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Developing countries detail nationally appropriate mitigation actions - TWN Bonn Update No. 19

Climate: Developing countries detail nationallly appropriate mitigation actions

Bonn, 10 June (Hilary Chiew and Chee Yoke Ling) – Developing countries reiterated that nationally appropriate mitigation actions (NAMAs) of developing countries are voluntary in nature unlike internationally legally binding commitments of developed countries and countries with economies in transition. Accordingly, monitoring, reporting and verification (MRV) of NAMAs should not further burden developing countries.

Parties to the UN Framework Convention on Climate Change (UNFCCC) deliberated on mitigation actions by developing countries (non-Annex 1 Parties) and associated MRV on Tuesday afternoon (8 June).

[The contact group under the Ad-hoc Working Group on Long-term Cooperative Action under the Convention (AWG-LCA) chaired by AWG-LCA chair Margaret Mukhahanana-Sangarwe had on 7 June discussed mitigation commitments or actions by Annex 1 Parties and associated MRV.]

Several delegations provided detailed views on “international consultation and analysis” as requested by the Chair who took the phrase used in the Copenhagen Accord paragraph in relation to NAMAs. Egypt objected to the use of this term while several developing country Parties referred to national communication guidelines as the criteria.

[The Copenhagen Accord is the controversial document that was “taken note” of in the last meeting of the Conference of the Parties in December 2008 in Copenhagen when it failed to obtain consensus due to its selective and untransparent process.]

The AWG-LCA Chair presented a new set of question to Parties:
a) How would support for planning and elaboration of nationally appropriate mitigation actions be provided?
b) What policy guidance needs to be provided by the AWG-LCA on:
• Frequency of submission of national communications from non-Annex I Parties and their different elements
• Revision of the guidelines for preparation of national communications of non-Annex I Parties
c) How would international consultation and analysis be undertaken, at what level and by whom? What elements of the national communications of non-Annex I Parties would need to be analyzed?

Brazil speaking on behalf of G77 and China said planning is specific to NAMAs and it should be supported independently and should not be a precondition for non-Annex 1 Parties to propose their NAMAs for seeking support. Support for NAMAs should reflect the voluntary nature of planning and elaboration of NAMAs and must be accompanied with the payment of the full agreed costs by developed countries.

The Group said that in the consideration of the national communications of developing countries in relation to NAMAs, Parties should respect the work of the Subsidiary Body on Implementation (SBI) without interrupting or restricting the flow of work within SBI.

India said the fundamental feature of developing countries’ mitigation actions is that such actions are voluntary in nature and are to be taken in the context of sustainable development. The NAMAs of developing countries will therefore be guided primarily by the national priorities of social and economic development including the energy needs of people and the eradication of poverty.

It said the fact that developing countries are prepared to undertake NAMAs out of their own volition and in the interest of global goal of climate stabilisation can, in no way, imply that NAMAs of developing countries constitute a part of internationally legally-binding mitigation commitment.

It said that some developing countries like India are endeavouring to undertake ambitious and specific NAMAs out of their own resources. Such actions, it added, can of course be enhanced if international support and enablement in terms of technology and finance mandated under the Convention is available from the developed country in requisite measure.

Referring to the idea of a low carbon growth strategy or emission pathway which has been referred to by some Parties as a necessary condition for elaboration and support of NAMAs, India said that a low carbon development strategy is not a part of the internationally agreed mechanism of funding the NAMAs which are a national and an autonomous exercise. There shall be no ground for subjecting the national plans and unsupported activities to international verification in the name of a low carbon strategy or pathway. The Convention and the Bali Action Plan, said India, make it clear that the guiding principle is the sustainable development of developing countries.

India also suggested that NAMAs seeking international support should be recorded in a registry along with relevant technology, finance and capacity building support and that these would be subjected to international MRV in accordance with guidelines adopted by the Conference of Parties. The registry needs to be a part of the climate change financial mechanism, and take into account only those mitigation actions that require financial support and have been proposed for such support and enablement from international sources.

India said that national communications that are required of developing countries under the Convention are the most appropriate vehicle for reporting all domestic mitigation actions including supported and unsupported actions.

India suggested that there can be different periodicity for different elements that are decided to be part of a National Communication. While the inventories etc. could be reported every 2 years provided full agreed cost is available for preparing such inventories etc; the actions as are consistent with Article 12.1(b) (of the UNFCCC) and the update on declared goal of domestic mitigation could also be reported at some other agreed frequency .

India emphasised that a regime of MRV for developing countries cannot be more rigorous than that for developed country Parties, whether it is the periodicity or the content or its consideration. Domestic mitigation actions that are not supported by finance and technology under UNFCCC arrangements or ‘unsupported NAMAs’ will be subject to only domestic arrangements for their MRV.

It said that guidelines for MRV, whether those that are supported and reported in the National Communication or those that are autonomous/domestically funded, should be subject to the decision of the COP through its competent subsidiary body, the SBI.

China said developing countries may on a voluntary basis propose NAMAs for financing. The planning of NAMAs should be financed on an agreed full cost basis according to Article 4.3 of the Convention.

It stressed that these planning activities are not be a precondition for non-Annex 1 Parties to propose their NAMAs for seeking support in terms of finance, technology transfer and capacity building. Such planning activities should aim at facilitating domestic technical analysis of NAMAs.

With regards to policy guidance of MRV, China reiterated that SBI should be the appropriate place to discuss this question where Parties have made a lot of efforts to make progress. The discussion of the National Communication of non-Annex I Parties including its frequency and revision is ongoing under SBI. Thus, the policy guidance from AWG-LCA is not necessary because it will duplicate the discussion and lead to confusion.

It said any additional obligations related to National Communications from non-Annex I Parties cannot be separated from the provision of finance and technology support in a timely and adequate manner and this should be significantly scaled up.

It underscored that these autonomous mitigation actions are distinct from mitigation commitments of Annex 1 Parties in terms of forms, legal nature and MRV requirement. Thus, ICA (international consultation and analysis) should also be distinct from the existing review process for Annex 1 Parties.

China was of the view that ICA is not a review process but a collective effort to improve transparency. The basis for ICA should be the information contained in National Communications submitted by non-Annex I Parties, and national sovereignty should be fully respected. The scope of the ICA should focus on presenting information and flagging issues for further clarification.

It also said transparency is for all Parties including Annex I Parties and non-Annex I Parties. The ICA is only part of a comprehensive package to improve transparency for all Parties and to enhance multilateral trust.

Pakistan said that it remains committed to NAMAs as agreed to under the Bali Action Plan. It said that the term NAMA is applicable to only those actions by developing country Parties that are supported and enabled by technology, financing and capacity-building. These actions are voluntary in nature and taken in the context of sustainable development.

It stressed that any additional mitigation actions that a developing country may wish to undertake beyond those supported and enabled would obviously be a sovereign choice, depending on its national circumstances and capacities which would constitute unilateral actions that are distinct from NAMAs.

It said that support for planning and elaboration of NAMAs should be provided through the financial mechanism and in accordance with Article 12 of the Convention. It is of the view that once a NAMA has been established at the national level following the internationally agreed guidelines, the process must lead to provision of funding and meeting the technological requirement. An automatic trigger to ensure availability of finance should be agreed to and it can only be available if the support for planning and elaboration of NAMAs is placed inside the UNFCCC financial mechanism.

With regards to frequency of National Communications, it said it is important that Parties explore the option of different cycles for different Parties as normally done under various other international bodies and international legal instruments. It finds potential basis for negotiations on Option 1 of paragraph 12 but not Option 2 of paragraph 12 in the Chair’s facilitative text.

[Option 1 provides for submissions within a range of 1 to 5 years, supported by finance and capacity building with LDCs and possibly small island developing States doing so at their discretion, while Option 2 provides for submissions every 2 years with conditional support.]

On revision of guidelines for preparation of national communications of non-Annex I Parties, Pakistan was open to ideas which will strengthen the process of national communication but does not think that splitting off or updating any particular component of the national communication serves the correct objective. It will burden the system but also a large number of Parties with low emission status. It suggested establishing different cycles or periodicity of the complete National Communication for different Parties as the way forward, pointing to specific provisions in the Chair’s facilitating text that could be considered.

Pakistan said strengthening guidelines for submission of national communication should be sufficient and should, therefore, obviate the need for ICA and once a national communication is submitted in accordance with such guidelines, it should be treated as a final product.

The United States said it sees the need to significantly support transparency of NAMAs and acknowledged that several developing countries have begun a process to support comprehensive planning in line with their broader development objectives.

It said more detailed guidance on MRV of developed countries can be elaborated over time, supporting this to be done under the AWG-LCA. It proposed increased reporting frequency of developing countries that is not like developed countries but it has to be timely and often enough.

It said that developing countries should conduct domestic MRV of actions in accordance with international standards and norms, and the ICA, together with international MRV for supported actions.

It proposed submission of national communication once every 6 years and limited updates every other year detailing among others, emission impacts, methodologies and assumptions used, and the link to emissions’ trading.

It also requested developing countries to submit a low emission strategy and update their respective national communications based on IPCC (International Panel on Climate Change) 2006 reporting guidelines.

On ICA, it said that it is not a process for assigning international consequences and punitive measures but to promote understanding and to enable developed countries to comprehend what developing countries are doing and what the world is doing in its collective effort to reduce emission.

It said following the understanding reached in the Copenhagen Accord, developing countries should conduct domestic MRV of actions in accordance with international standards and norms, and ICA. For supported actions, there should be international MRV.

For analysis, implementation of actions will be subject to ICA by an expert panel where the panel will follow the same type of procedure as other international bodies. The SBI could conduct interactive dialogue between Parties and the SBI.

It said the content of ICA includes guidelines and standards of financial institutions and other funding bodies. Without a reporting system of transparency of developing countries there could not be a climate deal, it added. It insisted that without effective transparency, the world has no way of assessing progress in combating climate change.

The European Union said that the NAMA registry would help to coordinate actions with support, and emphasized the importance of MRV to achieve a temperature rise below 2 degrees C.

Marshall Islands, speaking for the Alliance of Small Island States said it saw the need to adequately address the full life cycle of NAMAs including policy development, planning and related capacity building and proposal for support. With regards to ICA, it said its members are still studying the implications of the ICA and the primary objective should be to promote transparency to have a better picture of global situation.

Egypt questioned the Chair’s use of the term “international consultation and analysis” that is taken from the Copenhagen Accord, stressing that international guidelines determined under the UNFCCC should be the criteria.

It said the revision of MRV guidelines for developing countries should not lead to a gradual unifying of the reporting requirements for Annex I and non-Annex I Parties because the nature of the obligations are different and it has to be that way. It cannot accept subjecting NAMAs to ICA for review.

On the EU’s call for stringent MRV so that the objective of staying below 2 degree C (the target in the Copenhagen Accord) can be achieved, it asked if developed countries are expecting developing countries to fill the gap left by the weak emission reduction pledges of developed countries. It said the answer is “definitely not”. It asked Annex I Parties to revise their emission reductions commitment (to be of higher ambition).

South Africa agreed with Egypt, underscoring that developing countries were not here to fill the gap between Annex 1 pledges and the goal of limiting temperature rise to below 2 degrees C.


It said that analysis would include consideration of whether the reported actions have been taken and whether support has been received. It added that the analysis would consider deviation from business-as-usual, or a carbon intensity matrix or any other matrix chosen by the developing country.

Consultations, according to South Africa, should be based on information and analysis provided by the developing country in its national communication and inventory. It said that the guidelines for ICA should respect national sovereignty and be conducted at the multilateral level and not at the request of a particular Party.

Philippines reiterated that the only MRV in the UNFCCC is that of Annex 1 Parties’ commitments.

Chile said that it is up to the COP to define international guidelines for MRV, and this should be done by a group of intenrational experts working with national teams to identify the elements for MRV of national communications.

Saudi Arabia supported Pakistan and Egypt stressing that NAMAs are totally distinct from Annex 1 Parties’ commitments. It said that without support for NAMAs, many developing countries cannot prepare NAMAs. It agreed with Egypt in questioning the selective reading of the Copenhagen Accord.

Bolivia stressed the need to strictly respect national sovereignty in international consultations. It stressed the importance of the UNFCCC Article 4.7

[Article 4.7: The extent to which developing country Parties will effectively implement their commitments under the Convention will depend on the effective implementation by developed country Parties of their commitments under the Convention related to financial resources and transfer of technology and will take fully into account that economic and social development and poverty eradication are the first and overriding priorities of the developing country Parties.]

Norway said there was need to inform other countries what one is doing to show one’s efforts. It wanted the information to be trustworthy and of high quality. The national communication should be supplemented every six years but it would be on a voluntary basis for the Least Developed Countries.

Singapore said it is open to the concept of ICA but it must be a technical procesa and not a political or politicised process. It looks forward to developing the concept further.

In conclusion, the Chair said she will prepare conclusions including a request for the UNFCCC Secretariat to compile Annex 1 Parties’ emission reduction pledges and non-Annex 1 NAMAs. She said that she would make available on Thursday, June 10, a non-paper on her sense of the progress made at this session for consideration at the August meeting.

MRV of developed countries

On 7 June, the contact group discussed the MRV of mitigation actions of developed countries, as the Chair Sangarwe said that this matter had been dealt with sufficiently.

Brazil speaking for the G77 and China said that it was important for the establishment of rules for achieving comparability of efforts among developed countries as in the Bali Action Plan. Strongest rules are crucial for enhanced actions as in the Kyoto Protocol.

It referred to Article 5 which provide clear guidelines for regular review; Article 7 for annual inventories and supplementary information and Article 8 for the application of expert review processes as well as the guidelines established by the Conference of Parties. Information on policies and measures is important. Complementing this, there has to be strong compliance structure using the system application under the Kyoto Protocol. Information on use of LULUCF should reflect the rules under the Protocol within the context to strengthening this.

Brazil said that the matter of comparability and use of MRV as well as compliance should be considered under a technical panel to ensure that Parties have achieved the level of comparability of all Annex 1 Parties in the context of an ambitious global effort. It was opposed to joining the MRV of developed and developing countries in a single chapter in the negotiating text as the commitments of developed countries and actions of developing countries are separate and distinct.

Spain for the European Union said that in relation to the mitigation actions of developed countries, there was need to address the issue of accounting, legal formalization of emission reduction targets, coverage of the pledged emissions, accounting for land use, land-use change and forestry (LULUCF) as this was not clear for all developed countries.

It said that the contribution of the flexibility mechanisms needs to be clarified. There was also need to discuss annual reporting of GHGs and national inventories. It said that there was need to discuss modalities for achieving targets not defined under the UNFCCC as well as adjustment of expert review teams. It also said there need to discuss how compliance would be treated under a new instrument. It reiterated its suggestion for the secretariat to compile the pledges of the Annex 1 Parties. It said that there will be need for revised guidelines for national communications following the MRV framework.

The United States said that that developed countries need to prepare and report on inventories and the content is guided by the 2006 IPCC guidelines. It supported the need for frequency of reporting every 4 years and updates every 2 years. The biennial updates should be detailed in nature on status of the implementation of the quantified emission reduction targets, it added.


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