With regard to the report published on June 30, 2021 by Carbon Market Watch (CMW), in which he criticises the system of carbon tax of Colombia and says “two large-scale projects that aim to reduce deforestation in the colombian Amazon are exaggerating their impact in millions of tonnes of CO2e”, referencing the project KALIAWIRI REDD+, we would like to clarify the following:
1. THE REPORT MAKES ACCUSATIONS BASED ON PERCEPTIONS, THE MORE UNKNOWN THE REGULATION AND THE CONTEXT OF YOUR APPLICATION. In this it is stated that there are “... in terms of assess with sufficient certainty whether the use of these credits in violation of any regulation,” however throw accusations based on subjective perceptions without taking into account the rule and the context in which it is being applied. Know that the Ministry of Environment and Sustainable Development has been a joint work with ASOCARBONO and all the members of the Carbon Market, to clarify the application of the resolution 1447.
2. USE FALSE ARGUMENTS TO ENSURE THAT THE BASELINE OF THE PROJECT IS INFLATED. In this statement uses three false arguments, which we consider to be subjective, and that do not have the coherence or the colombian regulations or the approved methodologies for estimating emissions reduction.
Declares that the base line of the project is not nested, when the colombian regulations states the following: The establishment of the baseline of the REDD+ project from the NREF consists in the reconstruction methodology in the project area, showing consistency with him. The reconstruction methodology is the calculation of GHG emissions expected in the area of the REDD+ Project with the consistent use of the variables used in the NREF, based on the information provided by the SMByC: the definition of forest, warming potentials
overall, emission factors for forest type, the data history of deforestation for the project area, your method of estimation of emissions and its projection.
The project KALIAWIRI REDD+ has all the documents and data that support the use of variables provided by the SMByC. Or regulation, or in the methodologies of the standards point out that you must use the same rate of deforestation in the area of reference of the NREF, in the projects. So, the statement ignores the fact that the rate of deforestation is for a NREF represent an average of a whole country or region, while for a project estimate is a more specific and accurate and therefore will differ and this is not, as evil says the article, “the project is inflated” because no one can compare the carbon units that are generated in initiatives with different rates of deforestation.
3. IT LIES ON THE VERIFICATION PROCESS. The report notes that: “The validation reports and PDD claim that the baseline of the project was validated prior to the publication of the regulation 1447”, The reports of validation-verification and information supported in RENARE certifies that the project was validated in the year 2020.
4. YOU DO NOT KNOW THE RULE OF THE FULL POTENTIAL OF MITIGATION. In the report mentions that this inflated because “should be limited to the maximum potential mitigation and the provisions of article 40 of the Resolution 1447 of 2018”. To this we reply that all the information on the use of Maximum Potential Mitigation in the project KALIAWIRI is wrong, because the rule only applies to projects that have validated their base-line prior to the issuance of this Resolution, which is not applied to the case of KALIAWIRI since this project was validated in may 2020 as indicated in RENARE and in the validation Report.
5. FALSELY ACCUSES THE ALTERATION OF THE DATA OF THE PROJECT. According to Carbon Market Watch “If the project had been nested in the REDD+ programs to regional and national of Colombia for the period 2016-2019, it is estimated that it would have issued approximately 2 million of bonds least of which was issued in reality” Again accusation that lacks logical sense, first because there is no national programme or regional verified credits from 2017 and also because the hypothetical reconstruction of the base line with which the report compares projects and programmes, non-existent is technically incorrect, because it applies the rate of deforestation in a country to a project, methodology that is not regulated in the colombian legislation or in the methodologies of the approved standards.
6. UNKNOWN BENEFITS TO THE COMMUNITIES. The report notes that the issuance of the certificates of the project resulted in the least collection of the tax and in less international cooperation to combat climate change. These claims ignore the fact that one of the impacts of the carbon tax is the transfer of funding climate direct to the communities that incentivizes the practices of forest conservation of forests at the time that you perform a direct transfer of resources to indigenous communities for the improvement of their quality of life. The article at any time it asks for these benefits that are caused thanks to the figure of the non-levy of tax, which demonstrates clearly the lack of knowledge of the same by the authors of the report. We hope these clarifications can make echo to get a full information in relation to the development of REDD+ projects undertaken in Colombia, from the point of view of the regulatory Colombia. Colombia has shown that is at the forefront and ahead of time compared to its neighboring countries in the System of Monitoring, Reporting and Verification, and also in the National Registry of Emissions Reduction. The impact achieved by these projects in terms of social and environmental is significant, and becomes an engine for the colombian market of carbon will continue to grow and be strengthened. From BIOFIX CONSULTING and support to the seven guards that comprise the project KALIAWIRI REDD+, we call the technical coherence of the report, Carbon Market Watch, which was never consulted and shown by research that desmerita subjectively the environmental integrity of the certification programs and projects in colombia.