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Appendix ‘B’
: GULU CARBON COMPENSATION SCHEME
Comments on Draft Project Proposals
by
The Lancashire-Gulu Local Agenda 21 Link
and
Lancashire County Council
February 2008
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1
Introduction
This note sets out the response of the Lancashire-Gulu Local Agenda 21 Link (LL)
and Lancashire County Council (LCC) to a detailed set of project proposals, prepared
for inclusion in the carbon compensation scheme for Gulu (GCCS). The proposals
were submitted jointly by the Gulu-Lancashire Local Agenda 21 Link Association (GL)
and Gulu Municipal Council (GMC).
The proposals identify six projects (four main projects, one of which is divided into
three sub-projects), which are contained in the report ‘Gulu Carbon Compensation
Draft Project Proposal’, and an accompanying technical appendix ‘Activity Work Plan
and Budget’.
A third report, explaining how each project will be monitored and evaluated, is
awaited. Comments will be made on this report in due course.
Material in this note is collated from discussions held at three meetings in February
by a group of representatives appointed for the purpose by LL and LCC. The LL
representatives were Board Trustees Derek Taylor (Link Chair), Frances Maguire
(Link Vice-Chair) and Simon Kularatne. The LCC representatives were County
Councillor Matthew Tomlinson (Chair of Cabinet Committee on Climate Change),
County Councillor Jean Yates (member of Cabinet Committee on Climate Change)
and Andrew Mullaney (Head of Policy Development).
The group’s comments are organized into two sections. The first section contains
brief, general observations on the overall package of proposals, while the second
raises some detailed issues for clarification on each individual project, raised by
individual group members. We are confident that these latter can be easily clarified
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and that they will not be an obstacle to the implementation of the programme as a
whole.
Contact:
Derek Taylor
Chairman of Lancashire-Gulu Local Agenda 21 Link
Lancashire Coordinator for GCCS
Tel: + 41-1772-731302/735972
Email: [email protected]
GENERAL COMMENTS
We congratulate GL and GMC for putting together an excellent, well-thought out set
of proposals, and for presenting them in such a consistent, and highly professional
manner. In particular, we acknowledge the enormous amount of work that has gone
into producing this comprehensive piece of work in such a short space of time. Both
LL and LCC look forward to working in partnership with GL and GMC to further
develop the projects, and to help ensure that they are implemented successfully.
Taken together, the projects exceed the expectations we had as to what a carbon
compensation scheme might comprise. The GCCS forms a package that we think
could become a model for similar community-based collaborations on climate
change. We fully intend, with our Gulu partners, to use the proposals to promote and
publicize the initiative, especially to raise awareness about the issues involved, and
to generate additional funds and resources so that the programme can expand.
As presented, all six projects, despite their small-scale nature, will be of real value in
helping the people of Gulu to better adapt to the impacts of climate change. But they
will also bring considerable added value and benefits in terms of improving the
environment, boosting the economy and increasing opportunities for social cohesion,
at a time when the Gulu district is emerging from two decades of armed conflict. This
stimulus that the overall programme will give to the reconstruction process is
something we are especially pleased about.
In particular, we applaud the fact that the projects in the GCCS:

Address pragmatically, and in traditionally relevant ways, how people in Gulu
might adapt to climate change, or might be able to mitigate the impacts that
climate change might have on their lives
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
Will help local people improve their well-being through income generation, an
improved environment and better public health

Will enable people in Lancashire to compensate in a practical way for some of
the consequences their lifestyles are having for the global environment

Were drawn up through, and will be carried out by, the participatory
involvement of all genders, acknowledging the critical role of women

Are helping to build a productive, and mutually beneficial, spirit of partnership
and cooperation between GL, GMC, LL and LCC

Focus on community participation, opportunities for skills training and for
building the capacity of deserving groups

Will provide lessons, ideas and good practices for implementation elsewhere

Have an emphasis on creating, and maintaining, sustainable livelihoods that
are in tune with the local environment

Create prospects for promoting, and raising, public awareness about the
global environment in both communities

Look to the future, in that the GCCS is seen as the start of an expanded
programme to help more people over a much wider area.
DETAILED COMMENTS & ISSUES FOR CLARIFICATION
1. Community Integrated Wetland Conservation and Management Project
General
LL and LCC fully support this project, and the stated benefits it will deliver in terms
of climate change. In addition, the group welcomes the way that the project links the
conservation of an important natural resource to the potential for assisting local
people to raise income. The project is strong on community participation and
empowerment through training and the development of new skills. There are
parallels with wetland conservation projects in Lancashire, which might provide
scope for the future exchange of ideas on good practice.
Specific Issues
We would like to ask for further clarification about this project as follows:
a) Do GMC already possess the legal powers to produce bye-laws for controlling
the protected zones and for designating green belts, or will these have to be
sought - if so, will this delay the project, and add to costs?
b) Are there enough fish-farmers already operating in Gulu for the scheme to
start immediately, or will new fish-farmers have to be trained before the
project can start?
c) Will the designation of the 10km-wide wetland protection zones lead to people
being displaced to other areas, or will there be any other negative social or
economic impacts on local residents?
d) Will the project have any adverse impacts on public health - for example, will
the creation of ponds and reservoirs increase the risks of malaria, or other
water-borne diseases, spreading?
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e) The proposal suggests that many people will be trained - will the project have
the capacity to train this many people, especially as other projects in the
GCCS involve elements of training?
f)
It is proposed to plant palm trees and papyrus on the wetlands - will there be
a net loss in carbon savings as a result of planting trees on this wetland?
g) The proposal covers a large area - will it be possible to enforce the bye-laws
and protect the whole of the conservation area, e.g. from poachers?
h) What forms will the tourism that is mentioned take and how will it be
developed and promoted, as the Activity Work Plan & Budget contains no
allocation for this?
i)
Will it be cheaper to buy the hand-held GPS in Uganda, rather than in UK will one bought in the UK work in Uganda?
2. Bio-Diesel Demonstration Project
General
LL and LCC fully support this project in the form in which it is presented, and the
stated benefits that it will deliver in terms of climate change. The proposal is for a
small-scale project, using a naturally occurring ‘weed’ to produce fuel for purely local
use & income - in which form it would seem to be a highly sustainable activity.
However, we have a question about the potential long-term out-turn of the pilot subproject, which is raised below.
Specific Issues
We would like to ask for further clarification about this project as follows:
a) Jatropha curcas is increasingly grown as a commercial crop, attracts big
investors, and often displaces local food crops and people. The sustainability
of large-scale bio-fuel production is widely questioned, particularly with
regard to negative impacts on greenhouse gas emissions.
Will the pilot project remain as a locally sustainable enterprise, or is there a
risk that it will develop into a large-scale, unsustainable commercial operation
that could disadvantage local people and the wider environment?
b) The proposal says that the project will ‘create avenues for greater
employment while avoiding deforestation’ - how will deforestation be avoided?
c) Jatropha is toxic - is any training needed to avoid health problems, or are
local people aware of the dangers already?
d) Have Ugandan suppliers been contacted, as it may be cheaper, easier and
more sustainable to source the equipment and chemicals required locally?
3A. Sustainable Land-use/Land Management Sub-Project: Organic Farming
General
LL and LCC fully support this sub-project, and the stated benefits it will deliver in
terms of climate change. The use of locally occurring materials to promote a more
environmentally sustainable approach to food production is applauded. This will
assist income generation, and help to improve the health and well-being of local
people. The sub-project is strong on community participation and empowerment,
through training and the development of new skills.
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Specific Issues
We would like to ask for further clarification about this sub-project as follows:
a) Is there a potential advisory role in the sub-project for the agriculture
department of Gulu University - the University has been involved with both GL
& LL previously?
b) Is the project dependent on the World Bank + GEF/UNDP money, or can it’s
objectives be met just from the GCCS - if not, is there a fall-back position, or
alternative way of funding the project?
3B. Sustainable Land-use/Land
Timber Plantations
Management
Sub-Project:
Smallholder
General
LL and LCC fully support this sub-project, and the stated benefits it will deliver in
terms of climate change. Being the best supported project during the community
consultation process, shows that it meets an important local need. In this regard, we
welcome the fact that the sub-project will engage with a range of community-based
interests, including schools, individuals and community tree groups.
Such
widespread public support means that the ambitious target of planting 100ha of
timber trees will be easier to achieve.
Specific Issues
We would like to ask for further clarification about this sub-project as follows:
a) Are the actions listed at both T3.4s in the Activity Work Plan & Budget
included in order to meet the UNFCCC rules for small-holder CDM projects?
b) Might there be a problem with this sub-project in that the trees will be
planted primarily for agro-forestry purposes with money from the GCCS
budget, which might make them ineligible for offset payments under the
additionality criterion?
c) Carbon trading/off-setting is a complex, frequently criticized, process, so
might it be better to get the project up and running before exploring the
potential for off-setting?
d) Teak and mahogany are slow-growing species - will this affect their value in
terms of carbon trading?
e) Teak and mahogany are valuable commodities - how will they be protected
from illegal sawyers?
f)
Are there enough locally native species in the project - is the umbrella tree an
environmentally sustainable species in this part of Uganda?
g) If carbon offsetting is pursued, will £200 be enough to cover the cost of
consultants - could Gulu University provide this service?
h) Is the project dependent on the World Bank + GEF/UNDP money or can it’s
objectives be met just from the GCCS - if not, is there a fall-back position, or
alternative way of funding the project?
3C. Sustainable Land-use/Land Management Sub-Project: Integrated
Approach to Reduce Emissions from Deforestation and Forest Degradation
through Beekeeping
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General
LL and LCC fully support this sub-project, and the stated benefits it will deliver in
terms of climate change. Conserving locally occurring honey bees will make a vital
contribution to the sustainability of food production and natural plants generally, in
addition to supplementing incomes. The training and skills development aspects of
the sub-project are also welcomed. We have a question about the proposal to link
the project to the UNFCC REDD, which is raised below.
Specific Issues
We would like to ask for further clarification about this sub-project as follows:
a) Presumably, actions R4.0 to R4.4 are included in the Activity Work Plan &
Budget to qualify the sub-project for REDD status - but, as the trees will be
planted primarily for honey bee conservation will they be ineligible for offset
payments because of the additionality criterion?
b) As with the timber sub-project, might it be better to get the project up and
running before exploring the potential for off-setting?
c) Will there be a need for monitoring to check that participating farmers do not
continue to slash & burn?
d) Is the project dependent on the World Bank + GEF/UNDP money or can it’s
objectives be met just from the GCCS - if not, is there a fall-back position, or
alternative way of funding the project?
4. Integrated Garbage Management Project
General
LL and LCC fully support this project, and the stated benefits it will deliver for climate
change. Its benefits in terms of improving public health and the urban environment
are, perhaps, even more significant, while the resource efficiencies and income that
will be derived from the compost and the recycled plastic goods, are also welcome.
Total project costs are to be met mainly from sources other than the GCCS, and we
hope that the project will not be jeopardized if these funds do not materialize. LCC
has a wealth of expertise in integrated waste management, opening the scope for
the future exchange of ideas on good practice.
Specific Issues
We would like to ask for further clarification about this project as follows:
a) Is this project happening already, or is it already programmed?
b) As the project can not proceed without World Bank, or significant other,
money, might it be worth allocating the GCCS sum to a project that can start
quickly, and assisting the waste scheme at a later date?
c) Once the project does start, how will residents and businesses be made to cooperate - and what happens if they do not?
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