Submission to the UNFCCC on REDD and LULUCF - 5 February 2009

SUMMARY

1. Natural Ecosystems

• An overarching policy that has the protection of primary forests and other natural ecosystems (including peatlands) as the highest priority must be adopted.
• The recovery or restoration of forest and other natural ecosystems, including peatlands, must also be ensured.
• Comprehensive LULUCF emissions and removals must be recognized, measured, and accounted. This includes wetlands and peatland soils, deforestation and forest degradation.
• Any REDD mechanism must be focused on the reduction of gross emissions from forest, wetland and peatland degradation (including deforestation).
• Current definitional and monitoring deficiencies and perverse LULUCF rules must be tackled.
• The carbon in natural ecosystems is resilient and therefore biodiversity conservation is a core benefit rather than a co-benefit.

 2. Indigenous Peoples and Local Communities

• REDD must respect and promote the rights of indigenous peoples and local communities, and must not adversely affect their rights and benefits pursuant to other international instruments, treaties, agreements or recommendations.

 3. Good Governance

• REDD must be designed to provide strong incentives for building good governance of forests at national level, including genuine multi-stakeholder engagement, good fiscal governance, participatory law reform and improved forest law enforcement.

 4. Compliance

• REDD must include provisions to measure levels of compliance through robust mechanisms for monitoring, reporting and verification incorporating independent third party review, and to

 5. Financial Incentives

• Reliable, adequate, transparent and long term funding for REDD must be made available by
• Annex I countries, in addition to their official development assistance (ODA) commitments.
• Annex 1 countries cannot use REDD as an opportunity to avoid making deep and real cuts to domestic emissions.
• Independent and well governed national trust funds should be established to enable the equitable distribution of benefits, like funds and services, directly to local communities and indigenous peoples.
• In many countries, participatory legal reviews to clarify tenure and access rights will be necessary before funds from REDD can or should be distributed.

 6. Demand-side Management

• Leadership is required from developed countries to apply demand-side management to focus on reducing demand for, and trade in, forest products (especially those produced unsustainably or in contravention of national and international law), through policies in their own countries as well as support for relevant policies and measures in developing countries.
• As a baseline, Annex I countries should implement prohibitions on trade in illegally sourced wood products, with credible sanctions for non-compliance.