A Few Transparent Comments

We’re nearing the end and we’re not quite sure how much progress you”ve made in advancing the transparency negotiations. So we won’t take so much of your time, we just want to provide a couple of comments on the important issues in the transparency discussions.

• ECO is quite concerned with the proliferation of “encouragement” in the transparency text instead of ‘should” or ‘shall” requirements. Having strong transparency rules is a way to increase ambition and that is something we all ‘shall” do!
• Flexibility and providing support are key to facilitating improved reporting and transparency over time €“ and that’s the goal, right? Flexibility should be provided to those Parties that do not have the requisite capacity, but, once Parties have the capacity, they should no longer use flexibility. Improvement plans are a great tool to help Parties plan to build their capacity over time.
• It is important to transition to the Paris Agreement’s enhanced transparency framework as soon as possible. ECO suggests that the first biennial transparency reports should be submitted in 2022 in order to inform the first Global Stocktake and to show the rest of the world that you are moving forward and building momentum for the Paris system.
• ECO hears concerns about overburdening the Secretariat and the review process. Of course, we understand these concerns. However, simplified reviews represent a form of backsliding when we need to be enhancing the process all around. By signing the Paris Agreement, Parties committed to maintaining at least the quality and frequency of reporting and reviewing of the Convention. ECO urges them to stick to this pledge.
• Loss and damage is an important element of discussions throughout the COP. We urge Parties to find a way to incorporate loss and damage into both sections of the transparency framework €“ action and support.
• Observers are valuable contributors to any transparency process. If any Parties are in doubt as to the contribution, please refer to our past issues in which ECO asked questions to Parties undergoing a multilateral assessment and the facilitative sharing of views, some of which Parties answered. It would be a real enhancement to be able to ask these questions directly to Parties!
• Being transparent about one’s actions can contribute to raising ambition, however, sometimes it is not enough. Perhaps, ECO missed it in 35 pages of detailed text, but where is the link to the Article 15 committee to facilitate implementation and promote compliance? It is important that the technical review reports feed into the Article 15 committee.

And if you”ll allow us to get wonky for one final point, ECO is disappointed to see text for sectors and gases allowing Parties to avoid reporting on emissions and removals in the land sector if it’s not technically possible. That sounds to us like an excuse to avoid robust reporting!

We’re here to support you in building and implementing an enhanced transparency framework. We hope you’re up to the task.