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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 Comments on Gulu Carbon Compensation Scheme Draft Project Proposals 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 Comments on Gulu Carbon Compensation Scheme Draft Project Proposals 2 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 Comments on Gulu Carbon Compensation Scheme Draft Project Proposals 3 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? Comments on Gulu Carbon Compensation Scheme Draft Project Proposals 4 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. Comments on Gulu Carbon Compensation Scheme Draft Project Proposals 5 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 Comments on Gulu Carbon Compensation Scheme Draft Project Proposals 6 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? Comments on Gulu Carbon Compensation Scheme Draft Project Proposals 7