SUBMISSION BY ITALY AND THE EUROPEAN COMMISSION ON BEHALF OF THE EUROPEAN
UNION AND ITS MEMBER STATES
This submission is supported by Albania, Bosnia and Herzegovina and Serbia.
Rome, 14 October 2014
Subject:
The Ad Hoc Working Group on the Durban Platform for Enhanced Action
(ADP): the 2015 Agreement
SUMMARY
Intended nationally determined mitigation contributions (INDCs) provide the primary means for
operationalising the principle of CBDRRC in the 2015 Agreement. Through a common process that is
applicable to all, each Party will select its commitment type and level of ambition that is as
ambitious as possible, and that is differentiated in light of its national circumstances and capabilities.
Each Party will describe why its INDC reflects a fair and ambitious contribution to the agreed below
2°C objective. An international process to consider and analyse the INDCs prior to COP 21 will build
trust by enabling us to understand, compare, and aggregate proposed commitments. To ensure this
process succeeds, all Parties should stick to the Warsaw timetable, and the major and emerging
economies should come forward with INDCs by the first Quarter of 2015.
All INDCs must address mitigation. The INDC process was conceived and agreed with mitigation and
the below 2°C objective in mind. Adaptation and finance will be crucial components of a balanced
2015 Agreement. Ensuring adaptation and finance are properly addressed in the 2015 Agreement
requires specific and distinct approaches.
Up front information requirements, which are to be agreed in Lima, must ensure that INDCs are
transparent, quantifiable and comparable. Up front information requirements should be
differentiated according to the type of contribution.
A common multilateral rules-based regime including clear and robust monitoring, reporting and
verification (MRV) and accounting rules, as well as compliance, is fundamental in the context of
nationally determined contributions. It is the only way to achieve transparency and accountability
and secure confidence in the new regime.
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Mitigation commitments of all Parties – and in particular those of the major and emerging
economies - must be finalised in Paris, alongside all the rules essential to doing so. This includes all
the rules for MRV and accounting, such as those on accounting for the land-use sector and for the
use of international carbon markets, that would substantially impact the level of effort implied by
any mitigation commitment. Technical rules that would not substantially impact the level of effort
can be finalised after COP 21.
The 2015 Agreement needs to include a common and regular process for reviewing and
strengthening mitigation ambition to ensure that we collectively stay on track for below 2˚C and that
individual commitments are fair and ambitious. This process should be designed to: respond to the
outcomes of related processes that review Parties' performance (MRV); assess the adequacy of all
existing commitments in light of the below 2˚C objective; and synthesise the latest scientific and
technological developments (IPCC). This process should lead to the upward adjustment of Parties'
commitments.
With regard to adaptation the 2015 Agreement should: (i) recognise the global adaptation objective
as “the achievement of climate resilient sustainable development for all Parties"; (ii) reinforce the
commitments of all Parties to undertake measures to facilitate adequate adaptation and integrate it
in relevant national and regional planning processes; (iii) call to assist the efforts of developing
countries, especially those particularly vulnerable to the adverse effects of climate change. Decisions
supporting the 2015 Agreement should provide further guidance to Parties to improve the
effectiveness of national adaptation action, including the consideration of qualitative milestones for
progress on adaptation, as well as to facilitate enhanced cooperation in preparing and implementing
adaptation measures. The process to take adaptation forward to COP 21 and beyond should
comprise: (i) negotiation of the 2015 Agreement and supporting decisions to anchor and strengthen
adaptation provisions; (ii) continued implementation of the Cancun Adaptation Framework; and (iii)
the continuation of support, including through the Green Climate Fund's (GCF) target of funding
adaptation through 50% of its portfolio over time.
Finance in the 2015 Agreement has to provide the framework for shifting investment patterns
towards low-greenhouse gas (GHG) climate-resilient sustainable economies and societies. There is a
role for all Parties to take actions regarding climate finance in line with evolving responsibilities and
capabilities. This does not mean that all Parties should take the same actions. The 2015 Agreement
should capture the diversity of actions from the domestic level to the international level. Actions
could range from improving domestic enabling environments for facilitating climate-proof
investments to mainstreaming climate considerations into all policies, ensuring impact, and even
mobilising international climate finance.
1. We welcome the initiative of the ADP co-Chairs Non-Paper on Parties’ Views and Proposals on
the Elements for a Draft Negotiating Texti (the non-paper) and its intention of trying to help
move discussions forward. However, there are aspects of the substantive content of the nonpaper that we cannot support (including its structure, which cannot be deemed as agreed at all)
and there are a number of aspects where the EU position is not reflected or not represented
accurately. Nevertheless we consider the non-paper as a useful input for further discussions at
the October session of the ADP. It is the responsibility of the co-Chairs to guide Parties towards
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agreeing by Lima the draft elements for a negotiating text. To that end, we must leave the
October session having had in depth exchanges that lead to a clearer outline of the elements of
the 2015 Agreement and streamlining of the substance of the non-paper.
2. We also welcome the co-Chairs' draft decision on intended nationally determined contributions
of Parties in the context of the 2015 Agreementii (the INDC decision). The draft decision text is a
useful document to facilitate discussions during the upcoming October session. It is essential
that, as agreed, COP 20 adopts an INDC Decision - and we expect the co-Chairs to guide Parties
towards that outcome.
3. This submissioniii: (i) addresses particular areas in relation to which the EU position needs to be
better reflected in the non-paper; and (ii) sets out general reactions to the draft INDC decision.
In so doing the submission goes into further detail on the issues highlighted in the summary
above:
A. Operationalising common but differentiated responsibilities & respective capabilities
(CBDRRC)
B. Intended Nationally Determined Contributions
C. A multilateral rules-based regime for transparency and accountability
D. A cycle for regularly strengthening mitigation ambition in the 2015 Agreement
E. Adaptation in the 2015 Agreement
F. Finance in the 2015 Agreement
A. OPERATIONALISING COMMON BUT DIFFERENTIATED RESPONSIBILITIES &
RESPECTIVE CAPABILITIES
1. One of the most challenging issues that will need to be addressed by COP 21 is how the principle
of CBDRRC will be implemented in the 2015 Agreementiv.
2. If we want to meet our common below 2°C objective, all Parties will have to act to make a
transition towards a safe and sustainable low carbon economy in a way that reflects their
national circumstances. The EU is fully committed to a 2015 Agreement consistent with the
principles of the Convention – including CBDRRC. However, in order to be consistent with this
principle Parties' obligations must reflect evolving realities, circumstances, responsibilities and
capabilities in a fair and dynamic way that is ambitious enough to keep us on track to achieve
the below 2˚C objective. National circumstances have substantially changed in the past few
decades and are likely to do so in the future - a durable 2015 Agreement needs to take this into
account.
3. All Parties should have legally binding mitigation commitments in the 2015 Agreement, but they
will not be the same in level of ambition, and commitment types will differ.
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4. As agreed in Warsaw all Parties' intended contributions should be nationally determined. INDCs
therefore allow each Party to choose its contribution type and define its level of ambition in
accordance with its national circumstances and capabilities.
5. As such the concept of 'nationally determined' contributions put forward as part of the INDC
process, and the subsequent international process to consider and analyse the INDCs, provide
the mechanism through which we can operationalise CBDDRC in the context of the Convention,
and do so in a way that reflects evolving realities, circumstances and responsibilities in a fair
way. This notion should be reflected in the INDC decision and as a core element of the 2015
Agreement.
6. The EU joins many other Parties in the understanding that each Party's determination of its INDC
should represent a progression from previous levels of ambition and scope over time, and that
there should be no ceiling imposed on any Party's level of ambition or on the rules that apply to
it.
7. The differentiation of mitigation-related obligations both before COP 21 and in the context of
the 2015 Agreement itself should flow from this initial national determination of contributions –
including requirements for up front information (see section B below) and the MRV &
accounting rules base (see section C below). The overall result should provide for a common
system, differentiated on the basis of the commitment type chosen by each Party.
8. In this way the process of determining, communicating and assessing INDCs, and finalising
mitigation commitments in the 2015 Agreement, offer a fair and effective way forward for
designing the 2015 Agreement under the Convention, and reflecting evolving realities,
circumstances, responsibilities and capabilities.
9. This approach to operationalising CBDRRC through the notion of 'nationally determined', which
has been supported by a number of Parties, is not well reflected in the non-paper. The EU
cannot accept a static interpretation of CBDRRC that differentiates commitments of Parties
according to a binary split based on the Annex to the Convention.
10. Of course CBDRRC has implications in other areas like adaptation and finance, which must also
reflect evolving realities and circumstances in a fair way.
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B. INTENDED NATIONALLY DETERMINED CONTRIBUTIONS
The content of the INDC decision
1.
The INDC decision to be adopted in Lima needs to provide guidance to Parties both on the up
front information to accompany INDCs as well as on the process to consider and analyse INDCs
with a view to reaching an ambitious outcome at COP 21.
2.
Therefore the INDC Decision should:
a) Reiterate the timeline agreed in Warsaw that all Parties must communicate their INDCs well
in advance of COP21, and in the first quarter of 2015 for the Parties in a position to do so.
We would expect at least all major and emerging economies to communicate their INDCs in
the first quarter of 2015.
b) Clarify that all INDCs must address mitigation. The INDC should set out intended mitigation
contributions that each Party considers to be a fair and ambitious reflection of its
responsibilities and capabilities in the context of the below 2˚C objective, progressing from
previous levels of ambition and scope over time.
c) Specify the need to ensure that the aggregate effect of all Parties' contributions delivers on
the necessary level of mitigation efforts.
d) Clarify that INDCs should clearly set out what a Party will contribute itself unconditionally,
recognising that the poorest countries may be able to do more with support.
e) Set out that over time all Parties should aspire to having economy-wide absolute emission
reduction targets, although initially other types of commitments might be appropriate for
Parties with fewer responsibilities and less capability.
f) Stipulate that mitigation INDCs must be presented along with up front information in
accordance with agreed requirements – these requirements should be set out in the Annex
of the INDC Decision and should be differentiated according to the different types of INDCs.
The up front information requirements should ensure that INDCs are transparent,
quantifiable, comparable, and should facilitate the pre-COP 21 international process.
g) Set out in more detail information requirements needed to promote the transparency of
INDCs and to guide Parties more precisely in respect of the information that needs to be
provided – these should include:
•
On approaches for the land-use sector: Do Parties intend to include the land-use sector
as part of the INDCs? Which accounting approaches are they proposing? Do they intend
to do activity-based or land-based accounting? What reference levels are they using?
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•
On expected use of international market mechanisms: How will Parties avoid double
counting in their INDCs? Are there any restrictions on unit types used to meet the INDC?
(e.g. units from specific gases or geographical restrictions). What percentage of the total
emission reduction effort will be covered by international credits?
•
Methodologies: What methodologies are Parties using to frame their INDCs? Any
projections in the target year/period should be clearly defined and demonstrated. The
methodologies and assumptions used to calculate these projections should also be
transparently explained.
h) Set out that up front information should also include an explanation of why that Party
considers its INDC to be fair and ambitious, drawing on information gathered during the
domestic preparation processes, including any indicators and criteria used. As such the
“other information” section of the Annex of the INDC decision should be moved into the
mitigation section in order to include the mitigation data gathered by Parties as part of the
domestic preparation process.
i)
Set out an international process to consider and analyse the INDCs presented by Parties to
take stock of the aggregate level of ambition in relation to the below 2˚C objective as well as
facilitate the fairness of individual efforts. This process should take place in 2015, starting at
the latest at the ADP session in June, and be completed before COP 21 so as to allow for
finalisation of mitigation commitments in Paris.
j)
Further elaborate on the international process with the following elements:
•
•
•
•
•
3.
The Secretariat to compile the INDCs and summarise them into a technical paper.
Discussions should take place under ADP. After the first quarter of 2015, discussions
could be set in the form of panel meetings or workshops with the possibility to have
question & answer sessions following presentations from Parties. Those with the largest
emissions should be prioritised to ensure the largest possible coverage of GHG
emissions, noting that it is important that all Parties make ambitious mitigation efforts.
International Organisations, think tanks, civil society or other independent bodies with
relevant expertise could be invited to present their own findings/analysis on the basis of
the INDCs presented.
The modalities and timing of the process should be outlined.
Following the international process, Parties could step up the ambition level of their
contribution before finalisation at COP 21.
All the elements presented above are crucial to ensure that we create the conditions necessary
to adopt in Paris a 2015 Agreement with the highest level of mitigation ambition from all Parties
in the context of the below 2˚C objective. Some of these elements are already included in the
INDC Decision. However, some aspects are not addressed with sufficient precision or detail, and
others are absent altogether. We urge the co-Chairs to consider the above points when guiding
Parties towards the next iteration of the Decision.
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4.
The EU also supports the need for Parties to complement their INDCs with non-binding
low-emission development strategies. This is another aspect that is not reflected in the nonpaper or in the INDC decision.
The scope of INDCs
5. The INDC process was conceived and designed specifically with mitigation in mind. The focus
and scope of the INDC process should be to assist all Parties to bring forward, compare and
discuss proposed mitigation measures and ambition ahead of Paris.
6.
A number of Parties from across the negotiations have highlighted the difficulties with
adaptation and finance INDCs, including: technical problems; different timeframes for
underlying processes; and the additional burden imposed ahead of Paris.
7.
Adaptation and Means of Implementation are crucial elements that will have to be addressed in
the 2015 Agreement as part of a balanced and successful outcome at COP 21. They have their
own unique challenges which call for effective and tailor made approaches. Further ideas in
relation to these areas are set out in sections E and F below.
C. A MULTILATERAL RULES-BASED REGIME FOR TRANSPARENCY AND
ACCOUNTABILITY
Introduction
1. Warsaw sent a clear signal that Parties want to further strengthen the multilateral rules-based
regime. An international legally-binding rules-based regime including clear and robust MRV and
accounting rules is fundamental in the context of nationally determined contributions. It is the
only way to achieve transparency and accountability and create trust in the new regime.
2. While flexibility is important in a context where we need to account for a range of commitment
types and consider national capabilities and circumstances, it must be limited. We have to find
the right balance so that we do not undermine transparency, accountability and ambition. We
need a core set of rules that apply to all Parties and other rules differentiated according to
commitment type. The EU cannot support an approach that differentiates rules in a binary way
according to the static Annex of the Convention.
3. By a ‘rules-based regime’, we mean all rules required to guide the definition and implementation
of commitments. These include MRV arrangements, which ensure a sensible approach to the
detailed quantification and tracking of progress towards commitments, and accounting rules
including those for the land-use sector and for international carbon markets. We also mean the
procedures and institutions necessary to operationalise these rules, including the timing and
frequency of reporting and review cycles, the role of expert review teams and the UNFCCC
Secretariat as well as the institutional arrangements necessary to assess and address
compliance.
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4. There is enough time between now and Paris to develop the necessary rules to enable Parties
to firm up their mitigation commitments at COP 21. We don’t need to agree the whole rulebook, rather focus our efforts and: (i) prioritise the work up to Paris on those rules which have
significant impacts on the level of effort implied by commitments; (ii) agree in the 2015
Agreement in Paris provisions setting out the key elements of the MRV, accounting and
compliance regime; and (iii) provide clear guidance for the work that needs to happen after
Paris. We cannot allow the timetable agreed in Warsaw to slip and we cannot have a situation
where rules agreed after Paris significantly change the level of effort represented.
5. It is not practically possible, or necessary, to have all of the technical detail agreed in Paris. The
majority of rules will be further developed after Paris and, in particular, technical rules required
for the implementation of commitments. To this end, the COP 21 should set out work
programmes for the further elaboration of these technical rules.
6. We recognise that Parties have different, but evolving capabilities and data availability can
improve over time. As a result, the commitments put forward by Parties in Paris could for
example be impacted after COP 21 by data improvements. We are open to discuss how this
could be accommodated in the context of the 2015 Agreement.
The rules-based regime in the 2015 Agreement
7. By Paris, Parties need to define the basic regime principles and obligations of Parties that will be
laid down in the 2015 Agreement itself as part of the future rules-based regime.
8. Key principles that maintain the integrity of the commitments should be agreed both in Lima in
the INDC Decision (see Section B above) and should also be included in the 2015 Agreement at
COP 21:
a) Commitments should be transparent, quantifiable, comparable and verifiable.
b) Commitments should be defined in a way that allows for quantification in terms of tonnes of
CO2 equivalent.
c) Commitments should represent a progression from previous levels of ambition and scope
over time and Parties should maintain a mitigation commitment at all times.
d) Parties should aim to account for all significant emissions and removals of greenhouse gases.
e) Parties must define methodologies, rules and assumptions used to frame their commitments
(e.g. those used to calculate BAU projections).
9. In addition, the 2015 Agreement itself should include:
a) Recognise that accounting should include significant sources and sinks and be increasingly
comprehensive through progressive inclusion of sources and sinks over time.
b) A provision to ensure that once a gas, sector, category, activity area of land or pool is
accounted towards a commitment, it should continue to be accounted for in the future.
c) A provision that allows for the development of a comprehensive MRV framework that
specifies the information necessary to assess compliance with commitments and that this
information shall be reported in accordance with guidelines to be elaborated after COP 21.
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d)
e)
f)
g)
h)
i)
Such guidelines would define frequency of reporting and linkages to the reporting under the
Convention.
A provision on the use of common metrics and methodologies based on those accepted by
the IPCC and adopted by the COP.
A requirement for Parties to periodically report consistent time series of greenhouse gas
emissions and removals and to put in place and maintain national arrangements for
monitoring and reporting for the purposes of the 2015 Agreement.
A provision for the verification of such information in accordance with guidelines developed
by the COP after Paris once we gain more experience with International Consultation &
Analysis and International Assessment & Review. With regard to the assessment of GHG
inventories, review teams should provide a corrected estimation when inventory estimates
are missing or not based on agreed methodologies.
A requirement to be methodologically consistent between the reference chosen to define a
commitment and the calculations used during its implementation.
A recognition of the role of market mechanisms alongside two specific provisions:
• Providing for the international use of markets towards quantified commitments,
subject to the application of robust accounting rules which ensure that the
environmental integrity and the integrity of the mitigation commitments are
maintained and double counting is avoided and a requirement for Parties to
elaborate such rules including eligibility criteria;
• Providing for a UNFCCC defined market mechanism or mechanisms for the
certification of mitigation outcomes which promote scaled-up mitigation action,
entail a net contribution to global mitigation efforts and contribute to sustainable
development. There should be a requirement for Parties to elaborate modalities
and procedures for the mechanism(s) including participation criteria.
The key principles for accounting for the land-use sector, including:
• Avoidance of cherry picking, for example Parties should not only account for
removals by sinks but also need to include emissions by sources.
• Parties should account for fluxes of emissions and removals, or changes over time,
not for the stocks themselves.
• Parties could be able to use a voluntary provision to deal with natural
disturbances.
• Accounting for the land-use sector should be based on realistic and meaningful
reference levels in order to maintain the integrity of the commitments. Such
reference levels should mainly be based on historical data (i.e. base year/period);
or based on projections consistent with long term trends in historical emissions.
j)
A provision to allow for the development of rules on the circumstances under which
reference levels can be changed.
k) A provision establishing a compliance system applicable to all Parties along with its key
governing principles, the detail of which could be elaborated and adopted after COP 21.
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10. Finally, COP21 should establish work programmes to develop the more specific guidance
according to the principles and rules agreed in the 2015 Agreement. This will be necessary to
ensure effective implementation and should be completed before the entry into force of the
2015 Agreement.
Treatment of the rules-based regime in the co-Chairs' non-paper
11. Although many of the important elements of the 2015 Agreement's MRV, accounting and
compliance rules base are touched upon to some extent in the non-paper, it would facilitate
progress if those elements were to be further elaborated and time dedicated in the ADP in
October to more detailed discussions on the rules-based regime. We would like the range of
aspects of the rules-based regime fully reflected in the elements of the draft negotiating text we
will agree.
12. Furthermore, in the elements of the draft negotiating text, the sections on transparency of
action and on transparency of support should be separate (not combined as in the non-paper).
Although both elements are important to the 2015 Agreement, the substantive provisions in
these sections will be different. We would also like the section ‘transparency of action’ to be
called ‘transparency of action and accountability’.
13. It is important that the non-paper includes references to a compliance regime applicable to all
Parties. Effective implementation requires more than transparency alone. Linking the
compliance regime with the technical review in the MRV/accounting framework would allow the
compliance regime to assist Parties in the consistent implementation of their mitigation
commitments, MRV/accounting requirements and other commitments relevant for the
compliance regime, as well as to assess and address compliance.
COP Decisions in Paris
14. Parties should aim at developing MRV and accounting rules, including those that could
substantially impact the level of effort implied by commitments, through decisions at COP 21.
These may be further developed and improved over time.
15. Such COP Decisions could include:
a) A COP Decision agreeing that common metrics should be based on the 4th Assessment
Report of the IPCC and the common methodology should be based on the IPCC 2006
guidelines. It is worth noting that the IPCC methodology has a built-in tier system that gives
Parties flexibility in the way they measure their emissions and removals.
b) A COP Decision defining the rules for changes to the reference level a Party chooses. Such
changes should only be allowed in limited circumstances (e.g. changes should increase
ambition).
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c) A COP Decision on the land-use sector to define in more detail the accounting approaches
that are acceptable. For example, such a decision could agree that both activity-based
accounting and land-based accounting are possible as long as the methodologies to estimate
emissions and removals are based on those accepted by the IPCC. Parties should be able to
build on existing methodologies defined under the Convention and the Kyoto Protocol with
a view to starting a work programme after Paris in order to streamline and improve these
accounting approaches for use in future commitment periods.
d) A COP Decision on carbon markets that defines the detailed accounting rules and eligibility
criteria, and the modalities and procedures for a mechanism(s) along with participation
criteria. These decisions can build on the work ongoing under the Framework for Various
Approaches and the New Market Mechanism.
D. A CYCLE FOR REGULARLY STRENGTHENING MITIGATION AMBITION IN THE
2015 AGREEMENT
Overview
1. The 2015 Agreement and accompanying COP decisions should set out a process for regular
consideration and analysis of the level of ambition represented by mitigation commitments
against the below 2˚C objective (the cycle of commitments, distinct from the process to
establish, consider and analyse INDCs before COP 21). Defining a cycle of mitigation
commitments that promotes ambition over time is crucial.
2. The process needs to take place in the context of the latest science and with the objective of
ensuring that the 2015 Agreement puts us on a long term mitigation and transformation
pathway consistent with having at least a likely chance of ensuring that the below 2°C objective
is achieved. In that context, the 2015 Agreement should set out a long-term goal consistent with
the latest findings of the IPCC.
3. The process should encourage Parties to: (i) raise the level of existing mitigation ambition, if
necessary; and (ii) formulate ambitious subsequent commitments. The process needs to be
simple, efficient, avoid duplication of processes and be inclusive of all Parties. Only the Party
concerned may change in its mitigation commitment or the ambition of its subsequent
mitigation commitments.
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4. The following characteristics of the cycle should be included in the 2015 Agreement:
(i) The process should require all Parties to the 2015 Agreement to maintain a mitigation
commitment at all times in order to facilitate Parties to progressively increase their level of
mitigation ambition which should represent a progression from previous levels of ambition
and scope over time.
(ii) The process should take place regularly, be based on the latest science, apply to all Parties
and be facilitative. Furthermore the steps of the cycle should be applied to all Parties to the
2015 Agreement in the same year, so creating political moments which allow for
comparability and the mutual trust and confidence for Parties to be as ambitious as they can.
(iii) The 2015 Agreement should contain a simplified procedure to allow finalisation of
mitigation commitments, or adjustments of existing commitments, in a timely manner and
without the need for further formal ratification. The procedure should clarify that only the
Party concerned may propose a change in its mitigation commitment or the ambition of its
subsequent mitigation commitments.
5. In an accompanying COP decision agreed at COP21, we should be set out the details on
modalities of the cycle. This would allow the cycle to be easily strengthened over time if
necessary.
6. More specifically the decision should set out that the regular review of the ambition of
mitigation commitments, should:
a) be repeated every 5 years
b) be an international process that facilitates the transparency, clarity and understanding of
mitigation commitments, whereby the ambition and fairness of Parties’ mitigation
commitments can be considered in light of their contribution to the below 2°C objective
c) be facilitative, transparent and encourage Parties to come forward with ambitious
mitigation commitments or adjust existing commitments upwards
d) create a common understanding and enable comparison of mitigation commitments by
allowing Parties to explain their commitment and why they think it is fair and ambitious
e) be informed by science and be evidence-based, and also be guided by considerations of
evolving capability and responsibility
7. Further consideration needs to be given as to how the cycle could be facilitative and positively
build on wider opportunities.
The co-Chairs' reflections note
8. We consider the co-Chairs' reflections note of the June sessionv (the reflections note) as a basis
to further discuss how a post-2020 cycle of mitigation commitments could work, including in
relation to the matters raised above. However, we note some issues below.
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9. The EU is currently working towards a 2030 climate and energy package. Working towards this
timescale will help provide business certainty and investor confidence. This will not ‘lock in’ low
ambition. The mitigation contributions that Parties finalise in Paris should lock in only the lower
limit of ambition, not the upper. In that context a robust cycle of mitigation ambition within the
2015 Agreement that facilitates adjusting mitigation ambition upwards if necessary is needed to
ensure that all Parties collectively and individually stay on track to achieve the below 2˚C
objective. We work with a carbon budget approach in the EU, so our level of effort between
2020 and 2030 will be very visible. Commitments put forward by other Parties would need to be
equally visible.
10. The reflections note sets out options for a cycle of review based on the two proposed options of
10 or 5 year target periods. There is a real risk of chaos if Parties are able to pick different target
years, especially regarding ensuring comparability. We will need to consider this issue further.
But discussions should be limited to the two options of 2025 or 2030.
11. As stated above, all Parties should have the same process for a 5-yearly review. The mitigation
ambition of all Parties should be reviewed in the same year. This notion is not captured in the
reflections note.
12. Under the 2015 Agreement finalisation of new mitigation commitments, or upward adjustment
of existing ones, should be done using a simplified procedure.
Other processes that should inform the review of mitigation commitments
13. It is useful that the reflections note highlights that the ambition cycle could be informed by
other processes such as MRV of existing commitments, the periodic review under the
Convention, and the IPCC AR cycle. We should aim for maximising coherence and efficiency
throughout the whole process. However, the co-Chairs' diagram fails to acknowledge the need
to move to a common MRV framework over time.
14. In addition, the reflections note is not clear that when Parties come forward after 2020 with
future proposed commitments, those proposals must be accompanied with up front information
that meets agreed requirements.
E. ADAPTATION in the 2015 AGREEMENT
Introduction
1. Climate related hazards and altered hydrological systems are already impacting all countries,
especially those that are most vulnerable. Science shows that climate related impacts will
continue to grow and further exacerbate the impacts being experienced around the world.
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2. It is of utmost importance to act individually and collectively to reduce risk through ambitious
mitigation action and actions to prepare for and adapt to the adverse impacts of climate change.
Mitigation and adaptation are thus equally important to achieve climate resilient sustainable
development and the 2015 Agreement should aim at maximising synergies between them.
3. The co-chairs' non-paper reflects the range of views expressed by Parties and the EU is ready to
engage on that basis. Work and discussions in the run-up to Paris should focus on the elements
of the 2015 Agreement as well as how we can enhance and strengthen ongoing efforts in
supporting COP decisions.
4. Below we set out key ideas for what needs to be part of the Paris outcome on adaptation, as
well as setting out how to take adaptation forward to COP 21 and beyond. These ideas should
provide input and strengthen aspects of the co-chair’s non-paper.
What do we need to do in the ADP?
5. Towards reaching a successful outcome at COP 21, Parties must continue to engage on how to
best:
a) Recognise adaptation as an essential element to achieve the ultimate objective of the
UNFCCC as set out in its Article 2, its relationship and synergies with mitigation, it being part
of climate resilient sustainable development and that it relates to all Parties.
b) Promote measures to address climate impacts and risks to secure climate resilient and
sustainable development.
c) Facilitate planning and implementation of national adaptation measures with the objective
of increasing climate resilience of national sustainable development.
d) Build on and further the ongoing work under the Convention.
e) Promote coherence and cooperation at all levels and across related policy areas (e.g.
transboundary risks, systematic observation, early warning).
f) Strengthen and promote synergies with actors outside of the Convention.
g) Facilitate the mobilisation of means of implementation to support adaptation actions in
those countries that need it, especially those particularly vulnerable to the adverse effects of
climate change.
h) Enhance the monitoring and review of adaptation action and its outcomes to support
informed decision making and guidance by the COP as well as allowing for the flexibility to
incorporate and improve provisions in response to future evolution in knowledge and
experience (in line with the EU position outlined in the recent submission “Reporting
guidelines on national communications by Annex I Partiesvi”).
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Process to take forward and support adaptation actions
6. The process to take forward adaptation actions should comprise:
(i) Negotiation of the 2015 Agreement and supporting decisions to anchor and strengthen
adaptation provisions; and
(ii) Continued implementation of the Cancún Adaptation Framework (CAF), as well as continuation
of support (finance, technology, capacity building) provided bilaterally as well as multilaterally.
The 2015 Agreement:
7. The provisions of the 2015 Agreement should do three things:
(i) Recognise the global adaptation objective as “the achievement of climate resilient sustainable
development for all Parties”
(ii) Reinforce the commitments of all Parties
• to continue to formulate, plan and implement measures to facilitate adaptation in the
context of increasing the climate-resilience of their national sustainable development
• to communicate these through their National Communications.
(iii) Call to assist the efforts of those countries that need it and are particularly vulnerable to the
adverse effects of climate change, including through provision of financial and technical support
(including for capacity building).
8. Through these provisions, the 2015 Agreement will provide further visibility for action and
support for adaptation, and strengthen the monitoring and reporting provisions under the
Convention.
9. The 2015 Agreement should provide an anchor for the existing adaptation framework as a lot of
progress has been made. Parties should build upon the framework while furthering the work
under the Convention, including through the 2015 Agreement.
10. Together with related COP decisions, outlined below, these provisions would enable greater
understanding of the effectiveness of measures undertaken to facilitate adequate adaptation,
drawing on national reports and other relevant information, in order to inform further enhanced
action to be undertaken by Parties to address climate change.
Supporting decisions
11. More discussions will be needed to identify which provisions will be reflected in the 2015
Agreement itself and what would be in supporting decisions. Supporting decisions, building on
the CAF, could define milestones which could be useful to improve the effectiveness of national
adaptation action, including enhanced international cooperation in preparing and implementing
adaptation measures.
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12. Further guidance for Parties to improve the effectiveness of national adaptation action could
include:
a) facilitating joint learning to enable better monitoring and evaluation of the effectiveness and
outcomes of adaptation action.
b) the sharing of best practices and lessons learned relevant to assessment of climate risks,
planning for adaptation, management of climate risks etc.
c) providing guidance to facilitate integration of climate risks into national plans and strategies
with an aim to achieving climate resilience of their sustainable development.
d) setting timelines for Parties to achieve certain milestones such as integration of climate risk
assessments into national development planning.
Continued implementation of the Cancún Adaptation Framework
13. Given the extensive work undertaken to date the 2015 Agreement has to recognise that action
on adaptation does not start from scratch. The continued implementation of the provisions
under the CAF must play a central role in taking forward adaptation:
a) The Adaptation Committee (AC) is the overall advisory body on adaptation under the
Convention and will continue to act as the main player for more coherence on adaptation
under the Convention. It has already started and will continue delivering results in this
regard.
b) The National Adaptation Planning (NAPs) process plays an important role in contributing to,
and where possible facilitating, the adaptation efforts that countries themselves are
undertaking to address the impacts of climate change in the broader context of their
sustainable development. The NAPs process supports LDCs, as well as other developing
countries, in their medium and long-term adaptation planning processes including by
integrating adaptation in their general development planning. The EU is committed to
continuing to support LDCs and other developing countries, in their efforts to enable them
to realise their adaptation objectivesvii.
c) With the newly established Warsaw International Mechanism on loss and damage a space
within the Convention was provided to further enhance the understanding of
comprehensive risk management approaches, to strengthen the coordination among
stakeholders and to enhance actions and support to address loss and damage. The EU is
confident in the Executive Committee´s efforts to implement its workplan, which once
adopted will facilitate adequate and timely responses to reduce the risks of and address loss
and damage.
14. In addition, the Nairobi work programme (NWP), undertaken under SBSTA, assists all Parties (in
particular LDCs, SIDS) in sharing information and building knowledge on impacts, vulnerability
and adaptation to climate change in order to facilitate informed decisions on practical
adaptation actions and measures. While striving for improving the NWP work, including in
addressing emerging issues, the NWP will continue to serve as a knowledge hub and will support
and strengthen the CAF (Loss and Damage, NAPs, AC) whilst avoiding duplication of functions.
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15. Financial support to adaptation actions is provided bilaterally as well as multilaterally, amongst
others by the Adaptation Fund, the Least Developed Countries Fund (LDCF), the Special Climate
Change Fund (SCCF), and including through support to enable mobilisation of private sector
financial flows for adaptation investments. The Green Climate Fund, which was mandated to
channel a significant share of new multilateral funding for adaptation, should provide assurance
of support to the efforts of countries to become more resilient to the impacts of climate change,
e.g. with its own "adaptation window" and the decision to aim for a 50:50 balance between
mitigation and adaptation over time and a floor of 50% of the allocated adaptation funding to be
channelled to vulnerable countries, including least developed countries, small island developing
States and African States.
F. FINANCE in the 2015 AGREEMENT
1. Our agreed objectives are staying below 2°C and the transformation to low-emission and
climate-resilient economies and societies. Means of implementation are crucial for achieving
this goal, as well as for supporting the particularly vulnerable, including least developed
countries. Climate finance will therefore be an important part of the 2015 Agreement.
2. Climate finance is a means to an end. The 2015 Agreement has to provide the framework for
shifting investment patterns towards low-emission climate-resilient sustainable economies and
societies. The 2015 Agreement should send clear signals to the private sector and beyond, to
contribute to the mobilisation of climate finance and to reorient financial flows to that end.
3. The EU also stands by its own responsibilities, including enhancing our own efforts, not least in
providing and mobilising international support. Public finance will continue to play an important
role in climate finance post 2020. However, public climate finance alone will not be able to get
us on track for staying below 2°C and bring about the transformation and investment shifts
needed. The IPCC recognises that up to 2029 we need to shift about US$690 billion every year of
largely private investments in the energy sector alone towards low-emission alternatives. The
2015 Agreement therefore needs to reflect the importance of the private sector as a source of
finance and relevant investment flows for the transformation to a low-emission and
climate-resilient world. We recognise that private sector finance is complementary to, but not a
substitute for public sector financing where public finance is needed.
4. There is a role for all Parties to take actions regarding climate finance in line with evolving
responsibilities and capabilities. This does not mean that all Parties should take the same
actions. Finance-related actions in the 2015 Agreement should be differentiated. Some actions
should be undertaken by all Parties, while other actions should be undertaken by more capable
Parties, with the number of Parties participating increasing over time. Some parties may need
support in order to take action, for example some might need international support for capacity
building. The need for support may change over time or be met with different means of support.
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5. The range of actions spans from the domestic level to the international level and this diversity
should be captured in the 2015 Agreement. Actions could range from improving domestic
enabling environments for facilitating climate-proof investments to mainstreaming climate
considerations into all policies, promoting the effective use of resources ensuring impact, and
mobilising international climate finance. These actions will be an important part of sustainable
development. The following diagram shows a possible range of actions on mobilising different
sources and on mainstreaming and enabling environments, in relation to evolving
responsibilities (for climate change) and capabilities of Parties:
most capable / responsible Parties
all
Parties
6. The 2015 Agreement should reflect the need for global participation in order to effectively
mobilise and facilitate the deployment of finance for climate-related actions globally and should
encourage all countries in a position to do so to contribute to international climate support and
finance for the implementation of action.
7. The 2015 Agreement needs to be dynamic and able to adapt to changing realities and future
developments also in respect of climate finance, reflecting evolving capabilities and
responsibilities in this regard.
8. The 2015 Agreement should build on the Convention and existing institutions, but it also needs
to identify the means by which we can enhance climate finance and reorient investments
towards our overarching objective.
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9. The 2015 Agreement should capture the following:
a) Anchor the purpose of climate finance as a means to staying below 2°C and to achieve the
transformation required.
b) Mobilise climate finance through a diversity of actions by all Parties, according to their evolving
respective responsibilities and capabilities.
c) Recognise the role of finance from a variety of sources, including public, private and alternative
sources. Send a strong signal to the private sector at all levels and trigger the required
investments and involvement, including of local private sector. Public sector finance should seek
to catalyse and avoid crowding-out private sector investments. Private climate finance includes
financial flows that are mobilised by public intervention, including in the sphere of policy and
regulatory reform.
d) Create and improve enabling environments and policy frameworks for low-emission and
climate-resilient investments as a key means to facilitate the mobilisation of both domestic and
international climate finance at scale. This could include for example the phasing down of high
carbon investments and fossil fuel subsidies. All Parties implement and/or improve or more
broadly apply the pricing of GHG emissions making use of the range of tools available for
reflecting their costs sector-wide and economy-wide, with a view to ensure a level playing field
for all.
e) All Parties undertake continuous efforts to climate-proof international public finance flows and
enhance addressing climate change in the coordination of development aid, keeping in mind a
gender sensitive approach.
f) Integrate climate objectives into other policy relevant areas such as energy, agriculture, (urban
and land-use) planning and transport in order to facilitate the transformation to low-emission
and climate-resilient economies and societies. Mainstreaming of climate objectives would need
to take place at a larger scale and be fostered by all Parties as well as by all the relevant
institutions outside the Convention through strategies, mechanisms, and/or financial
instruments to reduce risks and/or improve incentives for low-emission and climate-resilient
investments.
g) Assist the efforts of those countries that need it and are particularly vulnerable to the adverse
effects of climate change, including through provision of financial and technical support
(including for capacity building).
h) Anchor a dynamic element to be able to adapt to future needs and changing realities and future
developments also in respect of climate finance reflecting evolving capabilities and
responsibilities.
i) Ensure that climate finance will be focused on results and delivers the greatest impact possible.
j) Build on the Convention and the existing institutions and architecture, in particular the GCF as a
major player in post-2020 climate finance and further enhance its effectiveness.
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k) Improve transparency and reporting on the range of flows and actions and results that
contribute to climate action. When elaborating such an improved tracking and reporting
framework, duplication should be avoided and it should be ensured that the underlying
approaches can be applied by all relevant actors so that the resulting data are comparable and
consistent among all contributing Parties and other providers of data like MDBs, while
supporting trust and credibility among Parties This requires strong cross-coordination and
collaboration between all relevant bodies under the UNFCCC to make best use of all existing
expertise and knowledge.
l) Foster country ownership as key for designing and implementing ambitious climate policies as a
basis for enhanced support, both in the areas of mitigation and adaptation. Low-emission and
climate-resilient development strategies are key to guide countries efforts.
i
ADP.2014.6.NonPaper, 7 July 2014
ADP.2014.7.DraftText, 7 July 2014
iii
This submission should be read together with the previous submissions of the European Union and its
Member States in relation to Workstream 1 of the ADP.
iv
Throughout this submission '2015 Agreement' refers to the legally binding agreement to be adopted at COP
21 pursuant to the Durban mandate.
v
Reflections on progress made at the fifth part of the second session of the Ad Hoc Working Group on the
Durban Platform for Enhanced Action, Note by the Co-Chairs, 7 July 2014
vi
Submission by the European Union and its Member States of 26 August 2014.
vii
The EU submissions dated 13 February 2012, 19 September 2013 and 26 August 2014 provided a multitude
of examples on how the EU supports different phases of adaptation planning in developing countries using a
variety of different channels and implementing modalities.
ii
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