Response to Dr Bala’s letter to WWF

Dear WWF,

I refer to our Minister for the Environment and Water Resources, Dr Balakrishnan’s 23 Oct 2014 letter to you on the WWF Living Planet Report 2014.

While Dr Bala claims to also nurture the world’s natural capital, there doesn’t seem to be any such nurturing information that can be found on his Ministry’s website. WWF’s website on the other hand, clearly shows worldwide nurturing initiatives like saving the sea or saving tigers in the wild.

You may ask what does an eye surgeon like Dr Bala know about environmental performance metrics that can help WWF develop better metrics. In fact, why would WWF, the premier agency in global environmental conservation need a Singapore minister to tell it what good metrics is?

Dr Bala’s complain that Singapore imports almost all food, materials and goods is no good reason why WWF environmental metrics should be changed. Consumption drives manufacturing which in turn drives energy use and carbon emission. It is precisely due to Singapore consumption that these goods are made in the first place.

Dr Bala must know that most First World nations are located in cold climates and must emit huge amounts of carbon each winter to heat homes. If WWF bends to our peculiarities, surely WWF must also bend to a great many peculiarities in other nations which may not necessarily end up with Singapore being better off?

Global Footprint Network methodology is sound

Global Footprint Network’s methodology is fundamentally sound and supported by renowned global institutions like Stanford’s Carnegie Institute for Science and Norway’s Center for International Climate and Environmental Research.

The Carnegie Institution for Science in Stanford, California, reports that in 2004 23 per cent of global CO2 emissions – some 6.2 gigatonnes – went in making products that were traded internationally. Most of these products were exported from China and other relatively poor countries to consumers in richer countries. Some countries, such as Switzerland, “outsourced” over half of their carbon dioxide emissions in this way because they have a high import-to-export ratio of such energy-intensive goods as consumer electronics, motor vehicles and machinery.

The average European is responsible for adding more than 4 tonnes of CO2 to the atmosphere in the manufacture of goods imported from other countries …

The Carnegie study is one of the most comprehensive to date of a growing number that track emissions based on where goods are consumed. National inventories such as those conducted annually by the United Nations Framework Convention on Climate Change currently consider emissions produced in each country’s own territory only.

“If we want to understand our footprint of emissions, we have to understand that others are emitting on our behalf to make our goods and services,” says study co-author Ken Caldeira. “The US and Europe are responsible for a bigger percentage of emissions, because it is emissions that go into the production of goods coming out of China that are supporting our lifestyle.”

The study draws on detailed economic data from the Global Trade Analysis Project based at Purdue University in West Lafayette, Indiana, which takes into account the CO2 emissions intensity of manufacturing in different countries and different sectors of the economy.

Another study, which Glen Peters of Norway’s Center for International Climate and Environmental Research in Oslo is to publish soon, uses similar trade data to analyse consumption-based emissions up to 2008 and also tracks how the global movement of CO2 emissions has changed since 1990.

[US still responsible for most CO2 emissions,, 8 Mar 2010]

Not true we have no influence over upstream processes

Dr Bala cannot say we have no control over upstream manufacturing processes because by virtue of our buying power, we can choose to import from countries with more efficient manufacturing processes and hence lower carbon footprints. Since Dr Bala’s ministry controls all food imports into Singapore, he is in a very good position to influence the shift of food imports towards countries with lower carbon footprints. Singapore being a price taker does not mean Singapore has no choice as to where to import from.

UNFCC methodology doesn’t tell the full picture

Many institutions have come forward to explain why the existing United Nations Framework Convention on Climate Change (UNFCC) method of carbon accounting is outdated and doesn’t tell the full picture of a nation’s carbon footprint and why a consumer based method or a method based on embedded carbon should be the right way forward instead.

The territorial emissions tell us where the emissions occur, but the consumption approach tells us why the emissions occur. Increasing demand for products and services drives up emissions across the world. Increasing demand in the UK may increase emissions, not necessarily territorially in the UK, but wherever those goods are produced.

[Stockholm Environment Institute, Project Report – 2010, page 1]

The UK has targets under the Kyoto protocol, and legal obligations under the Climate Change Act to reduce emissions. But the benchmark against which those targets and obligations are set excludes this “off-shored” carbon. Using a faulty accounting system creates a kind of Alice in Climate Wonderland world in which up is down, the wrong people take the blame and the kingdom is never put in order.


A first-principles assessment suggests that placing the carbon obligation with final consumers (and hence their government) would be a better approach, in a world economy where international trade in goods and services shifts embodied emissions between countries. Consumption-based carbon accounting would mean that a price signal is fully passed through the supply chain, thus avoiding over-consumption resulting from the cost of emissions not being priced into the goods and services.

[The Carbon Challenge, Geoff Bartram and Simon Terry, page 181]

The German Development Institute’s Sept 2010 paper “Counting CO2 emissions in a globalised world” also came to the same conclusion.

The UK Energy Research Centre submitted a memorandum to the UK House of Commons in 2011 proposing the adoption of a consumer based method of greenhouse gas allocation (

The UK reports greenhouse gas emissions using three approaches including the one based on the concept of embedded carbon (UK Department of Energy & Climate Change, Alternative approaches to reporting US greenhouse gas emissions, Apr 2014, page 4).

In fact, the UNFCC is not fundamentally opposed to the concept of carbon being imported or exported.

Carbon is brought into the country from … imports … and removed from the country through exports

[UNFCC Resource Guide, Module 3, National Greenhouse Gas Inventories, page 13]

Important to assign shipping and airfreight emissions

By not assigning international shipping and air freight carbon emissions to individual countries, both the International Energy Agency and the UNFCC are leaving significant amounts of global emissions with no country to answer for.

The GFN is therefore correct to assign shipping and air freight carbon emissions to individual countries although the assignment could be based on net imports instead.

Singapore doesn’t lack renewable energy

Dr Bala need not be so begrudging of other countries’ geothermal energy as there are currently only two countries – Iceland and Philippines that generate more than 15% of their electrical energy needs from geothermal sources.

Our lack of other renewable energy sources is no excuse for lament because Singapore’s solar power alone has the potential to supply 30% of our nation’s needs.

The sun could supply almost a third of Singapore’s electricity, up from less than two per cent now, by 2050.
If predictions made by researchers from the Solar Energy Research Institute of Singapore (Seris) come to pass, it may mean lower electricity bills and fewer carbon dioxide emissions.

[Straits Times, S’pore can tap more solar power by 2050, 20 Aug 2014]

Dr Bala should admit that Singapore has been late in adopting solar power even though Singapore has so much more sunshine than say Germany.

The puzzling thing is that Singapore, which is more suited to tapping solar power than most countries that already use the technology extensively, is not already doing so, said Professor Stephen Wittkopf of the National University of Singapore’s School of Design and Environment. ‘I’m German and I grew up with this type of technology around me. Singapore has 50 per cent more sunshine than Germany, so I don’t understand why it’s not making use of it here,’ he told a solar energy seminar at the Institute of South-east Asian Studies on Monday.

The conditions here are ideal for power generation using photovoltaic panels, which convert light into electricity, Prof Wittkopf noted. Sunshine is constant and there are many high-rise buildings. As their solid facades face east and west, they are able to capture strong sunlight.

[Straits Times, Sunny S’pore ‘ripe for solar power’, 2 Feb 2005]

Our lack of progress in adopting solar power is a good example of how our government has always favored economics over the environment.

Singapore’s Economic Development Board (EDB) … told Reuters the country would only use solar power when its price hit parity with the cost of buying it from the grid

[Reuters, Solar panels wait for sunny outlook in Singapore, 30 Mar 2009]

Switch to natural gas for economic, not environmental reasons

As with solar energy, Singapore’s switch from fuel oil to natural gas for electricity generation was primarily for economic rather than for environmental reasons as Combined Cycle Power plants running on natural gas have higher efficiency and hence lower cost of electricity generation.

So for all of Dr Bala’s lyrical waxing about Singapore’s commitment to the environment, that commitment almost always comes after economics.

Carbon Emission per GDP dollar unfair

It is unfair to compare countries based on carbon emissions per GDP dollar because it means that all else being the same, a richer country is allowed to emit more carbon than a poorer country. That’s not fair. A richer man has no right to pollute the earth more than a poorer man. The fairer way is to compare carbon emissions per capita.

As explained earlier, WWF’s carbon footprint calculation methodology isn’t questionable but merely more advanced than the one Dr Bala employs. Similarly, Singapore’s No. 7 ranking by WWF isn’t a mistaken outcome but an outcome based on a more advanced calculation methodology.

Yale studies not more accurate

The other studies cited by Dr Bala do not give a more accurate picture than the one by WWF.

The 2014 Environmental Performance Index by Yale University yielded some stupendous results that no reasonable person will accept as true or accurate. For example, it actually gave Singapore 100 marks for air pollution compared to 78 / 57 marks for Switzerland. Setting aside the fact Singapore experiences unpleasant haze from Sumatra every now and then, it’s just bewildering to think that Singapore air beats Swiss air hands down.

Country Air Pollution – Average Exposure to PM2.5 Air Pollution – Average PM2.5 Exceedance
Singapore 100 100
Switzerland 78.2 56.5

Yale also manipulated the indexes such that miraculously those indexes that Singapore scored poorly (e.g. SO2 emissions) disappeared while those that Singapore did well were doubled in weightage (e.g. access to drinking water and sanitation).

Asian Green City Index biased

The Asian Green City Index is blighted by biasedness. In both the 2011 and 2013 editions, the scores of five Asian cities hardly differed from one another, yet Singapore was placed one band above the rest.

Asian Green City Index 2011 and 2013 Well above average categories Above average categories Average categories Overall
Singapore 2 6 0 Well above average
Tokyo 2 5 1 Above average
Osaka 1 7 0 Above average
Yokohama 1 7 0 Above average
Hong Kong 1 6 1 Above average

More importantly, the 2011 report admitted to Singapore’s band being pushed up by one even though it had no basis for doing so based on quantitative measures alone. Siemens and the Economist were apparently impressed with Singapore government’s stated goals then. It seems that no such admission could be found in the 2013 report. But judging from the exact same outcome, Siemens and the Economist have continued to push Singapore’s band up by one despite having no basis for doing so.


The creativity and ingenuity Dr Bala referred to are mostly borrowed creativity and ingenuity. For example, our improved water security relied primarily on membrane technologies developed from the US.

Balanced expansion is not typically how one would describe Dr Bala’s government which is more commonly associated with growth at all costs. Even Dr Bala’s own parliamentary colleague Mr Injerjit Singh says so.

Dr Bala should not delude us about Singapore being a haven for flora and fauna. We no longer have virgin jungle or large natural predators which is the best indicator of the health of a forest. Our native plant and animal species numbers are far lower than those of a corresponding piece of virgin forest of the same size.

Whether Singapore contributes just 0.2% of global emissions is questionable from a consumption perspective. But even if that is true, Singapore represents only 0.07% of the world’s population so we are contributing nearly three times our fair share of global emissions.

Dr Bala’s ‘clarifications’ hasn’t provided a fuller or a more accurate view of Singapore’s environmental situation. Dr Bala should understand that self-praise is no praise. The comprehensive account of our environmental ‘achievements’ is not even recognized by most Singaporeans.

Vivian Balakrishnan – Minister for the environment and water resources, Response on WWF’s Living Planet Report 2014, 23 Oct 2014

Singapore and WWF share a common belief that all countries have a collective responsibility to augment and nurture the world’s natural capital, while minimising consumption and waste. In addition, more than half of humanity now lives in cities – and it is crucial to develop sustainable urban solutions that can be applied globally. This has special significance for Singapore as a city-state. We hope to work with WWF on developing better metrics for the environmental performance of cities.

2. We also wish to clarify some points in the recent WWF Living Planet Report 2014 (LPR 2014). The report fails to recognise Singapore’s unique circumstances as a small island city-state with no hinterland. Singapore has to import almost all food, materials and goods for daily life and economic activities. Consequently, the LPR 2014 report does not give due recognition to Singapore’s real environmental achievements, including our longstanding commitment to sustainable development and resource efficiency.

(a) The Ecological Footprints reported in the LPR 2014 were computed by the Global Footprint Network (GFN), which had attributed the carbon footprint of imports to the importing country. Given our limited land area and scarce natural resources, Singapore is heavily-reliant on imports of food, materials and goods to sustain daily living and economic activity. While we can reduce consumption, improve operational efficiency and reduce the carbon footprint of activities taking place within Singapore’s borders, we have no control over the upstream manufacturing and processing of imports – and hence their carbon footprint. Singapore is a price-taker within the larger international marketplace. We also note that this methodology deviates from the internationally-accepted carbon accounting methodology of the United Nations Framework Convention on Climate Change (UNFCCC), whereby embodied emissions on imported goods accrue to the exporting country instead.

(b) GFN also allocates international marine and aviation bunker emissions to each country in proportion to the country’s share of international trade volume. This results in a gross over-estimation of Singapore’s per capita carbon footprint as Singapore sits on a vital global shipping route and has one of the busiest transhipment ports in the world. GFN’s practice of breaking down and attributing international transport emissions to countries has not been adopted by other agencies that track carbon emissions for international transport. Both the International Energy Agency and the UNFCCC treat international bunkers as a separate category without assigning the emissions to individual countries.

3. The Ecological Footprint rankings also fail to recognise that countries have varying levels of access to renewable sources of energy that can substitute for the use of fossil fuels. Unlike other large and geographically diverse countries, Singapore does not have access to geothermal resources, hydroelectricity, wind, tidal or wave power. Solar energy is technically feasible and Singapore has been making steady progress to invest in this renewable energy source for widespread adoption, but even this is limited by the small geographical size of Singapore and the lack of a rural hinterland. Nevertheless, we have already switched from fuel oil to natural gas for power generation to reduce the amount of carbon per unit of electricity generated. In 2013, natural gas accounted for 91.8% of Singapore’s fuel mix for power generation. This has contributed to Singapore having one of the lowest carbon intensities (carbon emitted per dollar GDP) in the world.

4. The comparison in the LPR 2014 states that the footprint associated with carbon emissions formed the bulk (70%) of Singapore’s Ecological Footprint. Given that the methodology in calculating carbon emissions is questionable and also takes no account of Singapore’s size and circumstances (for the reasons given above), the conclusion in the LPR 2014 that Singapore has the 7th largest per capita Ecological Footprint of the 152 countries studied is similarly mistaken. Other benchmarking studies give a more accurate picture of Singapore’s strong standing in environmental protection and sustainability. One example is the 2014 Environmental Performance Index developed by Yale University and Columbia University in collaboration with the World Economic Forum. It ranked Singapore 4th out of 178 countries for its exemplary performance on high-priority environmental issues. Singapore was also ranked top among 22 major cities in the 2013 Asian Green City Index that was produced jointly by the Economist Intelligence Unit and Siemens.

5. Singapore has a long history of using creativity and ingenuity to overcome its natural constraints. As highlighted in the LPR 2014, water-scarce Singapore has improved its water security through the ‘four national taps’ strategy (rainwater collection, water imports, wastewater reclamation and desalination). In addition, we have balanced the infrastructural expansion needed to support Singapore’s high population density with concurrent urban greening and biodiversity conservation efforts. About 10% of Singapore’s total land area is currently set aside for parks and nature reserves, and more than 40% is covered by greenery. Singapore remains a haven for flora and fauna including 1,410 native vascular plant species, 364 bird species, 98 reptile species and 255 hard coral species.

6. Although Singapore contributes less than 0.2% of global emissions, it is committed to reduce carbon emissions, with a particular focus on raising energy efficiency across all sectors. The Energy Conservation Act was implemented in April 2013 to stipulate mandatory energy management requirements for large energy users in the industry sector. These requirements have been extended to the transport sector since January 2014. The Mandatory Energy Labelling Scheme and Minimum Energy Performance Standards also promote the use of energy efficient appliances among households. Singapore is on track to meeting its unconditional pledge at the UNFCCC to reduce emissions by 7-11% below business-as-usual levels by 2020.

7. We hope that the above clarifications provide a fuller and more accurate view of Singapore’s environmental constraints and commitments. The next edition of the Sustainable Singapore Blueprint is due to be released by the end of 2014, and will provide a comprehensive account of Singapore’s environmental achievements and its plans and ambitions to continue to work towards an environmentally sustainable future. We welcome analysts and interested parties to review the Blueprint when it is released.


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