leverje
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2005-04-07T11:41:10Z
European Commission
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Towards a comprehensive and ambitious post-2012 climate change agreement |
1. Background information |
I reply: |
On behalf of an organisation or an institution
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I reply on behalf of |
NGO (international, national, regional or local)
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Full name of organisation and Register of interest representatives ID number |
Finn Church Aid |
What is your country of residence/country where your organisation or institution is based? |
Finland
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2. The climate change challenge - a shared vision for the 21st century development |
Would this aspirational long term goal be appropriate in the light of the 2007 IPCC reports and latest scientific knowledge? (max 4000 characters) |
It is Finn Church Aid’s experience that people in developing countries are already suffering considerable impacts from the changes in the climate that the IPCC attributes to manmade greenhouse gas (GHG) emissions. For the poorest and most vulnerable people dangerous climate change is already a reality. Clearly in this case the UNFCCC – and the EU which often drives the ambition of the UNFCCC – must limit anthropogenic interference in the climate to the lowest possible level. Keeping global warming as far below 2°C is therefore a vital and important goal for the climate talks. However, the 50% reduction in global emissions is based on a stabilisation goal for GHGs of 450ppm, which the IPCC reports suggest only has a 50% chance of keeping us below 2°C. Science produced after the IPCC report indicates that such a goal is too conservative and the EU should raise its ambition to a far more precautionary level. Finn Church Aid recommends that the EU seeks a global emissions pathway that peaks before 2015 and declines rapidly to some 80% below 1990 levels by 2050. This would offer a maximal probability of around 25% of staying at or below 2°C. Clearly such a global pathway requires a heroic effort, but it is necessary if the world is serious about staying below the two degrees target. Such a pathway implies that the EU must commit to an urgent and rapid decarbonisation of its economy, of the order of a 40% cut on 1990 levels by 2020 and at least 80% cut – but preferably more like 95% – by 2050. But its responsibilities cannot end there. In order to achieve such a global pathway, emissions will have to come down in a number of countries that do not have significant historical emissions but do have a significant burden of poverty that needs to be their priority. The EU and other industrialised countries must commit to support emissions cuts in developing countries in order to achieve this global pathway without the injustice of shifting its burden onto the backs of those who are poor and have least ability to pay. The less action the EU and other industrialised countries take at home, the greater the burden on them to support emissions cuts overseas. For more information see: http://www.ecoequity.org/GDRs/GDRs_presentation_with_notes.ppt. |
Is there a need for other elements to be part of the shared vision in order to ensure the transition to a sustainable low carbon economy? (max 4000 characters) |
Yes. Limiting the changes in the climate is required in order to limit the impacts on global society. While populations in industrialised countries, like the member states of the EU, have the resources and the resilience to bear the short term costs of cutting carbon emissions and the costs associated with the impacts of climate change, this is not the case in many poor countries. Therefore, a long term climate goal only makes total sense if it is placed in the context of actions that explicitly safeguard the right to economic development for the poorest and most vulnerable – those who have contributed least to the problem we now face. The transition must be a fair and equitable one. Therefore the shared vision must include substantial financial, technical and capacity support for developing countries to ensure that they can both decarbonise their economies (mitigation) and cope with the impacts of climate change (adaptation) without significant additional costs that would undermine their development aspirations. |
3. Mitigation commitments by developed countries |
What should be the criteria for allocating emission reduction efforts among developed countries, considering also the need to ensure the "comparability of efforts" as agreed in Bali? (max 4000 characters) |
Finn Church Aid believes that – in accordance with the UNFCCC statement that dealing with climate change calls on all countries to cooperate based on ‘common but differentiated responsibilities and respective capabilities’ – all countries should be asked to take action on climate change that is commensurate with: • Their responsibility for climate change – based on the quantity of historical emissions they are responsible for; • Their capacity to act – based on income per person; • And above all not violating the right to development – anyone below a basic development threshold has to concentrate on escaping poverty and cannot be reasonably expected to contribute to tackling climate change. Clearly, the EU view is insufficiently ambitious in two senses to deliver its own stated long term goal of limiting global warming below two degrees. Firstly, as discussed above, action of the order the EU is proposing is based on insufficient level of global action and carries an unacceptable risk of catastrophic levels of climate change. Secondly, action of the order the EU is proposing shifts far too much of the burden on to other countries – who still need to focus on the issue of development. These countries, who have limited responsibility for the emissions currently changing the climate and the majority of the world’s population, as well as significant burdens of poverty, cannot be expected to take on unreasonable share of action on climate change. Therefore, leadership by industrialised countries must require significant decarbonisation – 40% cuts by 2020 and 80–95% cuts by 2050 – and significant support to allow cuts by developing countries. |
4. Mitigation actions by developing countries |
What type of mitigation actions should developing countries undertake? How should these be measured, reported and verified? What should be the scale and legal nature of these actions? How should differences in responsibility and capability of different developing countries be taken into account? (max 4000 characters) |
Finn Church Aid believes – as set out above – that all countries should contribute to action on climate change at a level commensurate with their responsibility and capacity. However, it is of the uttermost importance to take into account the need to respect the right to development of the people in developing countries as well as the by far slow and inadequate response of developed countries which need to take the lead in this. Until developed countries can be shown to have met their responsibilities – both in delivering significant cuts in their emissions and in providing finance, capacity and technology support to developing countries – it is inappropriate to make demands for significant action from developing countries. However, there is a need for significant action from developing countries. This dilemma is the heart of the problem in unlocking a solution to climate change. Developing countries can be asked to take no regrets measures and sustainable development policies and measures (SDPAMs). Notwithstanding with this, the only way to unlock the sizable cuts in developing country emissions that will be necessary is for developed countries like the EU to prepare a dramatic platform of measurable, reportable and verifiable (MRV) finance, capacity and technology support for developing countries. Developing countries have set out a willingness to engage in MRV actions in response to this. In this case, differentiation is unnecessary as the support would be associated with mitigation actions and so would take place in those countries that have the most cost-effective and greatest mitigation potential. |
To what extent and how should those actions be supported by technology and financial assistance from the developed countries? What kind of supporting tools could be developed at the international level to support domestic action and should there be respective roles for the public and private sector, including the carbon market? (max 4000 characters) |
See above. While the carbon market may be an appropriate tool for some elements of the required assistance, it is inappropriate for all of them. A market mechanism is unlikely to deliver support to technology transfer or capacity building at the right level or in the right locations. Controlling emissions from land use, land us change and forestry should not be dealt with through a market mechanism. Alternative tools – probably public funded, although possibly funded from levying the carbon market – will need to be developed to provide support in these areas. The multilateral climate change fund proposed by the G77 and China may be a useful mechanism, although the details of how it is funded need to be resolved. Where the carbon market is expected to finance mitigation efforts in developing countries, developed country targets must be strengthened to ensure that the process of cutting emissions in developed countries is not traded off against action in developing countries, but instead both actions add up to sufficient global action. |
How should technology and financial assistance by developed countries to developing country mitigation and adaptation actions be measured, reported and verified and should they be compared? (max 4000 characters) |
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5. Carbon market |
How should the existing Clean Development Mechanism and Joint Implementation be improved in order to increase their environmental integrity and effectiveness? (max 4000 characters) |
The CDM will need to be greatly improved post 2012: currently the CDM at best only off-sets Annex I emissions, for without effective testing of additionality and rigorous baselines it allows global emissions to increase in absolute terms. It is imperative to ensure that the CDM post 2012 moves beyond offsetting and yields real additional net reductions in global emissions, as well as real benefits for sustainable development. If the environmental integrity of uncapped trading cannot be assured, it should be abandoned and other means of financing and technology transfer explored. To ensure the environmental integrity of the agreement, it has to be binding of character and there will need to be a stronger element of MRV. QELROs are not, however, appropriate for developing countries. MRV for actions by developing countries will need to be differentiated by a mechanism, with lower requirements for actions undertaken through a country’s own policies and measures or through international funding, while those operating through market mechanisms will require a higher level of certainty that credits generated actually reflect emissions reductions. Finn Church Aid suggests that the CDM shifts away from the project-by-project approach to more comprehensive approaches, variously discussed as policy-based or sectoral approaches. No-lose targets may be appropriate for some developing countries. Policy-based crediting would mean to reward specific policies which result in reduced emissions compared to an agreed reference level. Sectoral crediting would look at the performance of a sector as a whole, i.e. the transport sector in a country or province, and would generate reduction units for sale if the sector’s emissions stayed below the baseline. No-lose targets would function very similarly to sectoral crediting, with credits being awarded if the target is overachieved but no penalties applied if the target is not met. They would have the added advantage that the target would be negotiated. However, it must be stressed that great care would need to be taken to ensure that the targets adopted would result in real emission reductions. Sectoral crediting approaches to the CDM, however, also entail some important new risks. In particular, the quantification of emissions and reductions at the sectoral level will have to rely on modelling and projections, which always possess a degree of uncertainty and may be subject to the same problems of gaming that currently are observed in the CDM. Projections at the sectoral level may prove even less reliable than project-by-project testing of additionality. It is therefore imperative to assess the reliability of quantifying developing country reductions at the sectoral level before scaling up uncapped trading. If the project-based CDM is retained instead of or alongside sectoral approaches, major reforms would be needed, in particular to drastically strengthen testing of additionality. There should be exploration of the reforms that would be required, and their implications. Finn Church Aid also has strong concerns regarding the environmental and social sustainability of many CDM projects to date. CDM projects must be required to meet the CDM Gold Standard to ensure that they positively contribute to sustainable development in host countries. To prevent projects with high social and environmental costs from being registered under the existing or future mechanisms, international sustainability standards and procedures for stakeholder consultations that have been adopted by many international entities should be applied to the CDM already now. JI shares the fundamental flaw of the CDM in that it is generally not possible to demonstrate that an investment would not have taken place under business-as-usual conditions. Finn Church Aid supports exploration of ways in which JI can be progressively replaced by domestic cap-and-trade emission trading systems in all industrialized countries. |
What new market mechanisms could be developed to improve the effectiveness of carbon market? (max 4000 characters) |
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6. Carbon leakage |
How could the delocalisation of emissions from developed countries with binding emission caps to other parts of the world be minimized? (max 4000 characters) |
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7. Sectoral approaches |
What type of sectoral approaches could effectively contribute to global emission reductions? (max 4000 characters) |
Any sectoral approach should respect the right to development of the poor – this means that developing countries which might incur significant economic costs from a sectoral approach should be compensated for those costs. For example, small island developing states are likely to be disadvantaged by any sectoral approach to shipping. |
8. Emissions from international air and maritime transport |
How could emissions from international air and maritime transport be effectively addressed? (max 4000 characters) |
In as much as a global sectoral approach is considered see response to question 7 above. Emissions from the transport sectors, including international aviation and shipping, are a fast growing source of greenhouse gases: in the EU alone, aviation emissions almost doubled in the period 1990–2005, while maritime emissions increased by 80%. It is imperative that these sectors are addressed in the international regime, respecting the UNFCCC principle of common but differentiated responsibilities. Emissions from international aviation are technically simple to address, certainly for developed countries. Emissions should be allocated to the point of sale of the fuel that gives rise to them, reported in the country’s national inventory and accounted for in its overall national emissions total (assigned amount). A multiplier, in line with the IPCC’s report on aviation, should be applied to account for the non-carbon dioxide effects of aviation emissions upon the atmosphere. Administratively, responsibility for abating aviation emissions should be removed from the remit of the International Civil Aviation Organisation (ICAO) and accounted for under the UNFCCC like all other emissions, except those from international shipping. ICAO has come up with no constructive ideas over the past decade, except to recommend that aviation emissions should be included in an ‘open’ emissions trading scheme, which would likely look identical to the Kyoto emissions trading scheme. Finn Church Aid encourages the EU to come to Poznan with a detailed proposal to address aviation emissions, to complement Norway’s proposal for maritime emissions. Accounting for emissions from international shipping cannot be dealt with by the same means as aviation, both because it is very easy to change the flag status of ships (their country of registration) and because tankering (ship’s captains choose to fill their fuel tanks at the cheapest port) is often an easy option. Tankering is not normally an option for aviation, where space in fuel tanks is strictly limited and slight changes in flight plans can lead to significant increases in fuel consumption and hence costs. Ships can thus change their ‘nationality’ and the place where they buy fuels to best suit their needs at a particular time. To circumvent this difficulty, it would be best to allocate responsibility for emissions to ship owners or to ships, as proposed by Norway. The unique circumstances of shipping make a sectoral approach the only way to meaningfully address these emissions. In developing this type of solution, care will need to be taken that developing countries, and especially small island ones, are not disadvantaged. |
9. Emissions from deforestation and forest degradation |
What should be sources of financing emission reductions from deforestation and degradation? (max 4000 characters) |
Significant concerns have arisen on this issue from both an environmental as well as from a development perspective. Several options for financing have been put on the table out of which one is a market based approach. Finn Church Aid has great concerns with this approach because: 1) Inconsistency with the EU’s mitigation objectives: A market based approach to protect forests could undermine the objective of the EU in reducing its emissions at home. The EU ETS scheme has been designed to reduce emissions from large point sources in Europe, and the inclusion of sinks in this scheme would undermine this objective. Furthermore, allowing forest credits into the ETS could crash the price of carbon by almost 50% [Anger, Sathaye et al. 2008] likely preventing necessary investments in clean and renewable technologies. An estimated 6 billion forest offset credits could be made available, which would flood the ETS. Also, in many countries, the lack of reliable data, e.g. on the historic rates of deforestation, is likely to lead to emission reductions that are “fake”. Without the right data there is no way, for example, to establish sound baselines of forest cover and destruction, and hence too many credits may be issued. Without certainty that real reductions are being made, the ETS would lose its means to assess and predict its contribution towards meeting the EU’s 2 degrees target. Worse still, it may even promote an increase in the total carbon emitted with uncertainty whether real and permanent reductions are made. Carbon emitted over a period of the next 50+ years should not simply be offset by protecting a forest that may burn down next year. 2) Inconsistency with the EU’s human rights objectives: Including forests in the carbon markets could lead to a “land grab” by national and private interests in areas where indigenous and local peoples’ rights are not recognised or enforced. It could also pose serious risks to biodiversity. Several cases have already been reported of violations of the rights of the forest-dependent poor and indigenous peoples such as evictions and expropriations, unjust targeting of the poor/indigenous as drivers of deforestation, and violation of customary land and territorial rights. Therefore, the EU’s reputation as an advocate of human rights ought to be safeguarded by properly taking into account all issues concerned with rights to land and resources. 3) Inconsistency with the EU’s objective of achieving the Millennium Development Goals: If forests were to be included in a market mechanism, it would be unlikely to help developing countries in achieving the MDGs. The number of CDM projects that are currently implemented in the poorest region of Africa is less than 2% of the global total amount. Leakage of deforestation to other countries or regions could have a huge impact on the livelihoods of forest dependent people. Certification standards developed specifically for carbon forestry projects tend to be voluntary and can’t be enforced. Also, the certification process to enter into the carbon market is expensive and small producers and indigenous people often cannot afford these initial transaction costs. There is a need to look at the viability of forest protection relative to other forms of land-use needs such as those related to food security and local livelihoods. Otherwise, it could well be that the implementation of Avoided Deforestation Schemes could actually take countries further away from achieving the MDGs. The creation of a Multilateral Forest Fund under the UNFCCC that partially exists of auctioning revenues would be very welcome to initiate the worldwide protection of forests and would prevent the above mentioned problems. One of the dangers of a fund based approach is that the fund would not be filled. However, if the fund would be linked to the market, e.g. auctioning allowances, there would be the security of always having a fixed flow of finance available. |
How financing of emission reductions from deforestation and degradation should be monitored taking into account non-permanence, leakage and liability issues? (max 4000 characters) |
To address leakage, any REDD regime must be nationally based. That is, nations will take on some sort of obligation to reduce emissions from deforestation and they will be responsible for delivering those emissions. However, states may choose to develop their own domestic markets with private participants. Although a national approach should eliminate sub-national leakage, it will not eliminate international leakage, though it may generally be less of a concern, depending on the driver for deforestation. For example, poor farmers dependent on subsistence agriculture and slash and burn are very unlikely to move continents or even countries. Oil palm plantation owners, on the other hand, can and do move from country to country. It is therefore important that participation in any REDD regime be as broadly based as possible. Non-permanence is also less of a difficulty under a nationally based approach than it would be under a project-based approach. Amazonas is, for example, unlikely to burn down overnight, whereas the trees in a small area project might. Nevertheless, it remains a problem that needs to be addressed. In a shorter term, withholding a proportion of forest ‘credits’ in a reserve is an option that could address inadvertent forest loss. Somehow, however, a means of factoring out natural phenomena (perhaps including human-induced climate change) needs to be developed. For example, according to studies by the Hadley Research Centre, a large area of rainforest in Northeast Brazil is likely to dry out due to climate change, and Brazil is concerned how this issue would be addressed by a REDD regime as the government can clearly do nothing to stop the forest loss. Of course, this loss would not be directly due to deforestation, but it would represent a huge loss of carbon stocks and it is by changes in carbon stock how REDD is most likely to be assessed. Liability is likely to be a difficult issue because although the PNG proposal is for a sectoral ‘commitment’, it is a moot point what the word ‘commitment’ means in the context of developing countries and how legally binding it might be. Also, a REDD commitment would, in effect, last forever and liability is bad at dealing with forever. Brazil, in particular, is worried about entering into a commitment of indefinite duration, which is partly why they propose a fund that would not absolutely bind them to action but essentially pay them trying to cut deforestation with rewards for succeeding. |
10. Adaptation needs and support for most vulnerable countries |
What mechanism should be used to finance cost-efficient adaptation action in the most vulnerable countries, in particular LDCs, SIDS and African countries? (max 4000 characters) |
The most cost-efficient adaptation action being strong mitigation by developed countries due to our moral obligation to minimise the harm we are causing. Respect to assuring that adaptation funds are really directed not only to the most vulnerable countries but the most vulnerable communities and households inside them, there is yet a need for global assessment guidelines and project and program approval procedures. The future mechanism ought to demonstrate a real political will to identify and focus on the most vulnerable people. See http://www.germanwatch.org/klima/adfund08.pdf. Enhancing and expanding action on adaptation by all Parties of the UNFCCC ought to be encouraged starting from now and going up to and beyond 2012. The magnitude of the support for adaptation in developing countries needs to be scaled up by at least three orders of the actual level. Based on conservative estimates, the mechanism must generate upwards of $50bn per year. The future adaptation framework and especially its funding regime must contain the following pre-requesting elements: expanded cooperation and support for National Adaptation Planning and Implementation; expanded action in the field of climate risk management including an international insurance mechanism; establishment/enhancement of regional adaptation centres/networks and an adaptation technology mechanism. There is a need to incorporate adaptation into broader development efforts to address linkages between development challenges and climate conditions. The future mechanism should generate long-term resilience with a view on ecosystem feedbacks and complex system behaviour. Adaptation needs to be understood holistically and yet targeted with clear local approach. Faced with this complexity, we call for a comprehensive approach to adaptation that entails a range of measures that reduce the physical risk posed by climate change; address and reduce the underlying factors of vulnerability and strengthen adaptive capacity of the most vulnerable people in line with existing human rights, world heritage and biodiversity obligations. The funding commitments by Parties in the future adaptation framework need to generate in the order of tens of billions of US dollars annually over and above existing ODA commitments (0.7% of developed countries GNI) largely provided by developed countries. The burden sharing needs to be based on indicators of responsibility for GHGs emissions and (economic) ability to provide resources. It ought to be linked with the level and scale of emission reductions so that a failure to fulfil mitigation targets results in additional adaptation funding burdens. Only financial contributions released either through mechanisms of the post-2012 architecture or following criteria and guidelines agreed on by the COP should be counted as contributions towards Parties’ determined shares. Flexible support to developing country governments in their own efforts to advance successful and effective national adaptation planning and implementation is vital for successful finance of adaptation, for a one-size-fits-all approach would increase the risk of mal adaptation. National priorities ought to get identified in transparent and inclusive processes and implementation supported by sufficient resources. An adaptation technology mechanism, whether within a wider technology framework or a separate mechanism under the UNFCCC, should enhance transfer, diffusion and deployment of adaptation technologies in particular to the most vulnerable. It must target removing IPR barriers and take into account the context-, site- and problem-specific nature of adaptation technologies. Hereby, we also want to highlight the European Parliament Climate Change Agora results: Workshop Solidarities, Working Paper calls nro. 4–8: http://forum.agora.europarl.europa.eu/jiveforums/servlet/JiveServlet/download/35-489-815-367/Final_Texts_SOLIDARITY_EN_Final.pdf. |
How should the effectiveness of adaptation measures be monitored and assessed? (max 4000 characters) |
To safeguard effective adaptation measures, key principles for “good” adaptation need to be defined for application of all Parties delivering countable adaptation finance. Hereby, Finn Church Aid stands for the following principles: 1) focus on the most vulnerable, 2) promotion of poverty reduction and long-term resilience, 3) inclusiveness, for adaptation projects and programs should actively and meaningfully involve all relevant stakeholders in gender-balanced planning and decision-making around how adaptation funds are disbursed, used, monitored and evaluated, whereby dialogue and collaboration between various stakeholders should be encouraged, 4) access to information, for adaptation activities should be conducted in a transparent way and be well documented and placed in a public domain, 5) attention to gender; given that poor women are particularly vulnerable to climate change, adaptation planning should prioritize adaptation needs of women and ensure that women are actively consulted and included in related decisions, 6) subsidiarity; decisions on adaptation should be made at the smallest, lowest or least centralized competent authority level relevant to the implementation and 7) learning by doing, for recognising that the challenges of future climate change are likely to be beyond past experience, effective adaptation requires the development and implementation of flexible programmes through which learning can be captured, mistakes rectified, and future activities adjusted. Lock-in to technologies that might be seen as a panacea, but are appropriate only for one particular future climate scenario must be avoided. Lessons learnt from adaptation projects and programmes need to be documented properly and spread so that others can draw on the experience in formulation of locally appropriate approaches. Existing guiding frameworks, such as the Hyogo Framework for Action on Disaster Risk Reduction (2005), ought to be taken advantage of. The adaptation funding regime should entail its own fair governance structure that decides priorities and procedures for resource expenditure under the authority and guidance of the COP. Management and governance of the resources must be transparent and representative, with a developing country majority, special consideration of the most vulnerable countries and people and inclusion of non-governmental stakeholders. The governance structure of the Adaptation Found may serve as a model for the future regime. It is particularly necessary to allow civil society and other stakeholders to hold governments accountable and monitor their decisions and activities; this can be secured by very simple procedures such as ensuring public notifications of coming and ongoing adaptation measures. To contribute to filling the implementation gap until a new agreement may enter into force in 2013, Finn Church Aid asks the EU to promote in Poznan an agreement to develop a 3-year pilot phase of "Adaptation Activities Implemented Co-operatively", with a view to launching it in Copenhagen as a concrete outcome that initiates near-term action before 2013. This pilot phase should, with particular support of developed countries, enhance the implementation of demonstration projects, programmes and policies in particularly vulnerable communities and countries through a package of financial, technical, capacity building and institutional support for the implementation of National Adaptation Programmes of Action (NAPAs). It should also assist developing countries in integrating adaptation into all relevant policies and national development strategies and plans as well as in formulating long-term adaptation strategies. |
What should be the catalyst role of the UNFCCC, considering notably the role and contribution of other relevant international organisations addressing the impacts of climate change on their area of competence? (max 4000 characters) |
The Copenhagen agreement must result in a coherent framework for long-term collaborative action on adaptation. To make adaptation a strategic cross-cutting priority, it needs a coherent and strategic approach across all work streams and components of the UNFCCC. Currently, the Convention covers adaptation in a fragmented way, for none of the existing arrangements (e.g. the Nairobi Work Programme on Impacts, Adaptation and Vulnerability or the Least Developed Countries Expert Group) has the mandate to fulfil the necessary task comprehensively. To enhance the situation, a permanent UNFCCC adaptation body is needed to particularly enhance action for implementation with the following key functions: 1) assess progress and develop recommendations for further action to the COP (in particular under SBI) based on Parties requests and reflections, 2) develop guidelines and give guidance for the preparation of long-term adaptation strategies and 3) assist the adaptation funding regime and develop mechanisms/instruments to verify countries’ related commitments. The body should take the form of a multi-stakeholder committee with government, expert, civil society and private sector participation. It should build on experience gathered through e.g. existing arrangements under the UNFCCC. A strong UNFCCC adaptation body would serve to strengthen regional cooperation initiatives as well as enhance linkages and exchange of experience with other funding streams and institutions dealing with adaptation. Developing countries, especially particularly vulnerable ones, need to be granted support for both longer-term integration of adaptation into national planning and implementation processes and the implementation of concrete adaptation projects and programmes. A key catalytic role of the UNFCCC could be, through the establishment of a strong adaptation funding regime, to leverage substantially increased financial resources and strategically spend these to expand the work of existing initiatives which have proven expertise, e.g. in climate-related disaster preparedness activities. The Adaptation Fund established under the Kyoto Protocol should be fully operationalised as soon as possible. Given the uniqueness and innovative features of its structures, Finn Church Aid thinks it should continue in the future regime as a central element of the adaptation funding regime. There are interesting proposals on possible sources of finance required by the future adaptation regime coming up from the UNFCCC negotiations. The Norwegian proposal of using the revenues from international auctioning of emissions allowances requires focused technical and political attention of the Parties as the most promising instrumental proposal actually on the table. It could be combined with instruments that address responsibility on sectoral and individual levels, e.g. through auctioning of allowances/levies in international transportation and through an international aviation passenger levy. Joint Implementation and Emission Trading offer further possibilities for resource generation for adaptation. There is yet a need to actively search for additional innovative mechanisms such as the Greenhouse Development Rights climate justice and burden sharing framework, and others which could mobilise private savings. Finn Church Aid requests the EU to promote establishment of an international insurance mechanism as an integral element of a post-2012 adaptation, see e.g. the submission from Munich Climate Insurance Initiative (MCII, 2008) “Insurance Instruments for Adapting to Climate Risks”, http://unfccc.int/essential_background/library/items/3599.php?rec=j&priref=500004788#beg. A comprehensive strategy under the UNFCCC must include both actions to prevent and reduce climate-related risks (prevention pillar) and to help countries to cope with the costs and damages that climate-related disasters impose on them (insurance pillar). |
11. Technology cooperation |
Is there a need for specific support schemes for the development, demonstration or deployment of certain technologies? If so, for which ones and how should these be structured? (max 4000 characters) |
Development, diffusion and transfer of technologies are fundamental to reach reduction targets and to make adaptation possible in developing countries. Transfer of technology and capacities are crucial to ensure developing countries have a continued possibility for development and industrialisation also within the frame of a global climate agreement. It is important to note that transfer of technology is a broad concept including transfer of knowledge, expertise, capacities, working cultures and methods and soft and hard technologies. The actual technology is often a small part of the whole, and technologies can seldom be copied directly. On the contrary, technological solutions must be made to be sustainable, efficient and usable in a local context. Transfer of technology can be something abstract, and many existing initiatives claiming to include it are purely different forms of foreign direct investment and partnerships. Any initiative within a climate change framework must therefore be measurable, reportable and verifiable. It should be acknowledged that markets and business are global and transfer of technologies therefore not necessarily means transfer to a locally owned company or actor. However, in order to ensure a long term and sustainable effect, initiatives should lead to increased capacities locally, including possibilities for further adjustment and usage in the area. All developing countries have a need for technology, but the ability to attract foreign investments and new technologies differ a lot. Big developing countries are eager to initiate their own innovation and development, and they have no problems attracting both interest and investments from foreign and transnational actors. For LDCs and many small developing countries the situation is different; for them marked based mechanisms will not be enough to attract foreign companies or technology transfer. It is therefore important that the new agreement includes a fund which can facilitate initiatives not based on marked criteria but need for new technologies related to adaptation and mitigation. Funds are also needed to support innovation and adjustments of technologies for developing countries, for today the most technological solutions are made for use in industrialised countries. Where IPRs are recognized as a barrier, an approach is needed to maintain incentives for technological advancement recognizing the need for rapid and affordable diffusion of existing and new advanced technologies. This will include, but not be limited to, using existing IPRs flexibilities and exceptions, as well as preventing anti-competitive practices that limit access. It should be acknowledged that private corporations have here a special role to play as most technologies are owned and used within them. It is needed to identify both pull and push factors, which will enable an efficient and sustainable transfer of technology, as described above. Transfer of technology can be pushed through regulations, such as global standards, that can increase the interest in climate friendly technologies, IPRs initiatives such as a IPRs library where patents are pooled and made available for payment and possibilities for national investments and trade policies facilitating transfer of knowledge, expertise and technologies. Pulling initiatives or incentives can be CDM (though not in its existing form) and financial support for initiatives facilitating transfer of technology, e.g. PPP and different forms of business to business cooperation. Access to investment capital (loans) for companies which are willing to invest in certain areas with special focus on transfer of technology can also be a possibility. Even though additional funds are crucial for many relevant initiatives, they need to be supplemented with an institutional framework. |
How to strengthen enabling environment for the deployment of the many existing clean technologies? (max 4000 characters) |
Capacity-building is a key enabling mechanism in developing countries, and needs to be addressed as a matter of priority within any future mechanisms to develop, deploy and diffuse technology. This relates to technical as well as regulatory and institutional capacities. Other key elements for enabling environments are a) clear and common global long term vision and framework, which is an essential signal for the private sector b) access to funding and c) enabling policy frameworks. For private sector development it is important to have clear and long term frames for activities. A long term perspective creates an environment where companies are willing to invest, what is important for facilitation of transfer of technology. As described above, funding is crucial, and it is not enough with marked based solutions as many of the most vulnerable countries will have difficulties to attract market based funds due to their location, size, domestic level of education and industrialisation, limited domestic market and lack of comparative advantages. Funds must be predictable, additional and adequate, and they should be used both for development and adjustments of technologies relevant for developing countries, and for diffusion of existing experiences, knowledge and technologies, either through purchase of products or patents, or through support to different types of international technology cooperation (e.g. PPP). Policy frameworks do also have an important role to play. However, they need to be adjusted to local conditions in order to make them efficient in enabling transfer of technology. There is a big difference between for example China and landlocked Malawi lacking big industrial sector. A climate change agreement needs to be adjustable and flexible to encompass different needs of different countries, and space must be given for national development priorities in selecting different policy measures. Intellectual property rights are one policy area which should be assessed, and in areas where existing IPRs provisions limit access to climate-friendly technology, improvements need to be made. It should be acknowledged that the need for initiatives may differ between countries and sectors, and action should therefore be differentiated. A framework agreement on IPRs and technology licensing could be established to encourage patent sharing, joint ventures and public private partnerships. Countries should agree on the principle of ‘protect and share’ in order to increase accessibility to key climate friendly technologies that are protected by IPRs, while strengthening incentives for R&D through IPRs protection for those countries that are ready to participate in such a scheme. Within the future framework, a possibility of a “Patent library” should be explored as an encountering forum for innovators and buyers of climate friendly technology. Knowledge and inventions on different selected technologies relevant for adaptation and mitigation will be pooled into a database, to which users can buy access for a set percentage of their profit – e.g. 10%. The profits are then pooled into the library and divided among the innovating parties according to the number of times their knowledge has been used. Furthermore, dissemination and facilitation of existing possibilities for IPRs sharing within the TRIPS system should be strengthened. |
12. Finance and investment |
How should additional public support be organised and which should be the three top priority areas for financial support in developing countries? (max 4000 characters) |
Substantial new and additional public funding is essential in order to a) leverage much greater amounts of private financing for the mobilization of climate friendly technologies b) provide funding for activities that do not attract private money, like majority of the adaptation activities. The priority areas for financial support in developing countries need to be adaptation, leveraging massive clean technology uptake and reducing emissions from tropical deforestation and degradation. The magnitudes of public funding have to meet the assessed needs and cover the agreed incremental costs. The rough estimations so far indicate that the developing countries’ needs of public financing could be in the order of 80–105bn $/year (57–73bn €/yr), of which the share of adaptation would be 50bn $, incremental costs of mitigation 25–50bn $ and protecting tropical forest 5bn $. The most promising revenue stream to make up the huge difference between existing and needed public funding is the auctioning of assigned amount units, as has been proposed by Norway. There are other promising sources of financing as well, such as those involving aviation and maritime fuels, which also should be explored. Meanwhile, the approach of auctioning of AAUs has a number of attractive features which make it jump to the front of the line. First, it can mobilize the scale of funding that is required. Auctioning just a small percentage of developed country AAUs could generate a significant amount of money. As Norway stated in their proposal, setting aside just 2% of AAUs could lead to the creation of $15 to 25 billion in funding per year. Or to take another scenario, setting aside 10% would generate between $75 billion and $125 billion. At this stage, the figures are only indicative. The mechanism should include a maximum limit for the overall purchase of AAUs per country. Second, it can help to deliver predictable and sustainable funding that isn’t at the whim of the annual budget process in capitals around the world. Rather, establishing this approach will guarantee a stream of financing over the life of the agreement. Third, the emissions reductions achieved through this mechanism would contribute additional reductions to our global efforts to address climate change. As they would not replace or offset emissions reductions in Annex I countries, they would “add to” the reductions achieved in meeting these targets. To assure these additional efforts, it is imperative that the “carve outs” do not reduce the level of ambition of the negotiated assigned amounts to fulfil the 25 to 40% below 1990 by 2020 range. Lastly, the adaptation funding from this mechanism would be more closely aligned with the “polluter pays principle”. After all, those that contribute to climate change should share a greater proportion of the adaptation needs according to their contribution. Provision of all financing, the use of those funds, and the results achieved in terms of mitigation of developing country emissions, must establish detailed and transparent mechanisms for measuring, reporting and verifying. This will build greater trust, ensure that money is actually flowing (not just promised), and avoid the inefficient use of our precious financing resources to help developing countries adapt to climate change and make the transition to low-carbon development. Whether these funds should be directed to and managed by only one fund or several, and whether there is a need for a totally new institution is to be assessed. However, management of these funds needs to be representative and transparent and the mechanism needs to be closely linked with the guidance of, and the principles set by the COP. The GEF being based inside the World Bank and having managers and decision makers outside of the UNFCCC process is not trusted by the developing countries and is therefore unlikely to serve as an optimal institution for managing these massive new funding streams. |
How could private sector be involved in mobilising additional finance? (max 4000 characters) |
Private-sector investments constitute the main share (86 %) of investment and financial flows in the energy sector today, and they will remain a key in the future as well. Deepening and widening emission reduction commitments and expanded carbon market with adequate price signal can play a large role in redirecting these flows, but it will not be adequate. Substantial new and additional public funding is essential in order to leverage much greater amounts of private financing for the mobilization of mitigation and adaptation technologies. Private sector with its innovation mechanisms and hands-on experience with technologies will also need to play a major role in developing the technical solutions for mitigation and adaptation. The Technology Cooperation Mechanism proposed by CAN-Europe would provide the private sector with ways of participating, by, inter alia, facilitating and funding public private partnerships, providing enabling environments for joint ventures and setting Expert Panels to help develop and oversee the global Technology Roadmaps. The Copenhagen outcome with its targets and mechanisms needs to create as predictable and reliable investment environment for the private sector as possible. This means, inter alia, shared global long term and midterm visions for emission reductions; deep emission reduction targets for developed countries; a new Technology Cooperation Mechanism that will assist and incentivise developing countries in creating enabling conditions for clean and sustainable investments; reformed and improved CDM that facilitates programmatic and sectoral approaches for developing countries with strongly improved additionality and sustainability criteria; tackling current barriers related to the IPRs and, last but not least, credible compliance mechanisms. |
13. Compliance and enforcement of the new agreement |
How should it be ensured that countries will comply with their commitments? (max 4000 characters) |
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14. Other suggestions |
Please enter any other suggestions that were not covered by previous questions (max 4000 characters) |
Finn Church Aid asks the EU to promote debate on and consideration of gender aspects in all climate change related political and procedural decisions in order to ease existing burden and calamities that particularly poor women are exposed to around the world by existing and worsening environmental degradation. |
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