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Comments on the Draft Carbon Offset Regulations 2018 – South South North

Dear Sir/Madam
SouthSouthNorth’s involvement in registering Africa’s first CDM and the world’s first Gold Standard project – and the later work in implementing and verifying Gold Standard CERs, provides us with a fairly unique experience and means we are relatively well-placed to comment on the carbon off set policy.
I am attaching a copy of our earlier submission, which provides details and the supporting background for our position and recommendations.
While we welcome the policy and commend treasury for this initiative, we remain very concerned about a basic failing and want to re-iterate three critical points:
1. The market that interests us and which the policy is expressly targeted to achieve (small scale, under 40,000 tCO2e projects that prioritise human development outcomes), cannot operate in a CDM, VER, GS compliance world. Those standards work for Industry level carbon projects and provide excellent revenue generating potential for expensive carbon consultants – specifically international consultants, but are useless for small-scale, social development, community-based projects that will form the back-bone of South Africa’s carbon market if we are to realise the stated poverty and development Policy Objectives.
2. The fact that the policy still does not make express and immediate provision for the recognition of a suitable carbon registry (when we have one that has a long and exemplary audited track record of achieving the exact objectives of the Policy – specifically relating to poverty, employment, empowerment – in addition to verified green house gas reductions) is a serious short-coming that sends the wrong signal to the South African carbon market (in so far as it exists) and will preclude the policy from achieving its stated outcomes.
3. Requiring small scale, community-based projects to wait for future promulgation of regulations that provide for additional validation and verification frameworks – and which might take 8 months (and likely longer) to come into effect, places such projects at an unfair and unnecessary disadvantage.
We urge Treasury to include Credible Carbon – alongside the others – as the one registry that can make the policy objectives a reality for small scale carbon off-sets.  We have the potential to attract finance from corporate emitters – as part of their social responsibility to scale up a range of exciting and highly desirable community based job-creation carbon projects – and to energise the sector, while telling a uniquely positive South African story.  If 70 cents in the Rand of the carbon off-set, has to be spent on high cost consultant fees to meet the bureaucratic standards of international registries, that would make no logical sense for us, the communities we serve, and any investor. Not providing accreditation for Credible Carbon will radically reduce the scale and nature of community-based projects that might otherwise be initiated.
Carl Wesselink

Microsoft Word – SSN Comments on Draft Policy.docx


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