RSEU comments to Ministry for Nature resources on the Draft Decree of the President of the Russian Federation "On the level of greenhouse gas emissions

The Ministry of Natural Resources and Environment has placed on its website a draft Decree of the President of the Russian Federation "On the level of greenhouse gas emissions," to conduct an independent examination of corruption.

To: Donskoy S. E.
Minister of Natural Resources and Environment
of the Russian Federation
123995, Moscow, B. Gruzinskaya str., 4/6
(499) 254 60 11, mpv@mnr.gov.ru

Dear Sergey Efimovich!

The Ministry of Natural Resources and Environment has placed on its website a draft Decree of the President of the Russian Federation "On the level of greenhouse gas emissions," to conduct an independent examination of corruption.

The Climate Secretariat of the Russian Social Ecological Union supports the importance of the regulations adopted in Russia in recent years: the Climate Doctrine of the Russian Federation and the Comprehensive Plan for Implementation of the Climate Doctrine of the Russian Federation for the period up to 2020.

We consider the fact that the Decree fixes specific numbers to ensure emissions "no more than 75 percent from the level of 1990" as reasonable and objective.

However, the draft Decree contains no specification, which would indicate the role of forests in the accounting system for greenhouse gas emissions. If the number given in the document is formed with the account for absorption by forests, it would in fact mean actual increase in emissions as compared to 1990 levels, which is a negative environmental factor and significantly reduces the role of Russia in the international climate process.

We emphasize that the ecosystem services of forests on increasing carbon sinks is one of the most effective conservation tools that do not require significant external budgetary infusions. In this case, sustainable forest management can become a good option for sustainable forest management to local communities and indigenous small peoples.

We believe that Russia can develop a separate national target for CO2 absorption by forests and for preserving climate-controlling functions of forests, which would promote sustainable and environmentally sound forest management in the long term. In case of adoption of the Decree "On the level of greenhouse gas emissions" in its present form, without specification about absorption of greenhouse gas emissions by forests, possible ambiguity arises, which may have corruption implications.

Based on the foregoing, we consider it necessary to include clarification "(without consideration for absorption of greenhouse gas emissions by forests of Russia)" at the end of the text in paragraph 1 a) of the draft Decree.

Also, we propose to determine in the Decree the date of stopping the growth of emissions, consistent with achieving the stated national goal of 40% reduction in energy intensity over 2007-2020. That is, to add a paragraph 1 c) "to ensure by 2020 reduction of energy intensity of national economics by 40 percent from 2007 levels."

Representatives of the Russian Social Ecological Union are ready to support the Decree with the proposed "forest amendments." We express our willingness to participate in working out the action plan envisaged by the Decree and in working out a target indicator for forests.