Achieving environmental integrity in the implementation of Article 6 requires many things; but where to start? For ECO, environmental integrity is impossible to achieve without conservative baselines, set well below business-as-usual (BAU). And even these are necessary, but not sufficient elements.
ECO is encouraged to see that the text forwarded to the COP Presidency included some principles for conservative baselines in Article 6.4. However, ECO is concerned to see many of these foundational principles in brackets, and some key principles missing or muddled. Methodologies in the new Article 6 mechanism must require baselines that are well below business as usual. While “best available technology” is listed in the text, it is also important to take into account what is economically feasible without the mechanism, as well as what is legally required.
Approaches based on projected or historical emissions are not appropriate for a conservative or ambitious benchmark. ECO urges Parties to remember that historical emissions are how we got into this mess in the first place. We need to do better.
As the economic, political, and technological contexts in which projects take place evolve, so should the baselines. Ensuring that methodologies are approved for a time-bound period, and requiring the review and update of baselines over time, is necessary in order to reflect the inherently dynamic nature of the viability of various technologies. It should be clear that Parties and the Supervisory Body must dynamically re-evaluate baselines over time to increase ambition.
ECO is pleased to see that the baseline methodology text has a strong definition of additionality that takes into account all relevant national policies, laws, and regulations. However, ECO is concerned that merely exceeding an NDC, as stated under part of the proposed definition, should not be sufficient to demonstrate additionality. As we all know, some NDCs are far behind what is ambitious climate action. ECO urges parties to define additionality as the activities that would not otherwise occur, since NDCs aren’t yet the benchmarks of the ambition we need.
ECO urges that baselines are set conservatively; otherwise we”ll be off base.