Prepared for the Bonn Climate Change Conference 5-15 June 2023
Carbon Market Watch welcomes the opportunity to provide input to the discussions on matters relating to Article 6.2 (plus one in 6.4) of the Paris Agreement ahead of the UNFCCC’s 58th session of the subsidiary bodies.
Sequencing and timing
● A step-wise process consisting of clearly separated, consecutive, procedural steps is needed to ensure TACCC principles are being met.
● Review of the initial report should be a prerequisite for all subsequent steps.No ITMOs should be issued/traded/used until the review is complete andrelated recommendations have been addressed.
Inconsistencies and implications of non-responsiveness
● Without a requirement for Parties to address reviewers’ recommendations, the review process as it currently stands is inadequate.
● Inconsistencies found in a review should have consequences: until these are addressed, Parties should not be able to proceed with their cooperative approach. Systematically ignoring review recommendations should have graver consequences, such as halting the use/future issuance of ITMOs.
● Inconsistencies that reveal double counting, over-issuance, or a general lack of environmental or social integrity, should result in corrective measures to cancel, and where necessary replace, ITMOs.
Modalities for reviewing confidential information
● Designating information as confidential will undermine trust in the cooperative approach concerned and Article 6.2 more widely.
● A justification should always be provided to the review team if information is designated as confidential.
● For the bare minimum of transparency, SBSTA should consider a drop-downlist of justification categories to be disclosed on the CARP.
Host Party authorisation statement to Supervisory Body
● Authorisation statements should be comprehensive (see list in below section) and should be provided before issuance, ideally upon or prior to registration.
● Authorisation after issuance can lead to reporting errors and serious problems such as double counting.
Revisions to authorisation
● Changes to authorisation can impact consistency of reporting and the application of corresponding adjustments, potentially resulting in double counting. Parties should further discuss these implications and possible solutions (if any), while always prioritising environmental integrity.
● We do not support revisions to authorisation, unless double counting can be definitively ruled out.
Draft agreed electronic format
● The final Agreed Electronic Format should provide clear and accessible information for all stakeholders. The current draft AEF is missing some relevant information columns, e.g. regarding OMGE and SOP.
● Unique identifiers should be used where appropriate to ensure consistency and comparability across rows, columns, and/or possible subtables.
Article 5 vs Article 6.2
● Article 5 and the Warsaw Framework are not carbon market mechanisms and are not automatically compatible with either Article 6.2 or 6.4.
Read the full recommendations here:
