Article 6 Wrap-up: How to Fly Above the Hot Air

27 June 2019

On this final day of SB50, ECO would like to remind Parties about the importance of strong environmental integrity provisions in the Article 6 rules.  

It is fundamentally critical that emissions transfers under Article 6 prevent double counting. Article 6 can only work properly if the rules ensure that double counting is avoided both in 6.2 and 6.4, and that corresponding adjustments are applied for mitigation outcomes both inside and outside the scope of a host country’s NDC. This must apply regardless of where the credits are used – i.e. for NDC and non-NDC purposes alike. 

ECO continues to hear from some Parties that corresponding adjustments for mitigation outcomes used toward purposes other than NDCs €” like aviation’s carbon market, the ICAO CORSIA €” are not important. ECO strongly disagrees. Leaving non-NDC adjustments out of the picture could punch a hole in the Paris Agreement the size of an A380 jumbo jet. 

And if Parties allow Certified Emission Reductions (CERs), Assigned Amount Units (AAUs) or Emission Reduction Units (ERUs) to transfer over without any conditions, it would punch a hole in the Paris Agreement big enough for a whole airline’s fleet. Allowing activities and methodologies from the Kyoto Protocol mechanisms to carry over without conditions would widen that enough to add another airline’s fleet! Why would Kyoto Protocol credits be bad for the system? It’s simple physics. It’s hard to get lift-off with “hot air” all around you.  

The environmental integrity of the mitigation outcomes under Article 6 is fundamental as well (e.g. emission reductions need to be real, quantified, additional, permanent, and verified). On the issue of whether mitigation outcomes are real, ECO is highly concerned with the possibility of non-CO2e metrics being used and converted into CO2e values for trade between Parties with NDCs measured in different metrics. The potential to game this conversion process seems enormous. 

Environmental integrity for Article 6.4 (and under baseline and crediting systems that might fall under Article 6.2) means adopting strong rules for setting baselines. Baselines should be set conservatively, well below business as usual. They could also integrate principles of “best available technology” (taking into account specific geographical conditions) and/or an ambitious policy trajectory. Baselines should also be dynamic over time.  

Voluntary cooperation under Article 6 should enhance mitigation, adaptation, and sustainable development, and Parties should make the operationalization of “overall mitigation in global emissions” a mandatory process.  Enhancing sustainable development doesn’t happen on its own, either. We need clear human rights-based environmental and social safeguards, including meaningful public participation, and a strong independent grievance mechanism to address harms if they do occur. A share of proceeds for the Adaptation Fund is critical as well.

ECO thanks negotiators for their hard work at the session. We hope you’re able to look at the good, the bad, and the ugly to achieve better alignment at the Pre-COP, and be ready to adopt strong rules for environmental integrity and sustainable development in Santiago at COP25.

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