Tag: Measurement Reporting and Verification

MRV and the Virtues of Clarity

As we look closely at the current state of the negotiations, the LCA text released over the weekend falls short of the advances we need on both clarification and accounting. Without more progress this week the environmental integrity of the regime will decay if not disappear altogether.

Amidst all the talk of lack of ambition, one would think that the far from sufficient pledges in hand today would at least be solid. But we don’t clearly know what is in the pledges and the foundation on which they supposedly stand – a solid accounting framework – is also at risk.

Here’s why we care about clarification of pledges. Recent workshops showed that countries have not been very forthcoming about their pledges, including underlying methodologies and assumptions. This is a serious problem for tracking progress towards both domestic goals and global temperature targets – and that’s at the heart of the matters before us, right?

We are looking at real challenges to understanding aggregate reductions, a key input into the 2013-2015 review.

And that’s not all. Without more transparency, it will also be difficult to avoid double counting of emissions reductions. So let’s review piece by piece where the text falls short.

Regarding Annex I targets, the text calls for workshops, a technical paper, and a template to be filled out by Parties (Chapter IIA, Para 9).

This is a good start, but the template should also request Parties to be forthcoming about market-based mechanisms accounting methodologies, procedures to avoid double counting, the use of uncovered sectors or gases acting as domestic offsets (if applicable) and related methodologies. And the template should be included in the Durban decision..

On non-Annex I actions, the text invites Parties to submit information on their actions (Chapter IIB, Para 23).

However, an invitation alone will not necessarily result in the information necessary for tracking performance. The COP should also create a mandate for non-Annex I Parties to provide information through the completion of templates or questionnaires, with capacity support as needed. These should be specific to various pledge types, given the diversity of actions.

Lastly, SBSTA should establish a process on how these details should be reported in biennial reports, and define adjustment procedures so Parties don’t just change assumptions and methodologies willy nilly with no real justification.

Now here’s why we care about accounting. Accounting for emission reductions is at the heart of environmental integrity of the climate regime. If done in a transparent, consistent, comparable, complete, and accurate manner, accounting ensures comparability, the ability to add up and assess global emissions reductions, and quality in the carbon market.

And here’s where the text falls short. On Annex I, while the text acknowledges the need for a common system for measuring progress (Chapter IIA, Para 14), the text does not refer to the word “accounting”, leaving the text fuzzy and vulnerable to co-opting. 

The text further calls for a work programme to establish such a system but fails to mention “common” and “accounting”.

And a work programme is not necessary for Annex I targets, considering the experience we have gained through the Kyoto Protocol. There is no date by which the work programme is completed, so clearly these elements are just tactics for delay.

So to recap, If we are to preserve any environmental integrity of this regime, provisions for clarification of pledges and proper accounting needs to be strengthened this week.

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Guide to De-Bracketing MRV

ECO is here to help negotiators remove some brackets from that new MRV text that is hot off the press, and insert a few critical items that Parties have somehow forgotten.

So pick up your erasers (or warm up your Delete keys) and let’s get to work!

Stakeholder participation – Observer participation is still bracketed in the ICA and largely absent or conditioned in the IAR. Inexcusable! Stakeholders, including NGOs, businesses and municipalities, have a right to participate and contribute important scientific and technical information to the negotiations.

Accounting and compliance – These two words seem to be toxic to some developed country parties, like the USA and Canada, but including them in international assessment and review (IAR) is fundamental. The IAR must review the accounting of emission reductions and lead to future compliance mechanisms under the Convention. You can see where things go otherwise; the lack of good accounting and compliance played a big role in the financial crisis.

Adjustments – A tonne is a tonne is a tonne. Not only do we need common accounting rules, in the IAR technical review, the review teams need to be able to adjust data when the rules aren’t followed. Brackets around adjustments – off!

MRV and the Review – Biennial reports, biennial update reports, and the IAR and international consultation and analysis (ICA) processes are key to providing an accurate picture of global emissions for the 2013 Review. This link is reflected in the IAR preamble but inexplicably has been deleted from the ICA preamble. This link and an appropriate timeline should be agreed. Developed country reports should be in by 1 January 2013 and developing country reports on 1 January 2014; and the IAR and ICA should start in May 2013 and May 2014, respectively. This timeline is crucial for providing effective input in the review process.

Developed country Biennial reports – It is troubling to see that the information on LULUCF and market mechanisms for developed country targets is bracketed. Remove the darn []’s! We need the information and it should be based on common rules.

New and additional finance – A key part of enhanced transparency in climate finance is defining “new and additional”. So don’t forget to keep that box in the Common Reporting Format for finance;.

National Communication guidelines need updating all around. Parties must agree in Durban to update the guidelines for both developed and developing countries. Currently, the text only has a provision for revising developed country guidelines.

Low Carbon Development Strategies – Most Parties seem to be forgetting paragraphs 45 and 65 from Cancún about low carbon plans, even if a lot of countries are moving forward domestically with them. Biennial reports focus on what has been achieved; but planning for a decarbonized future is crucial and that is where these strategies come in. We need a process to report on the development of those plans and share best practices.

Response measures don’t belong in IAR. (Do we need to say it again?) Consideration of the adverse impacts of mitigation actions is already done more than adequately as part of the annual review of GHG inventories. It has no place in the IAR process. This is a climate change convention, after all.

REDD+ reporting – A summary of REDD+ activities, including actions, methodologies, accounting and safeguards information systems, should be included in Biennial Update Reports and NatComms.

Beyond the text itself, countries could move the process forward if they made some concrete announcements. Take for example the USA. For all its rhetoric on transparency, they have yet to put forward serious money to support developing country biennial reports and the ICA process. The entire developed world has an interest in and an obligation to support these initiatives. Announcements of support in Durban would go a long way to ensure robust guidelines are adopted.

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The A-Z of MRV

Robust measurement, reporting and verification (MRV) is a critical part of the Durban outcome. But 24 hours before the new text is out, with Parties hard at work, ECO is concerned that key MRV elements are at risk of falling off the table.

First, let’s review the fundamentals: The reason we’re all learning the MRV alphabet soup is to support the implementation of commitments and actions, build confidence and ensure the environmental integrity of the regime. Seems obvious, right? Yet some of the proposals on the table would seriously undermine these objectives.

In addition, MRV must respect the framing principle of ‘common but differentiated responsibilities and respective capabilities’ and reflect differentiation between developed and developing countries while aiming for good reporting from both. ECO worries that some developed countries are trying to erase those lines. 

And finally, as critical as MRV is to the Durban outcome, it’s just one piece of the picture whose outlines were drawn by the Bali Action Plan. MRV must always be viewed as part of the bigger picture of increased mitigation,
finance, technology transfer and capacity
development commitments.

Critical MRV elements that must be in the Durban outcome include:

  • Procedural transparency and meaningful stakeholder participation, including the ability to make written submissions to technical analysis experts and the SBI; pose questions in an SBI review session open to Parties and observers, and unrestricted access to all information (inputs and outputs).
  • Common accounting rules on emission reductions and enhanced removals for Annex I countries.
  • A process to clarify the assumptions underlying the pledges of all countries (e.g. gases, sectors, base years, assumptions on BAU) to be able to accurately assess the gigatonne gap and ensure comparability for Annex I countries. (More coming from ECO on these hot button issues.)
  • MRV outputs must be timely and include enough detail to enable a meaningful first periodic review between 2013 and 2015. Biennial reports, biennial update reports, and the first international assessment and review (IAR) and international consultation and analysis (ICA) should be completed as early as possible in 2014.
    Enough detail must be provided in biennial reports (BRs) and biennial update reports (BURs) to conduct an effective global assessment, including clarity on assumptions, underlying pledges and projections until to 2050, in 10-year increments.
  • The technical review teams, SBI and the COP should have the ability to comment on the status of implementation and issue recommendations in order to assist Parties in the implementation of their pledges and to improve reporting.
  • A compliance process for Annex I countries, including consequences for non-compliance such as suspension from the flexible mechanisms.
  • Improved MRV of finance through the adoption of a common reporting format in biennial reports and in the future revision to the guidelines for national communications.
  • Enhanced support for developing countries to produce their biennial update reports and national communications, and to participate in international consultation and analysis (ICA).
  • A summary of REDD+ activities, including actions, methodologies, accounting, safeguards and information systems should be included in biennial update reports and national communications.
  • Time-specific provisions to revise guidelines for national communications by COP 18 and for BRs, BURs, IAR and ICA based on lessons learned, by COP 22 in 2016.
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