ࡱ> DFC 1bjbj .>jj-l*******>>]w bdddddd$  *]] ** **b b < 9 **b 4>P .b06, ^b >>****SSC-NM005- Thermal energy from plant oil for the user of cooking stoves Based on an assessment of the proposed small scale methodology and its application in sections A to C of the draft CDM-SSC-PDD, provide your comments to the proposed new small scale methodology. Please indicate the sections or issues to which your comments refer. We have serious concerns about the proposed thermal energy from plant oil for the user of cooking stoves methodology. Our concerns relate to leakage, (emissions from indirect land use change), assessments of greenhouse gas emissions from land use change other than deforestation, the assessment of nitrous oxide emissions, omission of some greenhouse gas emissions linked to plant oil production, and the assessment of competition with edible oil in local markets. We have further concerns about claims made in the project application for Plant Oil Stoves Protos, Bogor, Indonesia. Leakage/indirect land use change: The proposed methodology states: New plantations must not through indirect impacts, cause deforestation, and must not be on peat land where there are CO2 emissions post-drainage. There are no proposals as to how indirect impacts would be effectively monitored. Two recent peer-reviewed studies ( Use of U.S. Croplands for Biofuels Increases Greenhouse Gases Through Emissions from Land-Use Change, T Searchinger et al, 29th February 2008, Science,  HYPERLINK "http://www.sciencemag.org/cgi/content/abstract/1151861" http://www.sciencemag.org/cgi/content/abstract/1151861 and Land Clearing and the Biofuel Carbon Debt, J Farione at al, 29th February 2008, Science,  HYPERLINK "http://www.sciencemag.org/cgi/content/abstract/1152747" http://www.sciencemag.org/cgi/content/abstract/1152747 ) calculate that biofuel production will always result in land use change, unless food consumption was reduced. Higher commodity prices from the higher demand commonly drive this indirect land use change. Wecannot see how this can be monitored on a project basis: The increased plant oil demand will inevitably push up vegetable oil prices and we cannot see how indirect land use change can be avoided. In Indonesia, where the specific project application is based, the government are supporting a large-scale oil palm expansion programme to meet the growing bioenergy demand, particularly in Kalimantan, Sumatra and West Papua and the links between rainforest destruction and palm oil expansion are well-documented (see, for example The Last Stand of the Orangutan, UNEP, 2007,  HYPERLINK "http://www.unep-wcmc.org/resources/PDFs/LastStand/orangutanreport_1to11.pdf" http://www.unep-wcmc.org/resources/PDFs/LastStand/orangutanreport_1to11.pdf ). Searchinger et al state in their study: By excluding emissions from land use change, most previous accountings were one-sided because they counted the carbon benefits of using land for biofuels but not the carbon costs the carbon storage and sequestration sacrificed by diverting land from its existing uses. Although leakage is referred to, we believe that the methodology does not allow for an accurate assessment of the carbon cost of plant oil production. Assessment of land-use change emissions: We are concerned that only greenhouse gas emissions from deforestation and peatlands will be considered, not those from the conversion of other ecosystems, including grasslands. The study by Fargione et al suggests that conversion of temperate grasslands (US central grasslands, for example) results in the emission of around 134 kg of CO2 per hectare from the loss of soil carbon and carbon in vegetation. Converting abandoned cropland (in the US, for example) to biofuel production results in the emission of around 69 kg of CO2 per hectare. Those very considerable land-use change emissions are ignored in the proposed CDM methodology. This means that the full greenhouse gas emissions linked to plant oil production are not assessed. Assessment of nitrous oxide emissions: According to the proposed methodology, nitrous oxide emissions linked to fertiliser use will be assessed as 0.01 ton of N2O-N per ton of N input. Emissions linked to fertiliser production are to be ignored. The IPCC Guidelines for National Greenhouse Gas Inventories 2006 state that, in addition to the 0.01 figure, higher figures should be used for organic, nutrient rich soil and, furthermore, indirect N2O emissions should be calculated, both from the volatisation of N as NH3 and NOx, and from nitrate leaching and runoff. The proposed methodology thus ignores at least half of the total nitrous oxide emissions from each project involving nitrate fertiliser use or soybeans. Furthermore, a recent study by Paul Crutzen et al (N2O release from agro-biofuel production negates global warming reduction by replacing fossil fuels, P Crutzen et al, Atmos. Chem. Phys. Discuss., 7, 11191-11205, 2007,  HYPERLINK "http://www.atmos-chem-phys-discuss.net/7/11191/2007/acpd-7-11191-2007.html" http://www.atmos-chem-phys-discuss.net/7/11191/2007/acpd-7-11191-2007.html ) suggests that the IPCC figures for in direct nitrous oxide emissions themselves may be a serious underestimate. Indirect N2O emissions or emissions linked to fertiliser production should not be ignored. Given the current scientific uncertainty, we believe that the CDM Board should be extremely cautious about approving methodologies involving bioenergy linked to nitrate fertiliser use. Other greenhouse gas emissions linked to plant oil production Transport emissions linked to plant oil projects (from plantation to end-user) have not been considered. Carbon dioxide emissions linked to fertiliser use have been omitted. The 2006 IPCC guidelines state that carbon dioxide emissions linked to the use of fertilisers, including lime and urea should be calculated ( HYPERLINK "http://www.ipcc-nggip.iges.or.jp/public/2006gl/pdf/4_Volume4/V4_11_Ch11_N2O&CO2.pdf" http://www.ipcc-nggip.iges.or.jp/public/2006gl/pdf/4_Volume4/V4_11_Ch11_N2O&CO2.pdf). Competition with edible oils in local markets: The proposed methodology states that, for social reasons project plant oil consumption should not compete with edible oil on the local markets. There must be a surplus of at least 25%, taking account of the project activity. Otherwise, additional plant oil would need to be produced. This means that, in the absence of a surplus of edible oil in local markets, new plantations will need to be developed. We believe that local assessments of edible oil demand and supply cannot prevent serious impacts on peoples food security and nutrition. Global vegetable oil prices have risen steeply in the past two years, partly due to the growing use of vegetable oils for bioenergy. They are now at record levels. The United Nations Food and Agriculture Organisation states: Current forecasts suggest an unprecedented fall in global oilseed production, mostly caused by a shift of plantings from soybean to maize in northern hemisphere countries. Meanwhile, global utilization of oilseed products is expected to keep expanding. Vegetable oils face growing demand, including from the biofuel industry, while rising consumption of livestock products and record feed grain prices are stimulating demand for oilmeals. (FAO Food Outlook, November 2007;  HYPERLINK "http://www.fao.org/docrep/010/ah876e/ah876e01.htm" http://www.fao.org/docrep/010/ah876e/ah876e01.htm). In most countries, global vegetable oil prices directly impact on local prices. In Indonesia, for example, where the Protos project is based, high palm oil prices already force poorer households to re-use waste cooking oil, sometimes with chemical additives, because they can no longer afford to buy virgin vegetable oil (see: Indonesia_ Agrofuel from oil palm the poor pay with higher edible oil prices, Rivani Noor,  HYPERLINK "http://www.wrm.org.uy/bulletin/120/viewpoint.html#Indonesia" http://www.wrm.org.uy/bulletin/120/viewpoint.html#Indonesia ). This has serious health implications. Reduced domestic demand for edible oil can simply reflect high prices putting staple foods out of the reach of poor people. As the International Food and Policy Research Institute have confirmed, high food prices directly result in less access to food and more malnutrition: Cuts will likely be made to food expenditure, exacerbating diet quality and micronutrient malnutrition (When food makes fuel: the promises and challenges of biofuels, Joachim von Brown, IFPRI,  HYPERLINK "http://www.ifpri.org/pubs/speeches/vonbraun/2007jvbcrawfordkeynote.pdf" http://www.ifpri.org/pubs/speeches/vonbraun/2007jvbcrawfordkeynote.pdf ). We therefore believe that, in the context of high and rising vegetable oil prices, local supply and demand assessments cannot provide any safeguards against plant oil use for bioenergy reducing peoples access to food and increasing malnutrition and health impacts from the unsafe use of waste cooking oil for food. If impacts on food security were adequately assessed, by a revised however, this would require further land-use change, with serious implications for greenhouse gas emissions, other social impacts (including land rights) and deforestation. Additional concerns regarding the project application to which the proposed methodology relates: We have looked at the project application Fuel Switch in Household Energy Use Implementation of Plant Oil Stove Protos, Bogor, Indonesia. In the application it is stated that the plantation is certified with the blue certificate (since 2004) of the Indonesian Environmental Ministry. Hence, the plantation follows social and ecological standards. Oil plants are cultivated and harvested in a sustainable environmental friendly way. Plantation labourers are working according to social standards (regarding salary, working time and labour law according to Indonesian law). The plant oil in question will initially be palm oil from a plantation owned by PT Congong Garut in West Java. Although the RSPO has agreed principles and criteria for certifying sustainable palm oil, a verification system is still being developed and no palm oil has been certified so far. The scheme to which the project application refers is the PROPER scheme set up by the Indonesian Ministry for the Environment. This is not a certification scheme, but merely a government checklist confirming that certain legal obligations have been fulfilled. The actual data have not been published and are not open to public scrutiny. In order for a company to get a blue rating certain legal obligations on air and water pollution have to be fulfilled. Social standards are not addressed and as far as we are aware land-use change is not being monitored either through this scheme. Contrary to provisions in the proposed methodology, there is no indication that West Java has a surplus of edible oil. Given that very little palm oil is produced on Java, which has a population of over 120 million people, we cannot see how a surplus could exist in local markets. Accordingly, this project should not actually qualify under the proposed methodology. New palm oil production elsewhere would be required and indeed is likely to be the indirect impact of such a project yet there are no provisions for monitoring indirect land-use change and relevant greenhouse gas emissions from this. Comments by: Almuth Ernsting, Biofuelwatch,  HYPERLINK "mailto:info@biofuelwatch.org.uk" info@biofuelwatch.org.uk Marianne Klute, Watch Indonesia! ,  HYPERLINK "mailto:watchindonesia@snafu.de" watchindonesia@snafu.de IJSTW q s O Q j k STUzźŰźšźŗŒw0J5H*OJQJ0J5OJQJ5 5B*ph B*phjU^JjiU^J0J^JjU^J jU^JH*^J^J^Jo(]5B*]ph B*]ph6] 56]CJOJPJ^JaJ5CJOJPJQJ^JaJ-HIJST{|yzno7$8$H$1 >?no^MNO !!2!3!"")#*#+#f#g#m%n%%%% & &?(չձ{j Ujb Uj UjHU jU] B*]ph5B*]ph B*ph0JjU&j0JB*CJOJQJUaJph0JB*CJOJQJaJph0J5B*OJQJph0J5OJQJ 0JOJQJ0uv!!&&?(@(((^._.000081117$8$H$?(@(((V)00001115161[1\11111111 B*phj PJU^J 0JPJ^Jj PJU^JjPJU^J 5PJ^JPJ^J B*]ph5B*]ph^J,1h. 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