Contre l’introduction de la compensation “forêts” dans le marché carbone californien

Monsieur le Gouverneur Brown,

Nous vous écrivons pour vous exhorter de ne pas inclure le mécanismes de compensations internationales REDD + (Réduction des émissions dues à la déforestation et à la dégradation des forêts) dans le marché carbone en Californie. Les systèmes de marché carbone n’ont pas réussi à réduire les émissions alors que les projets de compensation ont constamment ignoré les droits des communautés locales et sont intrinsèquement viciés. Les organisations soussignées envoient cette lettre pour alerter contre l’inclusion de crédits REDD + qui ne manqueront pas d’aggraver les conflits environnementaux et sociaux.

Les premières tentatives pour inclure les forêts dans les marchés carbone soutenus par l’ONU ont conduit à d’importants débats techniques. Les crédits forêts internationaux REDD + ont été jusqu’à présent rejetés dans les négociations climatiques de l’ONU et exclus du marché carbone européen de l’Union européenne (EU ETS) pour de bonnes raisons. Des problèmes techniques non résolus, y compris l’additionnalité (qui prouve que la zone forestière n’aurait pas été protégée sans), les ‘fuites’ (les destructeurs de la forêt passant à un autre domaine), la permanence (les arbres ne stockent pas le carbone en permanence), la mesure (très complexe et incertaine car elle repose sur la diversité des variables biologiques) et la temporalité (les émissions et les absorptions peuvent encore survenir plusieurs années après qu’un projet arrive à terme). Outre ces incertitudes techniques, les causes sous-jacentes de la déforestationrestent largement ignorées tandis que la responsabilité de réduire les émissions à la source est édulcorée.

En raison de ces problèmes, introduire les mécanismes internationaux de compensations forêt dans le cadre du marché carbone en Californie augmenterait probablement les émissions de gaz à effet de serre (GES) relatives aux objectifs AB32 plutôt que de les diminuer, puisque les industries polluantes achètent des droits pour accroître leurs émissions. Cela reviendrait àexposer les communautés à faible revenu qui vivent à proximité des installations industrielles en Californie à des problèmes environnementaux et de santé encore plus importants. Alors que de nombreux peuples autochtones et des communautés tributaires des forêts qui vivent dans le Sud ont très peu de titres officiels sécurisant pour leurs terres, REDD + va alimenter la spéculation, augmenter la pression sur les droits fonciers et déposséder les populations locales. Ces risques sont aggravés par l’inclusion de la monoculture dans la définition standard des Nations Unies de ce que constitue une forêt.

Les forêts riches en biodiversité ont une signification unique pour ceux qui y vivent et en dépendent pour leur subsistance et leur survie culturelle. Les projets REDD+ font peser de graves préoccupations en termes de violations des droits humains et environnementaux et ont conduit à ce que des peuples autochtones et des communautés locales dans le Chiapas (Mexique) et dans la région Acre (Brésil) s’y opposent (ce sont les deux régions où les pollueurs de la Californie achèteraient ces crédits internationaux). Réduire les forêts à de seuls puits de carbone fait courrir d’énormes dangers. Les luttes pour la terre s’intensifient à mesure que les droits sur les terres sont séparés des droits d’accès et d’usage d’autres éléments de la nature.

Le gouvernement du Chiapas au Mexique, promeut par exemple un projet REDD + pilote dans la forêt tropicale Lacandon sur plus de sept réserves naturelles. Afin d’être «prêt pour REDD +», le gouvernement doit prouver que les zones à partir desquelles des certificats de carbone seraient générés sont sous une protection environnementale. A cet effet, la Commission nationale adéjà déplacé plusieurs communautés locales en utilisant des expulsions forcées et des pressions économiques en dépit de fortes résistances.

En outre, l’expansion des monocultures d’agrocarburants est une autre raison de l’empressement du gouvernement du Chiapas. Un programme d’Etat, intitulé “Reconversion productive de l’agriculture», finance les communautés locales de la jungle Lacandon pour planter des palmiers africains et de plants de jatropha pour les agrocarburants qui sont envahissants, qui détruisent les forêts locales et créent des dépendances économiques qui écrasent l’autonomie locale. Le Chiapas est l’État au Mexique avec la plus grande zone de plantation de palmiers, situés sur les bords de zones naturelles protégées, et ces monocultures utilisent de grandes quantités de pesticides qui polluent les sols et l’eau et nuisent gravement à la santé des populations locales. Une fois de plus: les plantations ne sont pas des forêts!

La Californie devrait appliquer des politiques qui s’attaquent aux causes profondes de la déforestation et du changement climatique afin d’entamer une transition vers une ère post-fossile. Les politiques fondées sur la justice sociale et environnementale doivent garantir que les pollueurs soient tenus responsables de leurs émissions de GES et de la destruction de l’environnement, tout en faisant en sorte qu’elles bénéficient aux communautés vulnérables et à faible revenu. Nous vous demandons de maintenir le système international REDD + hors du marché carbone californien. En outre, nous vous recommandons respectueusement de regarder attentivement la façon dont le marché carbone européen a échoué, comme une préfiguration de ce qui pourrait advenir marché carbone en Californie. Commercer les émissions de carbone n’est PAS une solution au changement climatique.

Cordialement,

- Aliança RECOs – Redes de Cooperação Comunitária Sem Fronteiras (Brazil)

- Movimento Mulheres pela P@Z! (Brazil)

- ITEREI

- Friends of the Earth International

- Centro de referência do movimento da cidadania pelas águas florestas e montanhas Iguassu ITEREI

- Plataforma Interamericana de Derechos Humanos, Democracia y Desarrollo (PIDHDD)

- Terræ Organização da Sociedade Civil (Brazil)

- Carbon Trade Watch

- FERN

- Common

- Attac France

- The Corner House

- Centre for Civil Society Environmental Justice Project (Durban, South Africa)

- Earth Peoples

Worlds in movement…

Time for Big Green to Go Fossil Free

Naomi Klein

“I am proud to have been part of the group at 350.org that worked with students and other partners to develop the Fossil Free campaign. But I now realize that an important target is missing from the list: the environmental organizations themselves.

“”People are fed up with being told that the best way to fight climate change is to change their light bulbs and buy carbon offsets, while leaving the big polluters undisturbed. And they are raring to take the fight directly to the industry most responsible for the climate crisis.”

“… some of the most powerful and wealthiest environmental organizations have long behaved as if they had a stake in the oil and gas industry. They led the climate movement down various dead ends: carbon trading, carbon offsets, natural gas as a “bridge fuel”—what these policies all held in common is that they created the illusion of progress while allowing the fossil fuel companies to keep mining, drilling and fracking with abandon. We always knew that the groups pushing hardest for these false solutions took donations from, and formed corporate partnerships with, the big emitters. But this was explained away as an attempt at constructive engagement—using the power of the market to fix market failures.

“Now it turns out that some green groups are literally part owners of the industry causing the crisis they are purportedly trying to solve.”

Read on….

Why are carbon markets failing?
For years we have put our faith in the market to incentivise cleaner technology, and for years the carbon market has been riddled with corruption. It’s time to try something else
in

By Steffen Böhm

The price of carbon credits can be so low that they have no impact on industry and offer no incentive to invest in low-carbon technology. Photograph: Rob Griffith/AP
Carbon markets have lost us more than 15 years in the battle against climate change yet we continue to plough forward with scaling them up. Why?

Some hope that this global expansion of carbon markets will revive their fortunes, helping to raise billions for investments in low-carbon and climate change mitigation technologies. Others, including myself, take a more evidence based approach, arguing that this hope of the pro-market lobby is unfounded, given the inefficient and even corrupt nature of carbon markets so far. There is an urgent need for alternatives to be considered, as the world is running out of time to curb the most serious impacts of run-away climate change.

The principles of carbon markets were established in the 1997 Kyoto Protocol, but to date there have been few, if any, measurable reductions in greenhouse gas (GHG) emissions that can be attributed to these measures. The two most important carbon markets so far – the EU Emissions Trading System (EU-ETS) and the UN’s carbon offsetting scheme, Clean Development Mechanism (CDM) – are failures, yet, new carbon markets based on these schemes are being planned in both developed and developing nations.

The EU-ETS is in turmoil at the moment, as the scheme is more over supplied with carbon allowances than ever before. This means that power stations and factories have been allocated more allowances than they actually need, due to the serious recession in many countries, but also due to intense industry lobbying. There has also been a flood of cheap CDM carbon credits, which has contributed to the price of carbon being so low that it currently is a negligible cost to industry, and, more importantly, it does not incentivise investments in low-carbon technologies.

Profiting from global warming?

As a result, many financial institutions have closed their carbon trading desks and have reduced their stakes in renewable energy funds. In fact, “working under the assumption that climate change is inevitable, Wall Street firms are investing in businesses that will profit as the planet gets hotter”, as Bloomberg reported recently. While new start-ups invest in adaptation, many big energy companies are getting out of renewables and instead bank on profits from increased extraction of fossil fuels.

If it seems unethical that companies would forego mitigation to profit from a hotter planet, it is also surprising that renewed hope and political energy is being put into introducing new carbon markets in places such as California, Australia, Japan and Canada. In addition, the World Bank has been busy introducing carbon markets in many developing countries, such as Brazil, Mexico, Colombia, Thailand, Vietnam and South Africa.

Why are carbon markets failing?

Carbon markets would not suddenly work better if the carbon price was right. There are at least three systemic failures with the carbon trading approach. The first concerns the link between carbon markets in the developed world and offsetting opportunities in developing countries. In a WikiLeaks released cable, government officials claimed recently that none of the CDM projects in India (the second biggest host of CDM projects after China) can be considered ‘additional’. This means that every CDM project should go beyond ‘business as usual’, that is, be greener than what would have taken place otherwise. In fact, the opposite is often true.

The GFL gas project in Gujarat, India, for example, has been one of the biggest producers of CDM carbon offset credits in the world, selling them to many of the biggest polluters in the EU. GFL has profited immensely from the CDM, and Europe’s polluters have had a cheap way to offset their climate responsibilities without actually greening their way at all. The EU Climate Action Commissioner, Connie Hedegaard, has admitted that such projects have a “total lack of environmental integrity”.

The second reason is that carbon markets have been infested by corruption and non-transparency. When studying one project in India, my research team realised that the Mumbai office of a major international consultancy appeared to have copied and pasted large chunks of documentation from one CDM project to another. In fact, carbon markets have created a lot of income for consultants, carbon brokers and project developers, not to mention the validators, policy makers, NGO professionals and academics who have made a living from these markets. There is very little independent and democratic oversight in the system. Instead, there are many revolving doors between the business, policy, NGO and university worlds, fuelling accusations of corruption.

Contrary to their claims, carbon markets have fuelled unsustainable practices. AT Biopower, a Thai company that generates renewable electricity by the burning of rice husk is able to sell carbon credits to Japanese and other polluters. AT Biopower presents rice husk as a waste product, but, as Carbon Trade Watch activist Tamra Gilbertson says it is actually a vital source of fertilizer in the local, sustainable economy of subsistence farmers. Farmers now have to buy petroleum-based, chemical fertilisers, which makes them worse off and creates negative environmental impacts.

Although it is plain to see that carbon markets have not worked at all, as they have failed to reduce GHG emissions, new trading mechanisms are currently planned in many countries around the world. Given the manifold problems outlined above, more than 100 civil society organisations are (including Earth Peoples) currently calling for the EU-ETS to be scrapped. They ask: why should we put our hope and trust into a system that has failed us so far? There are plenty of more powerful policies that can and should be explored: promotion of local economies, energy conservation, community-owned energy generation and carbon taxes.

None of these will provide a one-fits-all solution. But we cannot afford to lose another 15 years in our quest to rapidly decarbonise our economies, businesses and societies. Carbon markets have given the appearance of us doing something about climate change, while actually legitimising the constant rise of emissions. We need to go back to the drawing board and come up with solutions that actually work in practice.

———————————-

Steffen Böhm is director of the Essex Sustainability Institute, University of Essex, and professor of management and sustainability at Essex Business School. Steffen and his doctoral student - Siddharth, were also the editors of the book - “Upsetting the Offset” (MayFly books - London), in which some of us are contributing authors.

By Chris Lang, 6th March 2013

COONAPIP, the National Coordinating Body of Indigenous Peoples in Panama, has withdrawn from the UN-REDD process in Panama. In a letter to the UN, COONAPIP explains that UN-REDD “does not currently offer guarantees for respecting indigenous rights [nor for] the full and effective participation of the Indigenous Peoples of Panama.”

In a previous letter, dated 20 June 2012, COONAPIP wrote that the process “has been riddled with incongruences and inconsistencies” and that “We feel used in this process.”

In a Resolution from a meeting on 25 February 2013, COONAPIP calls on Indigenous Peoples,

“to proceed with caution and to take the necessary measures to avoid being tricked by United Nations bodies and officials, who have the legal obligation to comply with the United Nations Declaration on the Rights of Indigenous Peoples.”

Ironically, UN-REDD recently released its
Guidelines on Free, Prior and Informed Consent.

READ entire article HERE

Below is a statement from one of Earth Peoples co-founders Hector Huertas, on behalf of the Legal Counsel to COONAPIP, explaining the decision to withdraw from the UN-REDD process

The National Coordinating Body of Indigenous Peoples of Panama (COONAPIP) is a body with representation from the seven Indigenous Peoples of Panama and was identified by the UN-REDD Programme as a key actor in planning the national REDD strategy for Panama. However, COONAPIP is concerned that in the “consultation” process both the government of Panama and UN officials refuse to comply with indigenous rights recognized by the Panamanian State and the United Nations Declaration on the Rights of Indigenous Peoples.

For example, the officials refuse to recognize that almost 76% of the forests of Panama are found in indigenous lands and territories, which Indigenous Peoples have inalienable rights to, and which are recognized by the constitution and Panamanian law. Furthermore, it is contradictory that, on one hand, the officials minimalize the importance of indigenous issues for REDD, and on the other, allow logging companies to participate.

Indigenous Peoples have made it clear that a REDD strategy must first ensure the implementation of the nationally and internationally recognized rights of Indigenous Peoples. However, the UN-REDD officials say that it is not a priority of the Programme to help secure the land rights of Indigenous Peoples who do not have collective deeds and whose land has had protected areas superimposed upon them.

With regards to the issue of full and effective participation of Indigenous Peoples, the UN officials and the Panamanian government are dividing indigenous communities with money from the Programme to force supposed consultations. This unethical and reprehensible procedure prompted COONAPIP to stop participating in a process whose objective is to privatize the forests of Panama in violation of the Panamanian constitution and laws, and allow the State to cash in on carbon credits in utter contempt for the rights of Indigenous Peoples.

Hector Huertas, Esquire
Legal Counsel of COONAPIP

New Food & Water Europe Report Shows Why Use of International Forest Offsets Won’t Reduce Carbon Emissions

Brussels — Developments in the United States may lead to the adoption of international forest offsets being permitted in the EU Emissions Trading System (ETS). California’s newly launched carbon market is considering allowing offsets from REDD+ programs while at the same time the state is considering linking its market with the EU’s. California would be the first carbon market to allow international forest offsets. A new report, Bad Trade: International Forest Offsets and the Carbon Market, released by Food & Water Europe today, demonstrates that international forest offsets should not be allowed into any carbon market because they don’t encourage emission reductions at the source, but instead privatize natural resources, present opportunities for corrupt offset trading, and threaten the livelihoods and resources of indigenous communities.

Forest offsets would allow for a polluter in one location to pay for the protection of a section of forest in another location anywhere in the world, based on the idea that trees, which absorb carbon, can offset the emissions of the polluter. This methodology puts a financial value on the prevention of deforestation and degradation, essentially turning areas in countries with heavy forest cover into a financial opportunity for corporate greed.

REDD+ offsets lead to the financialization and privatization of nature. In addition, forests usurped into REDD+ programs become off-limits to the indigenous communities that have lived there for decades and have sustainably managed the forests without financial incentives.

“California’s attempts to allow international forest offsets could force Europe to adopt the same standards,” said Gabriella Zanzanaini, Director of European Affairs for Food & Water Europe. “Linking carbon markets to international forest offsets is essentially financializing nature, which could lead to corporate and governmental land grabs, displacement of indigenous peoples from their homes, and possibly the creation of a counterfeit offset market that grants credits without actually protecting forests.”

You can view the Food & Water Europe report here

Food & Water Europe is a program of Food & Water Watch, Inc., a non-profit consumer NGO based in Washington, D.C., working to ensure clean water and safe food in Europe and around the world. We challenge the corporate control and abuse of our food and water resources by empowering people to take action and transforming the public consciousness about what we eat and drink.

We are re-launching this recent video produced by the World Rainforest Movement, which is now available in four languages; English, Spanish, French and Portuguese. It tells about the impacts of REDD+ and the ´green economy´ projects for forest peoples, as well as their struggle against such projects to reclaim their territory.

Video: ENGLISH

The United Nations General Assembly has proclaimed 21 March as the International Day of Forests. By proposing this new international day, the UN is trying to raise awareness about the importance of all types of forests. However, the UN should raise awareness in the first place about the fact that forests around the world are increasingly disputed territories.

In this dispute there are two clear sides. On the one hand the around 300 million of people who depend directly on forests. These forest communities not only depend on forest for their survival but also play a fundamental role in the conservation of these forests. On the other hand the big transnational companies, for which forests are simply a source of profits, obtained by the extraction of commodities or by the substitution of forests with industrial monocultures. Since a couple of years, forests communities are facing another threat that is disputing their lands: REDD projects and other related “solutions” to the climate crisis, proposed in the context of the “Green Economy”.

A clear example of this dispute is what happens in the Atlantic Forest in Brazil. 500 years ago, the Atlantic Forest covered the entire Brazilian coastline, but is now seriously endangered. However, in the state of Paraná, a vast area of this Forest still survives. This is the largest area of the Atlantic Forest in the world and it is home to a number of different traditional communities; the Caiçaras, the Quilombolas and the indigenous Guaranis.

The ways of life of all three populations are closely tied to the Atlantic Forest. Most of them do not have legal title to the land they occupy or the forests they use. How have these communities traditionally coexisted with the Atlantic Forest?

Fifty years ago, ranchers began moving into the area, clearing the forest and taking over the land to raise water buffalos. In the 1990s, projects arrived, including REDD+, that form part of the so-called Green Economy. What has been their experience with this kind of projects?

In 2003, with the help of the Landless Workers Movement (MST), the community of Rio Pequeno occupied a ranch. What happens when communities organize and regain control over their land?

In 2012, the WRM visited a number of traditional communities in the area searching their answers to these questions. The result is this video, now available in four languages. We invite you to watch it, share it and/or use it in your work with communities also facing the dispute of their territories with REDD and “green economy” projects in general.

EARTH PEOPLES  JOINED WITH HUNDREDS OF ENVIRONMENTAL GROUPS FORCES:

First growth Atlantic Rainforest (Photo © Rebecca Sommer)

LETTER TO THE UN AND ITS INSTITUTIONS AND INITIATIVES RELATED TO FOREST ISSUES
(FAO, CBD, UNFCCC, UNCCD AND UNFF)

21 March – the first ´International Day of Forests´

An appeal to urgently halt forest destruction, addressing the underlying causes

The UN has launched one more initiative to call attention to the fate of the world´s forests: 21 March from 2013 onwards will be the International Day of Forests. But will the Day make any difference to the forests and people who depend on them, considering that the UN International Year of Forests in 2011 went largely unnoticed?

Indeed, the UN should lead the measures to halt tropical deforestation, and therefore it should know and appropriately address the causes of forest loss. The most important direct causes of deforestation are quite well known, and include logging, the conversion of forested lands for agriculture and cattle-raising, industrial tree plantations, urbanization, mining, oil and gas exploitation, hydroelectric dams and industrial shrimp farming.The underlying causes that drive deforestation, however, are multiple, interrelated, less easily visible, and often little discussed and understood. A thorough process of analyzing underlying causes of deforestation, undertaken in the late 1990s by the UN with significant civil society participation, concluded that these drivers of deforestation are related to land tenure, resource management, trade, international economic relations in general and social exclusion.

The FAO claims that deforestation was lower in the period 2000-2010, compared with the previous decade. Still, 13 million hectares of mainly tropical forests, including mangrove forests, were destroyed each year in this period; and the actual figure is likely to be even higher because FAO continues to consider industrial plantations as forests. By defining “forests” as any land with a certain quantity of trees on it, the FAO distorts the data: the real forest loss appears lower than it actually is because for the FAO, industrial tree monocultures are the same as diverse forests that provide home and food for forest dependent peoples.

The International Day of Forests comes in the wake of renewed international attention to tropical forests that started with climate negotiators putting the role of forests in climate change on the agenda of UN climate talks: since 2007, the UN climate summits have been debating REDD – Reducing Emissions from Deforestation and Forest Degradation. But have the efforts put into REDD+ resulted in reduced deforestation or at least a reversal of the current trend? Have the many initiatives undertaken since REDD emerged slowed the loss of forests worldwide? Are mangrove forests (“blue carbon”) less degraded today than they were in 2007? Are forest peoples’ rights better protected today than they were in 2007? Have the pledges of Northern governments to contribute US$ 7.7 billion, as well as the renewed attention itself for forests internationally really been able to slow, and eventually halt the loss of forests?

Recent reports from Brazil and Indonesia, the two countries where most of the forest was lost during 2000-2010, indicate that after a short dip in the rate of deforestation according to FAO statistics, deforestation is going on and many new forest areas are under threat of large-scale corporate-driven activities that destroy forests.

Those same actors involved in forest destruction are often at the same time involved in projects that allegedly aim to protect forests, for example through REDD+ projects. These actors include transnational corporations, Northern but also Southern governments, financial market institutions including the World Bank, big conservation NGOs and certification organizations.With the UN at the forefront, all of these key actors defend the so-called “green economy”,presented as a “win-win” approach that tackles both the economic-financial and environmental crises, by redirecting investments to unlock so-called “natural capital”, as well as new, supposedly clean technologies (such as those based on biomass) and the “carbon market”, as well as the trade in “environmental services” in general. In tropical forest countries, this is leading to increasing conflicts, human rights violations and resistance. The destruction, if anything, has increased, not decreased, let alone stopped.(1)

Forest destruction must be halted – urgently!

This letter is an international appeal that forest destruction needs to be urgently halted – and not just “reduced”. Forests are vital for forest peoples, whose way of life depends on them. An indigenous leader from Eastern DRC states: “The forest and the indigenous peoples could be described as inseparable friends. The life of a pygmy depends 100% on the forest because the forest is our home ‘par excellence’. I can state that without the forest, there can be no life for indigenous peoples”.(2) Halting deforestation and the recognition of land rights are of special importance for indigenous peoples in voluntary isolation. An increase in land grabbing, much of it in forest areas, and the ongoing destruction of forests, particularly through the “concession model” of logging, agriculture and mining, put at risk the continued voluntary isolation because most often the areas where peoples in voluntary isolation are able to still survive on this planet and maintain their way of life are the very areas targeted by land grabbers.

Halting forest loss is also crucial to combat social exclusion and to respect the rights of Nature and its intrinsic value. Furthermore, forests are important for humanity in general, especially the populations in tropical forest countries. It is extremely concerning that forests are increasingly affected by the effects of climate change. The perpetuation of the current unsustainable production and consumption model is at the root of both, the climate and forest crises. Initiatives aimed at truly halting deforestation – or avoiding runaway climate change – will therefore need to address these root causes.

To halt deforestation, the underlying causes that drive forest loss need to be eliminated. Urgent actions needed towards this end include:

-   Recognition of the rights of forest and forest-dependent communities over their communal territories with special attention to the indigenous peoples in voluntary isolation; these rights must include the right to control decisions affecting the territories of forest dependent communities.

-    Define forests by their true meaning for forest-dependent peoples; exclude industrial tree monoculture plantations from the definition: Plantations are not forests.

-   Expose and halt the destruction caused by transnational corporations (TNCs) and other actors who lead the land grabbing process; the past decade has shown that TNCs cannot be regulated: their existence and increasing influence are a main threat for the future of tropical forests.

-   Expose and break the pattern of corporate-driven false solutions like ´sustainable’ large-scale activities in tropical forests, REDD+, trade in environmental services, public-private partnerships, certified “green economy”, etc.. Instead, propose and defend true solutions which mean defending locally sustained economies, in terms of the use of for example minerals, biomass and energy. We reiterate the call of the international Oilwatch network: Leave the oil in the soil and the coal in the hole!

-    Support efforts to consume less forest destroying products instead of initiatives that promote buying the certified products from large-scale operations and companies that continue to destroy forests.

Above all, on this first International Day of Forests we call on the UN and its forest-related institutions to heed the lessons of past initiatives aimed at ending deforestation: Halting forest loss will remain an illusion until action is undertaken to eliminate the underlying causes that drive deforestation.

(1) For more information on Deforestation, see bulletin 188 of the WRM: www.wrm.org.uy
(2) FORESTS MUCH THAN ONLY TREES