a lower global warming potential. Destruction of GHG is most
commonly used under the CDM and sold through brokers and wholesalers to meet
compliance regulation.
Retiring EU ETS credits
These offsets are not project based and rely entirely on the trading and retiring of
EUA’s AAU and ERU.
Examples: EBICo and Gazproms retirement of phase II carbon credits to offset
carbon emissions from domestic gas supply.
Bio-sequestration
The most common association with carbon offsetting is that of bio-sequestration, or
forestry offsets. This is a simple concept to understand. As trees grow they absorb
CO2 and the carbon is essentially fixed within the tree for the lifetime of the tree.
Examples: The Carbon neutral company’s forestry projects in the UK. The Rainforest
restoration projects in Uganda by climate care. The woodland trust carbon offsets.
Cool Earth undertake projects that avoid deforestation but these are not marketed as
carbon offsets but they are linked to a carbon calculator. Other bio sequestration
projects. Tillage and carbon sequestration in soils are very popular approaches to
creating carbon offsets for the CCX and US markets (Bayon 2007).
Geo-sequestration and Carbon capture and storage (CC&S): This type of
approach involves the isolation and geological sequestration of GHG. Long favoured
by the big oil industries because of its ability to deal with emissions at source CC&S
is currently under consideration for inclusion in the regulated market.
Examples: Enhanced oil recovery through CC&S in older US oil wells by Blue Source.
5. Project Standards and Registries
Verification and standards for carbon offsets
The Government has recently published a draft paper of their Code of Best Practice for
Carbon Offsetting for UK consumers. This is a step forward for a largely unregulated,
although more recently, self-regulated market. This will enable offset providers to
become officially accredited and so provide certain guarantees to consumers.
In recent years, many of the major players in the voluntary market have been
attempting to regulate the market and this has led to the emergence of a number of
new standards which attempt assure quality within the vast array of carbon credits
available. The variety of different standards can be somewhat confusing, and the
new Defra code has issued with it a challenge to the market to shape up and get
serious, and reach a consensus for one, uniting standard.
Standards within the Voluntary carbon market
Gold Standard
CDM gold standard.
The Gold Standard is the first independent standard giving advice about best practice
for the developing and auditing of regulated and voluntary carbon reduction projects.
The Gold Standard has been set up by the WWF and endorsed by a large number of
environmental and development NGO’s and has taken input from large range of
carbon market stakeholders. The main motivation for the creation of the GS was that
the CDM screen process did not adequately examine the sustainable development
benefits of projects. The standard is built upon the methodology of the CDM but
includes additional screening test for Additionality, baseline reductions and
sustainable development. The gold standard focuses on renewable energy and
energy efficiency projects and excludes sequestration activities.
VCM gold standard
The gold standard for voluntary projects is based on the same methodologies as
those used in the CDM however the transaction cost are kept down as the projects
do not need to be registered with the CDM Executive Board .
VCS
The Voluntary Carbon Standard has been developed by the IETA and World Economic
Forum and is designed to work alongside other pre-existing standards (eg. Gold
Standard and CCX). The standard aims to provide a quality threshold in the
voluntary market and create Voluntary Carbon Units (VCUs). The methodology is not
only based upon the methodology of the CDM but it is also thought to go beyond it.
VER+ and BlueRegistry
Based on the methodologies of the CDM and JI the VER+ standard is said to be
“streamlined” with Kyoto (Hamilton 2007). It has been developed by TÜV SÜD who
currently work as project verifiers and is designed to work in tandem with the
BlueRegistry. The BlueRegistry aims to manage VER+ credits along with VER’s from
other standards to ensure that double counting dose not occur.
VOS (Voluntary Offset Standard)
Set up by the ECIS (European Carbon Investors Service) and represents more than
10 different banks and includes members such as Morgan Stanley and Barclays and
Climate Change Capital. Focusing mainly on the US and Australian pre-compliance
market the VOS is heavily based on the CDM and JI methodologies. Emissions
reductions achieved through the destruction of industrial GHG (such as HFC-23) are
excluded from inclusion in the VOS.
DEFRA: Code of best practice for carbon offset providers
Defra have just released the UK’s “Code of best practice for carbon offset providers”.
In it the recommend the inclusion of carbon credits compliant with the CDM and the
EU ETS (Defra 2008). These are:
Certified Emissions Reductions (CER’s from CDM)
European Union Allowances (EUA’s from EU ETS)
Emission Reduction Units (ERU from JI)
Defra 2008: Code of best practice for carbon offset providers
Products that meet the UK code of practice will be give a “quality mark” to show that
they comply with UK regulations. Defra acknowledge that carbon offsets are not the
“cure” for global warming. Offset providers are required to educate their customers
about other actions that can be taken to tackle climate change in order to meet the
proposed standard. There will be a UK registry to prevent the double counting.
The Defra code – what it means for the voluntary market
The government is trying to give individuals a quality assurance to the offset
customers through the backing of the Kyoto compliant markets. Credits generated in
the regulated market must undergo a more lengthy and expensive auditing and
verification procedure. The regulated market tends to favors large-scale industrial
projects whilst the VCM allows for more innovative approaches generating emissions
reductions. The exclusion of the VERs for the Defra standard could isolate the
voluntary carbon market and restrict funding for innovative projects. The door
remains open for the future inclusion of VERs in the future pending the unification of
the VCM under a common set of standards.
Friends of the Earth have responded to defra saying the code was of limited
environmental benefit as offset could be used as an alternative direct emissions
reduction. Reporting on this the papers are also covered reporting that the scheme
has been criticized by offset providers (Co-op group and woodland trust) for not
including VER’s (mainly from forestry) but remained impartial (Eccleston 2008 &
Macalister 2008).
5. Carbon offsets in the media
The media has been critical of carbon trading and in particular the VCM in recent
times Carbon trading. It has been proposed that this could be partly due to standard
cycles of reporting in the media (Figure 1), and if this is the case then the media
should be moving towards more balanced reporting on carbon offsets (Hamilton et al
2007). Weather or not this is the will prove to be true of media reporting on carbon
offsets in future is yet to be seen. It is however clear that media coverage about
carbon offsets is of critical importance and continued negative press will inevitably
have consequences for the VCM.
It could however also be argued that recent media
attention could serve to improve consumer confidence
in the VCM by driving standards up and leading to
improved verification and information transfer across
the market.
Whether or not this is the will prove to be true of
media reporting on carbon offsets in future is yet to
be seen. It is however clear that media coverage
about carbon offsets is of critical importance and
continued negative press will inevitably have
consequences for the VCM.
It could however also be argued that recent media
attention could serve to improve consumer confidence
in the VCM by driving standards up and leading to
improved verification and information transfer across
the market.
P ositive press
2.
1.
New
Development /
Concept in the
media
negitive press
3.
4.
ballenced
reporting
Figure 1. Media cycle as described by Hamilton (et al 2007). 1) A new story
undergoes a ‘honeymoon’ period where the benefits and positive aspects are over
hyped. 2) The initial story is no longer news worthy and the negative aspects
become the focus. 3) As public understanding grows reporting becomes more
balanced. 4) A new development arises that the public and press are not aware of
and the cycle continues.
Carbon offset in the media: case study
Climate Cares Ashden Award Winning treadle pump project in Indian provides an
excellent example of carbon offsets in the media. Articles appeared in the Times (The
‘carbon offset’ child labourers) and online forums (Is carbon offsetting just ecoenslavement?). These articles drew heavily on the imagery of child labour where the
poor are made to help “environmentally sensitive holiday makers assuage their guilt
over long-haul flights to dream destinations.” (The Times).
The articles take opposition to climate cares backing of the use of treadle pumps as
an alternative to diesel generator powered pumps. The diesel pumps are however
expensive to hire and run, pump at an unsustainable rate, washing away top soil and
depleting ground water suppliers. Whilst the treadle pump dose require manual
labour to operate it is an entirely appropriate technology for use on rural farms,
reducing cost and increasing crop yields. Climate Cares involvement gives support to
International Development Enterprises India (IDEI) who promote the use of the
treadle pumps. Climate Care simply make the treadle pumps affordable and the
farms choose to use them as an alternative to a
diesel generator.
Figure 2. Indian farmer My
For more on this see:
Pyari using a treadle pump.
The ‘carbon offset’ child labourers. The Times 23 rd
(Photo courtesy of Climate
Sept 2007, carbon-offsetting just eco-enslavement?
Care)
Spiked
online
03rd
Sept
2007.
&
‘Eco-enslavement’: peddling misperceptions? Spiked
online 25th Sept 2007.
6. Arguments against Carbon Offsets
One of the main arguments against the use of carbon offsets as a method of tackling
climate change is that they will be used as alternative to taking direct action to
reduce emissions. The comparison has been drawn carbon offsets and the Chaucer’s
The Pardoner’s Tale and the sale of intelligences by the Catholic Church in the 15 th
and 16th centaury to save wealthy sinners from purgatory (Monbiot 2006 & Smith
2007). This often referred to as ‘indulgence theory’. Critics of carbon offsets claim
the carbon offsets are at best a distraction from emissions reductions and could even
be an excuse to continue with “business as usual”, however there has been little
research into how carbon offsets are being used.
There are those who believe that carbon offsets do little to tackle climate change as
they do not tackle the route causes of climate change, they only treat the symptoms.
The organisation FERN (Forestry and the European Resource Network) has been
highly critical of carbon offset for this reason (FERN 2005).
Carbon offsetting is not a panacea
Carbon offsetting is not going to solve climate change on it’s own. But no mechanism
which we have currently available to us is, and with each scientific report being
released emphasising the increasing urgency of the we need to be doing not just one
thing, but everything we can.
“On the question of principle – it is as if we are all in a lifeboat in the middle of the ocean.
We’ve just discovered the boat has a hole in it. Half the passengers – those who are mostly
responsible for making the hole – refuse to do very much about it. The other half say they
didn’t make the hole so they aren’t going to do anything either.
We have to do two things. Clearly we need to fix the hole – and that is the role for politicians,
technologists, and others aiming to change human behaviour. But we also need to bail out the
boat – else it will sink before the hole is fixed. Offsets are about bailing the boat – they are
critical if we are to stay afloat long enough to sort the problem.”
Mike Mason, Climate Care
Ref: http://www.treehugger.com/files/2008/02/mike_mason_of_c.php
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