SUBMISSION BY ITALY AND THE EUROPEAN COMMISSION ON BEHALF OF THE EUROPEAN UNION AND ITS MEMBER STATES

Transcription

1 SUBMISSION BY ITALY AND THE EUROPEAN COMMISSION ON BEHALF OF THE EUROPEAN UNION AND ITS MEMBER STATES This submission is supported by Albania, Bosnia and Herzegovina and Serbia. Rome, 14 October 2014 Subject: The Ad Hoc Working Group on the Durban Platform for Enhanced Action (ADP): the 2015 Agreement SUMMARY Intended nationally determined mitigation contributions (INDCs) provide the primary means for operationalising the principle of CBDRRC in the 2015 Agreement. Through a common process that is applicable to all, each Party will select its commitment type and level of ambition that is as ambitious as possible, and that is differentiated in light of its national circumstances and capabilities. Each Party will describe why its INDC reflects a fair and ambitious contribution to the agreed below 2 C objective. An international process to consider and analyse the INDCs prior to COP 21 will build trust by enabling us to understand, compare, and aggregate proposed commitments. To ensure this process succeeds, all Parties should stick to the Warsaw timetable, and the major and emerging economies should come forward with INDCs by the first Quarter of All INDCs must address mitigation. The INDC process was conceived and agreed with mitigation and the below 2 C objective in mind. Adaptation and finance will be crucial components of a balanced 2015 Agreement. Ensuring adaptation and finance are properly addressed in the 2015 Agreement requires specific and distinct approaches. Up front information requirements, which are to be agreed in Lima, must ensure that INDCs are transparent, quantifiable and comparable. Up front information requirements should be differentiated according to the type of contribution. A common multilateral rules-based regime including clear and robust monitoring, reporting and verification (MRV) and accounting rules, as well as compliance, is fundamental in the context of nationally determined contributions. It is the only way to achieve transparency and accountability and secure confidence in the new regime. Page 1 of 20

2 Mitigation commitments of all Parties and in particular those of the major and emerging economies - must be finalised in Paris, alongside all the rules essential to doing so. This includes all the rules for MRV and accounting, such as those on accounting for the land-use sector and for the use of international carbon markets, that would substantially impact the level of effort implied by any mitigation commitment. Technical rules that would not substantially impact the level of effort can be finalised after COP 21. The 2015 Agreement needs to include a common and regular process for reviewing and strengthening mitigation ambition to ensure that we collectively stay on track for below 2 C and that individual commitments are fair and ambitious. This process should be designed to: respond to the outcomes of related processes that review Parties' performance (MRV); assess the adequacy of all existing commitments in light of the below 2 C objective; and synthesise the latest scientific and technological developments (IPCC). This process should lead to the upward adjustment of Parties' commitments. With regard to adaptation the 2015 Agreement should: (i) recognise the global adaptation objective as the achievement of climate resilient sustainable development for all Parties"; (ii) reinforce the commitments of all Parties to undertake measures to facilitate adequate adaptation and integrate it in relevant national and regional planning processes; (iii) call to assist the efforts of developing countries, especially those particularly vulnerable to the adverse effects of climate change. Decisions supporting the 2015 Agreement should provide further guidance to Parties to improve the effectiveness of national adaptation action, including the consideration of qualitative milestones for progress on adaptation, as well as to facilitate enhanced cooperation in preparing and implementing adaptation measures. The process to take adaptation forward to COP 21 and beyond should comprise: (i) negotiation of the 2015 Agreement and supporting decisions to anchor and strengthen adaptation provisions; (ii) continued implementation of the Cancun Adaptation Framework; and (iii) the continuation of support, including through the Green Climate Fund's (GCF) target of funding adaptation through 50% of its portfolio over time. Finance in the 2015 Agreement has to provide the framework for shifting investment patterns towards low-greenhouse gas (GHG) climate-resilient sustainable economies and societies. There is a role for all Parties to take actions regarding climate finance in line with evolving responsibilities and capabilities. This does not mean that all Parties should take the same actions. The 2015 Agreement should capture the diversity of actions from the domestic level to the international level. Actions could range from improving domestic enabling environments for facilitating climate-proof investments to mainstreaming climate considerations into all policies, ensuring impact, and even mobilising international climate finance. 1. We welcome the initiative of the ADP co-chairs Non-Paper on Parties Views and Proposals on the Elements for a Draft Negotiating Text i (the non-paper) and its intention of trying to help move discussions forward. However, there are aspects of the substantive content of the nonpaper that we cannot support (including its structure, which cannot be deemed as agreed at all) and there are a number of aspects where the EU position is not reflected or not represented accurately. Nevertheless we consider the non-paper as a useful input for further discussions at the October session of the ADP. It is the responsibility of the co-chairs to guide Parties towards Page 2 of 20

3 agreeing by Lima the draft elements for a negotiating text. To that end, we must leave the October session having had in depth exchanges that lead to a clearer outline of the elements of the 2015 Agreement and streamlining of the substance of the non-paper. 2. We also welcome the co-chairs' draft decision on intended nationally determined contributions of Parties in the context of the 2015 Agreement ii (the INDC decision). The draft decision text is a useful document to facilitate discussions during the upcoming October session. It is essential that, as agreed, COP 20 adopts an INDC Decision - and we expect the co-chairs to guide Parties towards that outcome. 3. This submission iii: (i) addresses particular areas in relation to which the EU position needs to be better reflected in the non-paper; and (ii) sets out general reactions to the draft INDC decision. In so doing the submission goes into further detail on the issues highlighted in the summary above: A. Operationalising common but differentiated responsibilities & respective capabilities (CBDRRC) B. Intended Nationally Determined Contributions C. A multilateral rules-based regime for transparency and accountability D. A cycle for regularly strengthening mitigation ambition in the 2015 Agreement E. Adaptation in the 2015 Agreement F. Finance in the 2015 Agreement A. OPERATIONALISING COMMON BUT DIFFERENTIATED RESPONSIBILITIES & RESPECTIVE CAPABILITIES 1. One of the most challenging issues that will need to be addressed by COP 21 is how the principle of CBDRRC will be implemented in the 2015 Agreement iv. 2. If we want to meet our common below 2 C objective, all Parties will have to act to make a transition towards a safe and sustainable low carbon economy in a way that reflects their national circumstances. The EU is fully committed to a 2015 Agreement consistent with the principles of the Convention including CBDRRC. However, in order to be consistent with this principle Parties' obligations must reflect evolving realities, circumstances, responsibilities and capabilities in a fair and dynamic way that is ambitious enough to keep us on track to achieve the below 2 C objective. National circumstances have substantially changed in the past few decades and are likely to do so in the future - a durable 2015 Agreement needs to take this into account. 3. All Parties should have legally binding mitigation commitments in the 2015 Agreement, but they will not be the same in level of ambition, and commitment types will differ. Page 3 of 20

4 4. As agreed in Warsaw all Parties' intended contributions should be nationally determined. INDCs therefore allow each Party to choose its contribution type and define its level of ambition in accordance with its national circumstances and capabilities. 5. As such the concept of 'nationally determined' contributions put forward as part of the INDC process, and the subsequent international process to consider and analyse the INDCs, provide the mechanism through which we can operationalise CBDDRC in the context of the Convention, and do so in a way that reflects evolving realities, circumstances and responsibilities in a fair way. This notion should be reflected in the INDC decision and as a core element of the 2015 Agreement. 6. The EU joins many other Parties in the understanding that each Party's determination of its INDC should represent a progression from previous levels of ambition and scope over time, and that there should be no ceiling imposed on any Party's level of ambition or on the rules that apply to it. 7. The differentiation of mitigation-related obligations both before COP 21 and in the context of the 2015 Agreement itself should flow from this initial national determination of contributions including requirements for up front information (see section B below) and the MRV & accounting rules base (see section C below). The overall result should provide for a common system, differentiated on the basis of the commitment type chosen by each Party. 8. In this way the process of determining, communicating and assessing INDCs, and finalising mitigation commitments in the 2015 Agreement, offer a fair and effective way forward for designing the 2015 Agreement under the Convention, and reflecting evolving realities, circumstances, responsibilities and capabilities. 9. This approach to operationalising CBDRRC through the notion of 'nationally determined', which has been supported by a number of Parties, is not well reflected in the non-paper. The EU cannot accept a static interpretation of CBDRRC that differentiates commitments of Parties according to a binary split based on the Annex to the Convention. 10. Of course CBDRRC has implications in other areas like adaptation and finance, which must also reflect evolving realities and circumstances in a fair way. Page 4 of 20

5 B. INTENDED NATIONALLY DETERMINED CONTRIBUTIONS The content of the INDC decision 1. The INDC decision to be adopted in Lima needs to provide guidance to Parties both on the up front information to accompany INDCs as well as on the process to consider and analyse INDCs with a view to reaching an ambitious outcome at COP Therefore the INDC Decision should: a) Reiterate the timeline agreed in Warsaw that all Parties must communicate their INDCs well in advance of COP21, and in the first quarter of 2015 for the Parties in a position to do so. We would expect at least all major and emerging economies to communicate their INDCs in the first quarter of b) Clarify that all INDCs must address mitigation. The INDC should set out intended mitigation contributions that each Party considers to be a fair and ambitious reflection of its responsibilities and capabilities in the context of the below 2 C objective, progressing from previous levels of ambition and scope over time. c) Specify the need to ensure that the aggregate effect of all Parties' contributions delivers on the necessary level of mitigation efforts. d) Clarify that INDCs should clearly set out what a Party will contribute itself unconditionally, recognising that the poorest countries may be able to do more with support. e) Set out that over time all Parties should aspire to having economy-wide absolute emission reduction targets, although initially other types of commitments might be appropriate for Parties with fewer responsibilities and less capability. f) Stipulate that mitigation INDCs must be presented along with up front information in accordance with agreed requirements these requirements should be set out in the Annex of the INDC Decision and should be differentiated according to the different types of INDCs. The up front information requirements should ensure that INDCs are transparent, quantifiable, comparable, and should facilitate the pre-cop 21 international process. g) Set out in more detail information requirements needed to promote the transparency of INDCs and to guide Parties more precisely in respect of the information that needs to be provided these should include: On approaches for the land-use sector: Do Parties intend to include the land-use sector as part of the INDCs? Which accounting approaches are they proposing? Do they intend to do activity-based or land-based accounting? What reference levels are they using? Page 5 of 20

6 On expected use of international market mechanisms: How will Parties avoid double counting in their INDCs? Are there any restrictions on unit types used to meet the INDC? (e.g. units from specific gases or geographical restrictions). What percentage of the total emission reduction effort will be covered by international credits? Methodologies: What methodologies are Parties using to frame their INDCs? Any projections in the target year/period should be clearly defined and demonstrated. The methodologies and assumptions used to calculate these projections should also be transparently explained. h) Set out that up front information should also include an explanation of why that Party considers its INDC to be fair and ambitious, drawing on information gathered during the domestic preparation processes, including any indicators and criteria used. As such the other information section of the Annex of the INDC decision should be moved into the mitigation section in order to include the mitigation data gathered by Parties as part of the domestic preparation process. i) Set out an international process to consider and analyse the INDCs presented by Parties to take stock of the aggregate level of ambition in relation to the below 2 C objective as well as facilitate the fairness of individual efforts. This process should take place in 2015, starting at the latest at the ADP session in June, and be completed before COP 21 so as to allow for finalisation of mitigation commitments in Paris. j) Further elaborate on the international process with the following elements: The Secretariat to compile the INDCs and summarise them into a technical paper. Discussions should take place under ADP. After the first quarter of 2015, discussions could be set in the form of panel meetings or workshops with the possibility to have question & answer sessions following presentations from Parties. Those with the largest emissions should be prioritised to ensure the largest possible coverage of GHG emissions, noting that it is important that all Parties make ambitious mitigation efforts. International Organisations, think tanks, civil society or other independent bodies with relevant expertise could be invited to present their own findings/analysis on the basis of the INDCs presented. The modalities and timing of the process should be outlined. Following the international process, Parties could step up the ambition level of their contribution before finalisation at COP All the elements presented above are crucial to ensure that we create the conditions necessary to adopt in Paris a 2015 Agreement with the highest level of mitigation ambition from all Parties in the context of the below 2 C objective. Some of these elements are already included in the INDC Decision. However, some aspects are not addressed with sufficient precision or detail, and others are absent altogether. We urge the co-chairs to consider the above points when guiding Parties towards the next iteration of the Decision. Page 6 of 20

7 4. The EU also supports the need for Parties to complement their INDCs with non-binding low-emission development strategies. This is another aspect that is not reflected in the nonpaper or in the INDC decision. The scope of INDCs 5. The INDC process was conceived and designed specifically with mitigation in mind. The focus and scope of the INDC process should be to assist all Parties to bring forward, compare and discuss proposed mitigation measures and ambition ahead of Paris. 6. A number of Parties from across the negotiations have highlighted the difficulties with adaptation and finance INDCs, including: technical problems; different timeframes for underlying processes; and the additional burden imposed ahead of Paris. 7. Adaptation and Means of Implementation are crucial elements that will have to be addressed in the 2015 Agreement as part of a balanced and successful outcome at COP 21. They have their own unique challenges which call for effective and tailor made approaches. Further ideas in relation to these areas are set out in sections E and F below. C. A MULTILATERAL RULES-BASED REGIME FOR TRANSPARENCY AND ACCOUNTABILITY Introduction 1. Warsaw sent a clear signal that Parties want to further strengthen the multilateral rules-based regime. An international legally-binding rules-based regime including clear and robust MRV and accounting rules is fundamental in the context of nationally determined contributions. It is the only way to achieve transparency and accountability and create trust in the new regime. 2. While flexibility is important in a context where we need to account for a range of commitment types and consider national capabilities and circumstances, it must be limited. We have to find the right balance so that we do not undermine transparency, accountability and ambition. We need a core set of rules that apply to all Parties and other rules differentiated according to commitment type. The EU cannot support an approach that differentiates rules in a binary way according to the static Annex of the Convention. 3. By a rules-based regime, we mean all rules required to guide the definition and implementation of commitments. These include MRV arrangements, which ensure a sensible approach to the detailed quantification and tracking of progress towards commitments, and accounting rules including those for the land-use sector and for international carbon markets. We also mean the procedures and institutions necessary to operationalise these rules, including the timing and frequency of reporting and review cycles, the role of expert review teams and the UNFCCC Secretariat as well as the institutional arrangements necessary to assess and address compliance. Page 7 of 20

8 4. There is enough time between now and Paris to develop the necessary rules to enable Parties to firm up their mitigation commitments at COP 21. We don t need to agree the whole rulebook, rather focus our efforts and: (i) prioritise the work up to Paris on those rules which have significant impacts on the level of effort implied by commitments; (ii) agree in the 2015 Agreement in Paris provisions setting out the key elements of the MRV, accounting and compliance regime; and (iii) provide clear guidance for the work that needs to happen after Paris. We cannot allow the timetable agreed in Warsaw to slip and we cannot have a situation where rules agreed after Paris significantly change the level of effort represented. 5. It is not practically possible, or necessary, to have all of the technical detail agreed in Paris. The majority of rules will be further developed after Paris and, in particular, technical rules required for the implementation of commitments. To this end, the COP 21 should set out work programmes for the further elaboration of these technical rules. 6. We recognise that Parties have different, but evolving capabilities and data availability can improve over time. As a result, the commitments put forward by Parties in Paris could for example be impacted after COP 21 by data improvements. We are open to discuss how this could be accommodated in the context of the 2015 Agreement. The rules-based regime in the 2015 Agreement 7. By Paris, Parties need to define the basic regime principles and obligations of Parties that will be laid down in the 2015 Agreement itself as part of the future rules-based regime. 8. Key principles that maintain the integrity of the commitments should be agreed both in Lima in the INDC Decision (see Section B above) and should also be included in the 2015 Agreement at COP 21: a) Commitments should be transparent, quantifiable, comparable and verifiable. b) Commitments should be defined in a way that allows for quantification in terms of tonnes of CO 2 equivalent. c) Commitments should represent a progression from previous levels of ambition and scope over time and Parties should maintain a mitigation commitment at all times. d) Parties should aim to account for all significant emissions and removals of greenhouse gases. e) Parties must define methodologies, rules and assumptions used to frame their commitments (e.g. those used to calculate BAU projections). 9. In addition, the 2015 Agreement itself should include: a) Recognise that accounting should include significant sources and sinks and be increasingly comprehensive through progressive inclusion of sources and sinks over time. b) A provision to ensure that once a gas, sector, category, activity area of land or pool is accounted towards a commitment, it should continue to be accounted for in the future. c) A provision that allows for the development of a comprehensive MRV framework that specifies the information necessary to assess compliance with commitments and that this information shall be reported in accordance with guidelines to be elaborated after COP 21. Page 8 of 20

9 Such guidelines would define frequency of reporting and linkages to the reporting under the Convention. d) A provision on the use of common metrics and methodologies based on those accepted by the IPCC and adopted by the COP. e) A requirement for Parties to periodically report consistent time series of greenhouse gas emissions and removals and to put in place and maintain national arrangements for monitoring and reporting for the purposes of the 2015 Agreement. f) A provision for the verification of such information in accordance with guidelines developed by the COP after Paris once we gain more experience with International Consultation & Analysis and International Assessment & Review. With regard to the assessment of GHG inventories, review teams should provide a corrected estimation when inventory estimates are missing or not based on agreed methodologies. g) A requirement to be methodologically consistent between the reference chosen to define a commitment and the calculations used during its implementation. h) A recognition of the role of market mechanisms alongside two specific provisions: Providing for the international use of markets towards quantified commitments, subject to the application of robust accounting rules which ensure that the environmental integrity and the integrity of the mitigation commitments are maintained and double counting is avoided and a requirement for Parties to elaborate such rules including eligibility criteria; Providing for a UNFCCC defined market mechanism or mechanisms for the certification of mitigation outcomes which promote scaled-up mitigation action, entail a net contribution to global mitigation efforts and contribute to sustainable development. There should be a requirement for Parties to elaborate modalities and procedures for the mechanism(s) including participation criteria. i) The key principles for accounting for the land-use sector, including: Avoidance of cherry picking, for example Parties should not only account for removals by sinks but also need to include emissions by sources. Parties should account for fluxes of emissions and removals, or changes over time, not for the stocks themselves. Parties could be able to use a voluntary provision to deal with natural disturbances. Accounting for the land-use sector should be based on realistic and meaningful reference levels in order to maintain the integrity of the commitments. Such reference levels should mainly be based on historical data (i.e. base year/period); or based on projections consistent with long term trends in historical emissions. j) A provision to allow for the development of rules on the circumstances under which reference levels can be changed. k) A provision establishing a compliance system applicable to all Parties along with its key governing principles, the detail of which could be elaborated and adopted after COP 21. Page 9 of 20

10 10. Finally, COP21 should establish work programmes to develop the more specific guidance according to the principles and rules agreed in the 2015 Agreement. This will be necessary to ensure effective implementation and should be completed before the entry into force of the 2015 Agreement. Treatment of the rules-based regime in the co-chairs' non-paper 11. Although many of the important elements of the 2015 Agreement's MRV, accounting and compliance rules base are touched upon to some extent in the non-paper, it would facilitate progress if those elements were to be further elaborated and time dedicated in the ADP in October to more detailed discussions on the rules-based regime. We would like the range of aspects of the rules-based regime fully reflected in the elements of the draft negotiating text we will agree. 12. Furthermore, in the elements of the draft negotiating text, the sections on transparency of action and on transparency of support should be separate (not combined as in the non-paper). Although both elements are important to the 2015 Agreement, the substantive provisions in these sections will be different. We would also like the section transparency of action to be called transparency of action and accountability. 13. It is important that the non-paper includes references to a compliance regime applicable to all Parties. Effective implementation requires more than transparency alone. Linking the compliance regime with the technical review in the MRV/accounting framework would allow the compliance regime to assist Parties in the consistent implementation of their mitigation commitments, MRV/accounting requirements and other commitments relevant for the compliance regime, as well as to assess and address compliance. COP Decisions in Paris 14. Parties should aim at developing MRV and accounting rules, including those that could substantially impact the level of effort implied by commitments, through decisions at COP 21. These may be further developed and improved over time. 15. Such COP Decisions could include: a) A COP Decision agreeing that common metrics should be based on the 4 th Assessment Report of the IPCC and the common methodology should be based on the IPCC 2006 guidelines. It is worth noting that the IPCC methodology has a built-in tier system that gives Parties flexibility in the way they measure their emissions and removals. b) A COP Decision defining the rules for changes to the reference level a Party chooses. Such changes should only be allowed in limited circumstances (e.g. changes should increase ambition). Page 10 of 20

11 c) A COP Decision on the land-use sector to define in more detail the accounting approaches that are acceptable. For example, such a decision could agree that both activity-based accounting and land-based accounting are possible as long as the methodologies to estimate emissions and removals are based on those accepted by the IPCC. Parties should be able to build on existing methodologies defined under the Convention and the Kyoto Protocol with a view to starting a work programme after Paris in order to streamline and improve these accounting approaches for use in future commitment periods. d) A COP Decision on carbon markets that defines the detailed accounting rules and eligibility criteria, and the modalities and procedures for a mechanism(s) along with participation criteria. These decisions can build on the work ongoing under the Framework for Various Approaches and the New Market Mechanism. D. A CYCLE FOR REGULARLY STRENGTHENING MITIGATION AMBITION IN THE 2015 AGREEMENT Overview 1. The 2015 Agreement and accompanying COP decisions should set out a process for regular consideration and analysis of the level of ambition represented by mitigation commitments against the below 2 C objective (the cycle of commitments, distinct from the process to establish, consider and analyse INDCs before COP 21). Defining a cycle of mitigation commitments that promotes ambition over time is crucial. 2. The process needs to take place in the context of the latest science and with the objective of ensuring that the 2015 Agreement puts us on a long term mitigation and transformation pathway consistent with having at least a likely chance of ensuring that the below 2 C objective is achieved. In that context, the 2015 Agreement should set out a long-term goal consistent with the latest findings of the IPCC. 3. The process should encourage Parties to: (i) raise the level of existing mitigation ambition, if necessary; and (ii) formulate ambitious subsequent commitments. The process needs to be simple, efficient, avoid duplication of processes and be inclusive of all Parties. Only the Party concerned may change in its mitigation commitment or the ambition of its subsequent mitigation commitments. Page 11 of 20

12 4. The following characteristics of the cycle should be included in the 2015 Agreement: (i) The process should require all Parties to the 2015 Agreement to maintain a mitigation commitment at all times in order to facilitate Parties to progressively increase their level of mitigation ambition which should represent a progression from previous levels of ambition and scope over time. (ii) The process should take place regularly, be based on the latest science, apply to all Parties and be facilitative. Furthermore the steps of the cycle should be applied to all Parties to the 2015 Agreement in the same year, so creating political moments which allow for comparability and the mutual trust and confidence for Parties to be as ambitious as they can. (iii) The 2015 Agreement should contain a simplified procedure to allow finalisation of mitigation commitments, or adjustments of existing commitments, in a timely manner and without the need for further formal ratification. The procedure should clarify that only the Party concerned may propose a change in its mitigation commitment or the ambition of its subsequent mitigation commitments. 5. In an accompanying COP decision agreed at COP21, we should be set out the details on modalities of the cycle. This would allow the cycle to be easily strengthened over time if necessary. 6. More specifically the decision should set out that the regular review of the ambition of mitigation commitments, should: a) be repeated every 5 years b) be an international process that facilitates the transparency, clarity and understanding of mitigation commitments, whereby the ambition and fairness of Parties mitigation commitments can be considered in light of their contribution to the below 2 C objective c) be facilitative, transparent and encourage Parties to come forward with ambitious mitigation commitments or adjust existing commitments upwards d) create a common understanding and enable comparison of mitigation commitments by allowing Parties to explain their commitment and why they think it is fair and ambitious e) be informed by science and be evidence-based, and also be guided by considerations of evolving capability and responsibility 7. Further consideration needs to be given as to how the cycle could be facilitative and positively build on wider opportunities. The co-chairs' reflections note 8. We consider the co-chairs' reflections note of the June session v (the reflections note) as a basis to further discuss how a post-2020 cycle of mitigation commitments could work, including in relation to the matters raised above. However, we note some issues below. Page 12 of 20

13 9. The EU is currently working towards a 2030 climate and energy package. Working towards this timescale will help provide business certainty and investor confidence. This will not lock in low ambition. The mitigation contributions that Parties finalise in Paris should lock in only the lower limit of ambition, not the upper. In that context a robust cycle of mitigation ambition within the 2015 Agreement that facilitates adjusting mitigation ambition upwards if necessary is needed to ensure that all Parties collectively and individually stay on track to achieve the below 2 C objective. We work with a carbon budget approach in the EU, so our level of effort between 2020 and 2030 will be very visible. Commitments put forward by other Parties would need to be equally visible. 10. The reflections note sets out options for a cycle of review based on the two proposed options of 10 or 5 year target periods. There is a real risk of chaos if Parties are able to pick different target years, especially regarding ensuring comparability. We will need to consider this issue further. But discussions should be limited to the two options of 2025 or As stated above, all Parties should have the same process for a 5-yearly review. The mitigation ambition of all Parties should be reviewed in the same year. This notion is not captured in the reflections note. 12. Under the 2015 Agreement finalisation of new mitigation commitments, or upward adjustment of existing ones, should be done using a simplified procedure. Other processes that should inform the review of mitigation commitments 13. It is useful that the reflections note highlights that the ambition cycle could be informed by other processes such as MRV of existing commitments, the periodic review under the Convention, and the IPCC AR cycle. We should aim for maximising coherence and efficiency throughout the whole process. However, the co-chairs' diagram fails to acknowledge the need to move to a common MRV framework over time. 14. In addition, the reflections note is not clear that when Parties come forward after 2020 with future proposed commitments, those proposals must be accompanied with up front information that meets agreed requirements. E. ADAPTATION in the 2015 AGREEMENT Introduction 1. Climate related hazards and altered hydrological systems are already impacting all countries, especially those that are most vulnerable. Science shows that climate related impacts will continue to grow and further exacerbate the impacts being experienced around the world. Page 13 of 20

14 2. It is of utmost importance to act individually and collectively to reduce risk through ambitious mitigation action and actions to prepare for and adapt to the adverse impacts of climate change. Mitigation and adaptation are thus equally important to achieve climate resilient sustainable development and the 2015 Agreement should aim at maximising synergies between them. 3. The co-chairs' non-paper reflects the range of views expressed by Parties and the EU is ready to engage on that basis. Work and discussions in the run-up to Paris should focus on the elements of the 2015 Agreement as well as how we can enhance and strengthen ongoing efforts in supporting COP decisions. 4. Below we set out key ideas for what needs to be part of the Paris outcome on adaptation, as well as setting out how to take adaptation forward to COP 21 and beyond. These ideas should provide input and strengthen aspects of the co-chair s non-paper. What do we need to do in the ADP? 5. Towards reaching a successful outcome at COP 21, Parties must continue to engage on how to best: a) Recognise adaptation as an essential element to achieve the ultimate objective of the UNFCCC as set out in its Article 2, its relationship and synergies with mitigation, it being part of climate resilient sustainable development and that it relates to all Parties. b) Promote measures to address climate impacts and risks to secure climate resilient and sustainable development. c) Facilitate planning and implementation of national adaptation measures with the objective of increasing climate resilience of national sustainable development. d) Build on and further the ongoing work under the Convention. e) Promote coherence and cooperation at all levels and across related policy areas (e.g. transboundary risks, systematic observation, early warning). f) Strengthen and promote synergies with actors outside of the Convention. g) Facilitate the mobilisation of means of implementation to support adaptation actions in those countries that need it, especially those particularly vulnerable to the adverse effects of climate change. h) Enhance the monitoring and review of adaptation action and its outcomes to support informed decision making and guidance by the COP as well as allowing for the flexibility to incorporate and improve provisions in response to future evolution in knowledge and experience (in line with the EU position outlined in the recent submission Reporting guidelines on national communications by Annex I Parties vi ). Page 14 of 20

15 Process to take forward and support adaptation actions 6. The process to take forward adaptation actions should comprise: (i) Negotiation of the 2015 Agreement and supporting decisions to anchor and strengthen adaptation provisions; and (ii) Continued implementation of the Cancún Adaptation Framework (CAF), as well as continuation of support (finance, technology, capacity building) provided bilaterally as well as multilaterally. The 2015 Agreement: 7. The provisions of the 2015 Agreement should do three things: (i) Recognise the global adaptation objective as the achievement of climate resilient sustainable development for all Parties (ii) Reinforce the commitments of all Parties to continue to formulate, plan and implement measures to facilitate adaptation in the context of increasing the climate-resilience of their national sustainable development to communicate these through their National Communications. (iii) Call to assist the efforts of those countries that need it and are particularly vulnerable to the adverse effects of climate change, including through provision of financial and technical support (including for capacity building). 8. Through these provisions, the 2015 Agreement will provide further visibility for action and support for adaptation, and strengthen the monitoring and reporting provisions under the Convention. 9. The 2015 Agreement should provide an anchor for the existing adaptation framework as a lot of progress has been made. Parties should build upon the framework while furthering the work under the Convention, including through the 2015 Agreement. 10. Together with related COP decisions, outlined below, these provisions would enable greater understanding of the effectiveness of measures undertaken to facilitate adequate adaptation, drawing on national reports and other relevant information, in order to inform further enhanced action to be undertaken by Parties to address climate change. Supporting decisions 11. More discussions will be needed to identify which provisions will be reflected in the 2015 Agreement itself and what would be in supporting decisions. Supporting decisions, building on the CAF, could define milestones which could be useful to improve the effectiveness of national adaptation action, including enhanced international cooperation in preparing and implementing adaptation measures. Page 15 of 20

16 12. Further guidance for Parties to improve the effectiveness of national adaptation action could include: a) facilitating joint learning to enable better monitoring and evaluation of the effectiveness and outcomes of adaptation action. b) the sharing of best practices and lessons learned relevant to assessment of climate risks, planning for adaptation, management of climate risks etc. c) providing guidance to facilitate integration of climate risks into national plans and strategies with an aim to achieving climate resilience of their sustainable development. d) setting timelines for Parties to achieve certain milestones such as integration of climate risk assessments into national development planning. Continued implementation of the Cancún Adaptation Framework 13. Given the extensive work undertaken to date the 2015 Agreement has to recognise that action on adaptation does not start from scratch. The continued implementation of the provisions under the CAF must play a central role in taking forward adaptation: a) The Adaptation Committee (AC) is the overall advisory body on adaptation under the Convention and will continue to act as the main player for more coherence on adaptation under the Convention. It has already started and will continue delivering results in this regard. b) The National Adaptation Planning (NAPs) process plays an important role in contributing to, and where possible facilitating, the adaptation efforts that countries themselves are undertaking to address the impacts of climate change in the broader context of their sustainable development. The NAPs process supports LDCs, as well as other developing countries, in their medium and long-term adaptation planning processes including by integrating adaptation in their general development planning. The EU is committed to continuing to support LDCs and other developing countries, in their efforts to enable them to realise their adaptation objectives vii. c) With the newly established Warsaw International Mechanism on loss and damage a space within the Convention was provided to further enhance the understanding of comprehensive risk management approaches, to strengthen the coordination among stakeholders and to enhance actions and support to address loss and damage. The EU is confident in the Executive Committee s efforts to implement its workplan, which once adopted will facilitate adequate and timely responses to reduce the risks of and address loss and damage. 14. In addition, the Nairobi work programme (NWP), undertaken under SBSTA, assists all Parties (in particular LDCs, SIDS) in sharing information and building knowledge on impacts, vulnerability and adaptation to climate change in order to facilitate informed decisions on practical adaptation actions and measures. While striving for improving the NWP work, including in addressing emerging issues, the NWP will continue to serve as a knowledge hub and will support and strengthen the CAF (Loss and Damage, NAPs, AC) whilst avoiding duplication of functions. Page 16 of 20

17 15. Financial support to adaptation actions is provided bilaterally as well as multilaterally, amongst others by the Adaptation Fund, the Least Developed Countries Fund (LDCF), the Special Climate Change Fund (SCCF), and including through support to enable mobilisation of private sector financial flows for adaptation investments. The Green Climate Fund, which was mandated to channel a significant share of new multilateral funding for adaptation, should provide assurance of support to the efforts of countries to become more resilient to the impacts of climate change, e.g. with its own "adaptation window" and the decision to aim for a 50:50 balance between mitigation and adaptation over time and a floor of 50% of the allocated adaptation funding to be channelled to vulnerable countries, including least developed countries, small island developing States and African States. F. FINANCE in the 2015 AGREEMENT 1. Our agreed objectives are staying below 2 C and the transformation to low-emission and climate-resilient economies and societies. Means of implementation are crucial for achieving this goal, as well as for supporting the particularly vulnerable, including least developed countries. Climate finance will therefore be an important part of the 2015 Agreement. 2. Climate finance is a means to an end. The 2015 Agreement has to provide the framework for shifting investment patterns towards low-emission climate-resilient sustainable economies and societies. The 2015 Agreement should send clear signals to the private sector and beyond, to contribute to the mobilisation of climate finance and to reorient financial flows to that end. 3. The EU also stands by its own responsibilities, including enhancing our own efforts, not least in providing and mobilising international support. Public finance will continue to play an important role in climate finance post However, public climate finance alone will not be able to get us on track for staying below 2 C and bring about the transformation and investment shifts needed. The IPCC recognises that up to 2029 we need to shift about US$690 billion every year of largely private investments in the energy sector alone towards low-emission alternatives. The 2015 Agreement therefore needs to reflect the importance of the private sector as a source of finance and relevant investment flows for the transformation to a low-emission and climate-resilient world. We recognise that private sector finance is complementary to, but not a substitute for public sector financing where public finance is needed. 4. There is a role for all Parties to take actions regarding climate finance in line with evolving responsibilities and capabilities. This does not mean that all Parties should take the same actions. Finance-related actions in the 2015 Agreement should be differentiated. Some actions should be undertaken by all Parties, while other actions should be undertaken by more capable Parties, with the number of Parties participating increasing over time. Some parties may need support in order to take action, for example some might need international support for capacity building. The need for support may change over time or be met with different means of support. Page 17 of 20

18 5. The range of actions spans from the domestic level to the international level and this diversity should be captured in the 2015 Agreement. Actions could range from improving domestic enabling environments for facilitating climate-proof investments to mainstreaming climate considerations into all policies, promoting the effective use of resources ensuring impact, and mobilising international climate finance. These actions will be an important part of sustainable development. The following diagram shows a possible range of actions on mobilising different sources and on mainstreaming and enabling environments, in relation to evolving responsibilities (for climate change) and capabilities of Parties: most capable / responsible Parties all Parties 6. The 2015 Agreement should reflect the need for global participation in order to effectively mobilise and facilitate the deployment of finance for climate-related actions globally and should encourage all countries in a position to do so to contribute to international climate support and finance for the implementation of action. 7. The 2015 Agreement needs to be dynamic and able to adapt to changing realities and future developments also in respect of climate finance, reflecting evolving capabilities and responsibilities in this regard. 8. The 2015 Agreement should build on the Convention and existing institutions, but it also needs to identify the means by which we can enhance climate finance and reorient investments towards our overarching objective. Page 18 of 20

19 9. The 2015 Agreement should capture the following: a) Anchor the purpose of climate finance as a means to staying below 2 C and to achieve the transformation required. b) Mobilise climate finance through a diversity of actions by all Parties, according to their evolving respective responsibilities and capabilities. c) Recognise the role of finance from a variety of sources, including public, private and alternative sources. Send a strong signal to the private sector at all levels and trigger the required investments and involvement, including of local private sector. Public sector finance should seek to catalyse and avoid crowding-out private sector investments. Private climate finance includes financial flows that are mobilised by public intervention, including in the sphere of policy and regulatory reform. d) Create and improve enabling environments and policy frameworks for low-emission and climate-resilient investments as a key means to facilitate the mobilisation of both domestic and international climate finance at scale. This could include for example the phasing down of high carbon investments and fossil fuel subsidies. All Parties implement and/or improve or more broadly apply the pricing of GHG emissions making use of the range of tools available for reflecting their costs sector-wide and economy-wide, with a view to ensure a level playing field for all. e) All Parties undertake continuous efforts to climate-proof international public finance flows and enhance addressing climate change in the coordination of development aid, keeping in mind a gender sensitive approach. f) Integrate climate objectives into other policy relevant areas such as energy, agriculture, (urban and land-use) planning and transport in order to facilitate the transformation to low-emission and climate-resilient economies and societies. Mainstreaming of climate objectives would need to take place at a larger scale and be fostered by all Parties as well as by all the relevant institutions outside the Convention through strategies, mechanisms, and/or financial instruments to reduce risks and/or improve incentives for low-emission and climate-resilient investments. g) Assist the efforts of those countries that need it and are particularly vulnerable to the adverse effects of climate change, including through provision of financial and technical support (including for capacity building). h) Anchor a dynamic element to be able to adapt to future needs and changing realities and future developments also in respect of climate finance reflecting evolving capabilities and responsibilities. i) Ensure that climate finance will be focused on results and delivers the greatest impact possible. j) Build on the Convention and the existing institutions and architecture, in particular the GCF as a major player in post-2020 climate finance and further enhance its effectiveness. Page 19 of 20