India's proposals for the assessment and review of climate change action

Posted by () on Nov 04 2011
VERTIC Blog >> Environment

Sonya Pillay, London

As noted last week, a frenzy of submissions and proposals has emerged in the run up to the 17th Conference of the Parties (COP 17) to the United Nations Framework Convention on Climate Change (UNFCCC). A particular talking point in the conference, which is to be held in Durban (November 28 – 9 December 2011), will relate to India’s recent submission to the Ad Hoc Working Group on Long-term Cooperative Action (AWG-LCA). This submission suggests some interesting adjustments to common verification practices under the Convention.

Launched during COP13 in Bali, the AWG-LCA acts as a companion to the Kyoto Protocol Working Group. Aimed at enabling ‘full, effective and sustained implementation’ of the convention, it prioritises a shared vision on the basis of equity and the principle of ‘common but differentiated responsibility’. Synthesising the interests of all parties thus implicitly bridges the divide between Annex I states, comprised mainly of the developed bloc, and non-Annex I states. A notable outcome of the AWG-LCA work establishing cooperative solutions is its development of a system of monitoring, reporting and verification (MRV), and measures to augment this system.

To that end, India’s submission at Panama, tendered on 28 September 2011, argues that ‘existing procedure for measurement and reporting of targets’ does not fulfil its intended objectives of comparability and confidence-building. New Delhi believes that guidelines for submission and international assessment and review (IAR) need to be revised, updated and enhanced to tackle these perceived inadequacies.

From Copenhagen to Cancun
Monitoring, reporting and verification provisions in climate change negotiations play a pivotal role in providing transparency and on-going evidence of countries’ progress on climate change. The existing UNFCCC MRV system requires two regular submissions. First, National Communications (Natcoms) every 3-5 years by Annex I states provide updates on national implementation of the Convention (i.e. summaries of national greenhouse gas inventory data, funding, support to developing nations, climate change targets and achievements). Second, national GHG (greenhouse gas) inventories, on an annual basis for Annex I states and less frequently for non-Annex I states, are more specific compilations of GHG emissions and removals.

The Cancun Agreements of November 2010 build extensively on these provisions to create new transparency mandates and, crucially, to subject countries to more rigorous scrutiny for greater comparability. Under this new system, both Annex I and Non-Annex I states are to submit information through the same basic format (though with slightly different content): biennial update reports. For the first time, developing countries are tasked to submit Natcoms every 4 years. Under the existing MRV architecture, they are allowed greater flexibility in the frequency of their submissions. The Cancun framework supplements the existing apparatus, but is yet to be fully implemented.

The differentiated obligations of developed and developing states are demonstrated in their reporting requirements. Annex I biennial reports and national inventories focus on domestic progress in achieving quantified emission reduction targets and ‘the provision of financial, technological and capacity building support to developing country parties’. These reports are then subjected to a process of IAR. A work programme developing the potential modalities and guidelines of this IAR are however yet to be established.

Non-Annex I reports are meant to outline the progress of nationally appropriate mitigation actions (NAMAs) in the context of sustainable development strategies, in addition to updates of national GHG inventories. These will then be submitted to International Consultation and Analysis (ICA) instead of IAR. As with IAR, the particularities of this process have yet to be hammered out. However, implicit in its name, the ICA plays a more advisory role than IAR.

Under the Cancun framework, the MRV process is boosted by a greater emphasis on domestic MRV. For instance, internationally supported, non-Annex I NAMAs will be domestically measured, reported and verified before being subjected to international MRV, putting the onus on countries to self-monitor and encouraging adherence to international guidelines. Enhanced guidelines for the review of Natcoms, more frequent reporting and common reporting formats provides a framework within which parties’ can better track progress against their pledges.

‘Robust, rigorous, and transparent’
India’s two-page document attempts to build on certain IAR inputs and procedures introduced in the Cancun Agreements. New Delhi’s approach in climate change talks has increasingly been to press Annex I countries to better uphold their climate change commitments, and to engineer solutions that protect the interests of non-Annex I states. Its suggested improvements reflect these concerns.

Five of New Delhi’s suggestions would meaningfully alter the general MRV framework. First, ‘for IAR to be robust and transparent’, common accounting rules derived from enhanced guidelines on reporting and accountability should be developed, as part of the improvement of common reporting formats initiated by Cancun. Second, India recommends that the provision of support in developing ‘complete, comparable, transparent and accurate’ common reporting formats and financial methodologies should be ‘built into’ the IAR process.

Third, as a first step towards preparing biennial reports, Annex I countries should ‘indicate their ambitious quantified emission limitation and reduction commitments (QELRCs), including emission reduction targets’, and include these in Natcoms. India’s document notes that Durban ‘should include a decision to this effect’. This would allow the review process to measure progress against declared targets. 

Fourth, the in-depth expert review of annual Annex I inventory reviews should lead to an assessment report. A subsequent SBI consultation amongst all parties would then facilitate an annual review ‘of the ambition levels and targets for emission reduction in the Annex I countries’. This is perhaps expected to behave as an in-built response mechanism, wherein poor progress reviews instigate non-Annex I countries to apply increased diplomatic pressure. And lastly, India is adamant that ‘IAR has to be no less onerous for developed countries than the ICA is for developing countries’.

A palatable proposal?
India’s suggestions are in the spirit of, and strengthen, the MRV goals of comparability and confidence-building. However, workability must also be considered. This means two things. First, well-functioning IAR and MRV systems could become sluggish if politicised. Should the technical-logistical endeavours of the IAR framework be tied too tightly to the ideological objectives of the Convention, it might face diplomatic quagmires. And second, workability must entail an efficient and unencumbered system.

For these two reasons, India’s suggestion of SBI consultation leading to subsequent annual review of Annex-I ambition could be a difficult MRV provision to implement. It also appears to place extra, some might say ‘onerous’, IAR pressure on Annex I states. Moreover, creating an additional resource-intensive layer of annual reviews amidst a newly-implemented and unpolished Cancun framework of Annex 1 and non-Annex 1 biennial reports appears unwieldy. When India’s submission and others are considered at Durban, delegates must remember that it is crucial to establish IAR provisions that are both strong and workable.

Last changed: Nov 04 2011 at 12:22 AM




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