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Dear Member of the Ad Hoc Group,

On March the 9^th, the EU ad hoc group on climate change meets in Brussels. It will use this meeting to prepare a position for debate with other key Parties to the Kyoto Protocol at the informal sessions on the flexibility mechanisms in Malaysia at the end of March.

The Malaysian meeting represents a clear opportunity for the EU to demonstrate a continued commitment to global environmental leadership in the fight against climate change. In particular, a Clean Development Mechanism which supports sustainable development, will form a key part of any final package at COP6 in November. We believe that a successful CDM must comprise four key elements.

As a basic principle nuclear power is a non-sustainable technology must be explicitly excluded from the CDM.
A positive list of renewable and energy efficiency technologies should be developed for inclusion in the CDM.
An environmental screening process should ensure that all projects pass a sustainability test before being eligible for certified emissions reductions under the CDM.
We do not consider that sinks projects are eligible under the CDM, as Article 12 explicitly deals only with emissions reductions.

Nuclear power is an unsustainable technology and has no place in the CDM because of severe and repeatedly demonstrated environmental and social impacts. Nuclear power gives rise to long-lived highly toxic wastes, involves transports of hazardous materials, and creates a serious accident risk with potential transboundary effects. Development of the nuclear fuel cycle also increases the threat of nuclear proliferation through the inevitable creation of weapons-usable nuclear materials. The Alliance of Small Island States (AOSIS) has proposed text stating that rules for CDM projects "shall not support the use of nuclear power". It is clear that unless nuclear power is specifically excluded in the rules of the CDM, there is a danger that some would consider it eligible by default. Therefore we would request that you support the AOSIS text and demand that the EU, as a bloc, do the same. We can not support an agreement at COP6 which results in a CDM that supports a technology as demonstrably unsustainable as nuclear power.

The EU should develop the concept of a "positive list" of technologies to be included in the CDM. Whilst it is impractical to finalise details on March 9^th , the EU can endorse the principle of such a list focusing on renewable and energy efficiency technologies. Advocating a positive list will allow the EU to engage other countries in a constructive debate about incentivising sustainable technologies, whilst demonstrating a continued commitment to environmental leadership within the process. Positive list technologies could for example be given exclusive access in an initial phase of the CDM.

A sustainability screen is necessary for all projects to ensure that they contribute to sustainable development as explicitly requested by the Kyoto Protocol. Project eligibility criteria should be developed to ensure that high environmental and social standards are guaranteed in the CDM. We do not believe that large hydro or large fossil projects will pass a credible sustainability test.

While the basis for Joint Implementation under the Kyoto Protocol is different, it is essential for the same reasons that JI should not be used to support nuclear power or other unsustainable technologies.

Yours Sincerely,

Karla Schoeters,

Director,

Climate Network Europe