Response to Defra consultation on voluntary carbon offsets

It stifles NGOs efforts to ensure that voluntary carbon offsets make a serious contribution to sustainable development, which the CDM currently fails to do; It promotes institutional monopoly (putting all eggs in the UNFCCC basket) at a time when a sensible approach to global climate policy suggests that institutional diversity is valuable; The appellation “code of best practice” suggests a level of robustness in the EU ETS and CDM markets that cannot yet be claimed; As is well-known, EUA prices have been highly volatile, and while it is possible that Phase II prices will be steady and high, it is also possible that EUA prices could crash to extremely low levels, as in Phase I. An EUA price crash would leave the “code of best practice” in a rather embarrassing position.