ADP Mitigation Section: General Thoughts

Although the text is currently far from complete the agreement will require nations to submit - at a timeframe to be determined - actions to mitigate climate change. These actions will become binding after having been subjected to a non-binding ex-ante peer review process. As these actions are nationally determined nations are really free to include whatever they like. However to aid with the peer review process I think the agreement should mandate key areas that are covered in a standard form.

Type: As it stands the negotiating text suggests numerous variations of the idea that developed nations submit Absolute Emission Reduction Targets (AERT's) while developing nations submit Diversified Enhanced Mitigation Actions (DEMA's). However in none of the 12 pages of discussion does it define in a workable way what either an AERT or a DEMA is or how nations will transfer from providing DEMA's to providing AERT's over the course of the 80-100 year lifespan of the agreement.

Therefore I think it is best to do with away with the division and get all parties to submit their action plans in the same format. However part of that format will allow them to state whether their action represents an absolute reduction in emissions, a reduction of emissions as a percentage of economic growth (Intensity) or a combination of both. Obviously the agreement itself will have to include to obligation for nations who committed to absolute reductions under the Kyoto Protocol - or would have done if they'd signed up (America) - to continue to commit to absolute reductions under this new agreement.

Scope: Simply what gases are covered. With the Intergovernmental Panel on Climate Change (IPCC) spending decades researching and drawing up a standard inventory of Green House Gases (GHG's) I obviously think that this standard should be adopted for all actions. However I appreciate that maintaining such an extensive inventory will be particularly onerous for many of the less capable nations.

For example Morocco in their submission have excluded F-gases on the grounds that Morocco's current emissions in this area are negligible at best. However I feel that I should point out that F-gases are mainly used refrigeration and air-conditioning products. Being a warm country as the Moroccan economy grows and the costs of production fall this is the sort of thing that more and more people are likely to buy and then need repaired and eventually disposed of causing emissions in this area to grow. Therefore it is good science to measure the current level to make it easier to assess and respond to any change in the future.

At the same time there is debate as to whether the IPCC inventory is as exhaustive as it needs to be. For example in their submission Mexico has gone beyond the IPCC standard to include Short Lived Climate Pollutants (SLCP's) such as black carbon. As these react relatively quickly with other elements in the atmosphere and disappear they are not included in the IPCC inventory. However they do have an effect on global temperature and a much more significant effect on people's health in terms of things like smog. As such counting them alongside traditional GHG's helps to make the point that the costs of mitigation action are off-set by wider benefits to society in terms of human health.

All of these different positions will of course make for interesting and hopefully capacity building discussions during the peer review process. As such I'm not certain the agreement should limit parties to a standard scope providing they understand that they will have to justify their decision to their peers during the review process. In terms of a specific clause in the text I think we're playing around with synonyms of "Encouraged" versus "Obligated."

Coverage: The sectors of the economy to which the reductions apply. As with scope the IPCC has spent decades developing rules governing what and how emissions are measured in certain sections of the economy. With the exception of China all of the submissions I have read so far apply this IPCC standard. As such I think that it should be the compulsory minimum standard applied to all submissions. After it shouldn't place much of an extra obligation on less capable nations such Ethiopia because if they don't have one of the standard sectors in their economy that part of their submission can simply read; "Non-Applicable."

However again as with scope there is debate as to whether the IPCC standard goes far enough. For example it still doesn't provide a standard measure for how land use such as forestry is accounted for and it is for political rather then scientific reasons that emissions from aviation are not currently counted. Therefore I think the agreement needs placeholders to allow for those issues to be resolved at a future point. How nations choose to deal with those sectors within their submissions until will of course help the process move towards a solution.

Baseline: Obviously if a nation is making any sort of reduction we need to establish the level from which they are reducing. This is an area that has already produced rather a lot of cheekiness.

For example the US has pledged to make a 28% reduction from the 2005 baseline while the EU has pledged to make a 40% reduction from the 1990 baseline which on the face of it sounds much more ambitious. However if you get into it the EU has already reduced it's emissions by 20% from the 1990 baseline meaning that it's reduction from the 2005 baseline is only 20% - 8% less ambitious then the US. Given the calibre of the people involved in the peer review process this type of accountancy trick isn't going to fool anybody for any length of time. In the interests of making a process that has to deal with many more, far more complex issues run as smoothly as possible I think that there should be a standard baseline year and that year should be 1990 when many nations began making reductions under the KP.

However the nations that are making intensity reductions rather then absolute reductions are not working from a baseline year. Instead they are working from a prediction of what their growth in emissions would be under a Business As Usual (BAU) scenario. Also developed nations like the Republic of Korea (RoK) and Lichtenstein make the entirely valid point that while other nations were mucking about they were taking the issue very seriously and have already taken drastic action to dramatically cut their emissions. As a result their absolute reductions in future are going to be relatively tiny compared to the reductions made by nations who have arrived late to the party. Therefore their continuing commitment is better reflected by the reductions they make from BAU.

As such I think that all submissions should include a baseline year and a BAU baseline. Considering both factors gives a wider and therefore more accurate picture of each nation's situation. It will also help identify when nations should transition from making intensity reductions to making absolute reductions and the overall objective of the agreement is to reach a point where nations reach zero emissions making further absolute reductions impossible.

Time Frame: How long each submission lasts for. Although there has been a lot of debate over this issue based on the submissions I've read so far I think there is a universal agreement that they will last for 10 years with only the US opting for the 5 year time frame. Given the rate at which governments tend to change this has always struck me as the appropriate length of time. However I also think that there should be an ex-post review process at the half-way - 5 year - point to help nations assess how their current action plan is working and help prepare for the next commitment cycle.

Reduction: It almost goes without saying that each submission must include a reduction figure. Obviously this should be both a percentage and include - in an easy to read format - supporting figures showing how that percentage was arrived at. So if for example a nation is claiming a 40% absolute reduction on 100 tonnes they will show that the total at the start was 100 tones and the total at the end is 60 tonnes.

Metric: Although a variety of GHG's are measured they are all calculated in accordance with their Global Warming Potential. With the exception of China who have made no reference to how they intend to do this all the other submissions I've read use the metric laid out in the IPCC's 4th Assessment Report. Therefore I think the agreement should mandate "The latest IPCC report" as the standard metric.

Methodology: Obviously it is not possible to measure the exact emissions from every single car, refrigerator, cow etc so assumptions need to be made. Again the IPCC has produced extensive guidelines on how to do this so I think the latest IPCC guidance should be mandated in the agreement.

The problem arises with intensity targets which are based on the IPCC standard being applied to predictions of economic growth. As far as I am aware there is no global standard of how to predict economic growth and some of the methods used are notoriously unreliable. For example during the 2010-2015 Parliament I don't think the UK government got a single one of its growth predictions right.

As a result I have no idea how to standardise growth predictions within the submission. However I think that it should be mandated that all submissions provide a detail explanation of how their predictions have been reached in order to allow them to be assessed by the peer review process. This may even lead to a harmonised methodology being created.

Means of Implementation (MoI): Simply how the party making the submission intends to achieve its pledged reduction. This can vary wildly from nation to nation.

For example in command economies such as China where the government does everything they simply state that they are going to include the reductions in their national plan and then implement their plan. However in democratic nations such as the US where the government merely establishes the regulatory framework in which the private sector operates the process is more complicated with existing regulations having to be tightened and new laws passed alongside the government applying policies in sectors of the economy which is it is active such as road construction. In some of the least developed nations such as Ethiopia many of the MoI will simply involve working with stakeholders to educate them in more efficient ways to harvest firewood and use cooking stoves.

Although I personally have a preference for democracy the purpose of the agreement is to combat climate change rather then fight some great battle of political ideology. So along with the fact that even within the same nation there will be a wide variation in MoI I am happy to give nations free reign in this area rather then mandating a standard set of rules.

However I would say that where the MoI involves applying existing legislation or creating new legislation rather then simply providing a list of legislation like the US has done it would really help the review process if nations could explain how each specific piece of legislation relates to a specific sector of the economy. For example the US government recently thought that certain sections of the Clean Air Act could be used to regulate mercury emissions from power stations. The Supreme Court disagreed in a lengthy and detailed ruling that I am going to have to read at some point. Being aware of this sort of weakness in a policy would really help the ex-ante review assess how credible a claim is and help weed out flawed submissions before they become legally binding targets.

Market Mechanisms: Within negotiations there is currently something of an ideological split over whether market based mechanisms such as Carbon Credit Trading Schemes (CCTS) can be counted as a MoI. As such I think it is important that nations state seperately whether then intend to use market mechanism as a MoI or not. And if they do to what extent.

Furthermore they should state whether they intend to use a domestic mechanism such as the US state of California's carbon market or an international mechanism such as the EU-wide carbon market. After all we can't have a situation in an international market where both the nation selling a carbon credit and the nation buying the carbon credit count the same emission reduction as part of their total.

Although the Clean Development Mechanism (CDM) provides some guidance as yet there is not a unified set of rules of how market mechanism work and how they are accounted for. Therefore beyond stating what type of market mechanism is being used nations submissions should also include an explanation of how the market mechanism functions. Hopefully through the peer review process this will help formulate a standard guidance document that can be referenced in the same way IPCC guidance is referenced in the areas of scope, coverage, metrics and methods.

Conditional/Additional: While I think the agreement should make clear that all nations, regardless of circumstance, have to make some effort of their own to mitigate emissions I think nations should be permitted to include a conditional section. This would detail reductions that would otherwise have to be delayed until the next commitment cycle unless they recieve additional outside support in order to implement them sooner. The rules of how this conditional portion are measured and presented will obviously be the same as the unconditional portion.

Also nations such as Lichenstien, Singnapore and the RoK have made the point that because of their extensive work in the area already any further reductions they make are likely to be highly cost intensive. Therefore it would be more efficient for them, and all around, to provide money to allow other nations to reduce their emissions rather then battling to reduce their own. After all it makes more sense for, say, the RoK to spend USD1million to reduce the emissions of five different nations by one tonne rather then spending the same amount of money reducing their own emissions by a single tonne.

Obviously to avoid double counting any emission reduction can only be counted by the nation where the reduction has taken place. However the nation that has provided the money to allow the reduction to take place should also receive some credit. Including an conditional/additional section allows them to show their peers that although they may only have been able to deliver a 0.5% reduction in their own country they have also facilitated a 2% global cut.

Percentage of Emissions Covered: With the format allowing for both absolute and intensity reductions alongside slight differences in scope and coverage I think it is important for submissions to include a section explaining the percentage of total emissions that the stated reduction applies to. For nations that are making absolute reductions based on the full scope and coverage this will always be 100%.

However for nations that are making intensity reductions based on limited scope and coverage the picture is more complicated. For example - while I'm happy for people to check my working out - Ethiopia's contribution will see all emissions rise by some 22,000% despite the reduction. Displaying this information clearly and uniformly will help the peer review process to identify nations that perhaps need to start making the switch from intensity reductions to absolute reductions.

Obviously nations in that sort of position will not be keen to have their increase in emissions highlighted so clearly. However I am confident that the peer review process will understand that the agreement does allow for this sort of rise. After all a 22,000% increase is still better then a 23,000% increase and a 100% increase on 1 tonne is much the same as a 1% increase on 100 tonnes.

Therefore as with the reduction figure itself this percentage of total should include the figures used to calculate the percentage alongside the percentage itself.

 Adaptation: Obviously the agreement needs to include a seperate section dealing specifically with adaptation and that will be my next job. However I think that adaptation actions should be included in the same national submission alongside mitigation actions.

Quite apart from the fact that certain actions such as re-forestation are both mitigation and adaptation actions my vision for how these submissions will work is that they will provide a snapshot of how each nation is being affected by climate change and what action it is taking to respond to those challenges. So for example if a nation has to take urgent adaptation action to prevent a significant proportion of its population being killed this should be presented alongside any mitigation action because the peer review process will be able to recognise that the need for urgent adaptation action will inhibit a nations ablity to carry out mitigation action. It may even facilitate increased funding for those most in need.

Adaptation obviously covers a wide range of actions because the way you would adapt to flooding is obviously markedly different to the way you would adapt to drought. As such I don't think it is really possible, or beneficial, to lay out a standard format of how adaptation actions are presented. However in order to promote capacity building within the peer review process it is essential that all nations, even developed ones that need no help with adaptation and may not even have any real need to adapt include examples of adaptation actions they are taking.

Emissions Pathway: I almost like to think of this agreement as a 80-100 year novel where we all know the ending will be us achieving the reductions needed to keep global temperatures below the 2/1.5C rise so everbody can live happily ever after. The submissions made for each commitment period are like the chapters in which we lay out how the story develops to allow us to get to the ending.

As such I think each submission should include an emissions pathway estimate to show how the chapter fits into the narrative arc. Obviously making predictions this far into the future is very difficult so this should only be a rough, non-binding guide. Both Singapore and Mexico have been able to provide examples of how this can work in practice with Singapore indicating that their emissions will peak at the end of the second 10 year commitment cycle allowing them to move to absolute reductions for the subsequent cycles while Mexico is predicting a similar transition around the start of the 5th cycle.

You may have noticed that the criteria I've selected are remarkably similar to the criteria included in the template that was circluated at COP20. However I have excluded some like "Fair & Ambitious." I think this is quite an abstract concept to include in a standard submission form for a series of scientific calculations. However throughout the agreement there is text requiring that national submissions are both fair and ambitious. Therefore while they may not choose to include it as a specific section parties do need to be aware that they will have to be able to justify their actions as both fair and ambitious to their peers as part of the review process.

Having considered the general concepts behind the section I will now have to develop approptiate language to allow the agreement text to function in such a way as to fulfill these concepts. That seems likely to be quite challenging because while I will re-read it again the 11/6/15 draft seems to have gone off in a completely different direction. As such I'll probably be going back to the COP20 draft although even that only seems able to offer loose guidance rather then concrete options at this point.

15:15 on 10/7/15 (UK date).