POLICY RECOMMENDATIONS FOR THE COP 25
UN CLIMATE CHANGE NEGOTIATIONS
Subsidiary Body on Implementation (SBI 51)
Subsidiary Body on Scientific and Technological Advice (SBSTA 51)
Conference of the Parties serving as the meeting of the Parties of the Paris
Agreement (CMA 2)
Madrid, Spain2 – 13 December 2019
At the UN climate negotiations in December 2018, countries finalized and adopted most of the rules,
procedures, and guidelines to make the Paris Agreement fully operational. During the negotiations inMadrid at COP 25, countries need to finalize outstanding rules for market and non-market cooperationto achieve global climate goals, and advance important discussions related to agriculture and inclusive
participation. The decisions on markets will complete the Paris Agreement “Rulebook,” which alreadyincludes implementation guidance for countries related to mitigation, adaptation, finance mechanisms,reporting, tracking progress, and capacity building.
2019 is an important year for countries to review and enhance the ambition of their nationallydetermined contributions (NDCs) before they begin implementation post-2020. Natural climate
solutions—the mitigation and adaptation benefits that come from nature—are essential for achieving
the agreed global goals on climate change and must be implemented as part of countries’ NDCs.
Conservation International believes that harnessing the full potential of nature to mitigate and help
people adapt to climate change is critical to the success of the Paris Agreement.

Key Recommendations
Conservation International proposes the following specific policy recommendations for
SBI/SBSTA 51 and CMA 2:
Increase efficiency for delivering climate goals and finance through market mechanisms
 Parties should facilitate the generation and robust accounting of emission reduction
transfers across all sectors and enhance the potential for removals by sinks;
 Any emissions reductions transferred from sectors or gases that are not covered in thescope of a country’s NDC should demonstrate robust baselines, monitoring, reportingand verification, and be subject to a corresponding adjustment; and Parties should prepare guidance to facilitate the trading of internationally transferredmitigation outcomes by Party and non-Party actors (such as airlines under the CORSIA–
International Civil Aviation Organization’s market-based measure) in a way that ensures
the avoidance of double counting.

1

Ensure inclusive participation
 Ensure the full and inclusive participation of all relevant actors, such as smallholders,women, indigenous peoples and local communities in climate policy and action, whose
involvement is key to achieving agreed global goals.
Consider critical issues under the Koronivia Joint Work on Agriculture Prioritize the inclusion of smallholder farmers in national planning efforts to incentivize
the protection of forest cover and ensure food security through diversified, sustainable
landscapes.
Harness the role of nature to deliver results for national and global climate action
 In their revised or enhanced NDCs, countries should incorporate both mitigation andadaptation efforts across all sectors, including natural climate solutions (e.g., REDD+,
sustainable agriculture, ecosystem-based adaptation and coastal carbon management).

Voluntary Cooperation on NDCs through the Transfer of International Mitigation
Outcomes
SBSTA, Agenda Item 12CMA, Agenda Item 10
Relevant Documents: Guidance on cooperative approaches (6.2); Rules, modalities and proceduresfor the mechanism (6.4); Work programme under the framework on non-market approaches (6.8)
Article 6 of the Paris Agreement establishes a broad framework for voluntary cooperation among
Parties in delivering climate action. It sets out three approaches through which Parties may interact: 1)
bilateral or regional cooperative approaches via internationally transferred mitigation outcomes(ITMOs); 2) a centrally governed UNFCCC mechanism to contribute to mitigation and support
sustainable development; and 3) non-market approaches.1 Encouraging the transfer of high-quality
emission reductions generated in all sectors, including the land sector, can drive needed flows offinance to climate actions addressing both sources and sinks, particularly in developing countries.
Guidance on Article 6.2 and 6.4 should ensure the environmental integrity of all internationallytransferred emission reductions, while promoting flexibility and higher ambition for meeting global
mitigation goals. To that end, all Article 6.4 units that are internationally transferred should be subject
to Article 6.2 guidance.
Parties are encouraged to consider the following technical elements when developing Article 6.2 and6.4 guidance:

1

Paris Agreement, Article 6, Paragraphs 2, 4, and 8, respectively.

Maggie Comstock
Senior Director, Climate Policy
mcomstock@conservation.org

21.

APPLYING A CORRESPONDING ADJUSTMENT FOR SECTORS AND GASES OUTSIDE OF A
COUNTRY’S NDC
Any emissions reductions transferred from sectors or gases that are not covered in the scopeof a country’s NDC should demonstrate robust baselines, monitoring, reporting and verification,and be subject to the same corresponding adjustment as other transfers. The requirement to“apply robust accounting” and “ensure environmental integrity and transparency” supports theapplication of corresponding adjustments to out-of-NDC-scope ITMOs. Unless both sides of atransaction account for the transfer, a mismatch is created between the sum of the host andacquirer’s inventory emissions and the sum of their accounted emissions. Such a mismatch isinconsistent with a straightforward interpretation of “robust accounting.” Applying special ordifferential treatment for mitigation originating outside of NDCs also risks creating a perverse
incentive for countries to keep those sectors outside their NDCs. Rules should ensurecomparable accounting treatment of all mitigation outcomes, regardless of where they originate
or toward what commitment they are used.

2. APPLYING A CORRESPONDING ADJUSTMENT FOR ITMOS USED FOR MITIGATIONPURPOSES OTHER THAN TOWARD A COUNTRY’S NDC TARGETS
Any effort a country makes to mitigate emissions—whether through activities and sectors
covered in its NDC, mitigation in sectors that fall outside its NDC, or to assist mitigation in othersectors (e.g., international aviation)—is ultimately mitigation delivered toward the ParisAgreement goal of keeping the global temperature increase to well below 2°C and pursuingefforts toward 1.5°C, as well as the UNFCCC goal of avoiding dangerous anthropogenic
interference in the climate system.
Parties must therefore prepare guidance and the necessary systems to facilitate the acquisition
and reporting of internationally transferred mitigation outcomes by Party and non-Party actors(such as by airlines using offset credits towards the offsetting obligations under the International
Civil Aviation Organization’s (ICAO) Carbon Offsetting and Reduction Scheme for International
Aviation (CORSIA)) in a way that ensures the avoidance of double counting.
As agreed at COP 24 in December 2018, Paragraph 77(d) of the Transparency Framework
applies high-level reporting requirements for internationally transferred mitigation outcomesused toward an NDC or “the use of mitigation outcomes for international mitigation purposes
other than achievement of its NDC,” which would include transfers to international airlines under
CORSIA. This language in Paragraph 77(d) is an important foundation for ensuring no double
counting; however, Parties should reaffirm and strengthen this provision in the more detailed
Article 6 guidance.
3. KEEPING ARTICLE 6 OPEN TO ALL SECTORS
Parties should facilitate the generation and robust accounting of emission reduction transfers
across all sectors and enhance the potential for removals by sinks. While specific sectors (suchas the land sector) do not need to be explicitly referenced in Article 6 guidance, the Draft Article
6 Texts include language that could limit or ban the international transfer of mitigation outcomesfrom forests and the land sector and these references must be removed or replaced. See
explanations and locations for text recommendations in the box below.

Maggie ComstockSenior Director, Climate Policy
mcomstock@conservation.org

3

Specific text recommendations to support Article 6 transfers across all sectors 2
Remove references prohibiting activities from Article 5 (the “Forest Article”)
Under Article 6.4, remove “and shall not include actions referred to in Article 5.” Ambitious mitigation
action is needed in all sectors in order to urgently address climate change. Prohibiting international
cooperation in specific sectors that otherwise meet Article 6 guidance would be inconsistent with
the Paris Agreement and undermine global efforts to limit temperature rise to safe levels.
Further, engaging in a sector-by-sector discussion in the context of Article 6 is harmful in securing
optimal guidance for cooperative approaches that ensures consistency and high environmental
integrity. Limiting the sectors from which a country may transfer could undermine their nationalprerogative to voluntarily engage in cooperative approaches for emission reductions that meet thecriteria of Article 6 as well as their sovereign right to choose sectors for climate action.
Article 6.4:

Draft SBSTA Bonn Text, Article 6.4 Annex, Section VI, paragraph 39, bullet (a)Remove limits on sectors with “high uncertainty”
Remove language proposing limits on sectors with “high uncertainty.” In quantifying mitigation
outcomes, all sectors encompass some level of uncertainty. As already outlined in the Definition
section of the text, ITMOs must be measured in accordance with the methodologies and commonmetrics assessed by the IPCC which already include calculations and recommendations foraddressing uncertainty across all sectors. Additionally, several measures inherent in ensuring
environmental integrity (which are included in the text) can address uncertainty, such as conservative
baselines, below BAU emissions projections, and procedures to address any material reversals.
These tools are already sufficient to address uncertainties. Additional limits on sectors would be
confusing, unnecessary and could reduce needed investment in sectors that could make asignificant contribution to the achievement of the Paris Agreement’s mitigation goals.
Additional proposed limits could also potentially discriminate against countries with data limitations,even though they may be fully implementing IPCC-recommended guidance to manage any resulting
uncertainty. This would go against the tenet of equitable implementation under Article 2 of the ParisAgreement. We cannot afford to ignore mitigation solutions that meet Article 6 criteria for highenvironmental integrity if we are to deliver on the goals of the Paris Agreement.
Article 6.2:



Draft SBSTA Bonn Text. Article 6.2 Draft decision, paragraph 4, bullet (l), sub-bullet (viii)
Draft SBSTA Bonn Text. Article 6.2 Draft Annex, Section XI, paragraph 60, bullet (h)Article 6.4:



Draft SBSTA Bonn Text, Article 6.4 Draft decision, paragraph 7 (Option A), bullet (g), sub-bullet (ii)
Draft SBSTA Bonn Text, Article 6.4 Draft Annex, Section XI, paragraph 89, bullet (b)Adjust references to “permanence”
Mitigation outcomes from all sectors are vulnerable to risks that challenge the long-termsustainability of results, including political risks, project management risks, financial risks, market

2

Current language locations are provided for the two sets of Article 6 texts that were identified in the COP 24 outcomes as the starting
point for negotiations at COP 25. These texts will likely change rapidly or be replaced, which would likely render these current text
locations inaccurate.

Maggie Comstock
Senior Director, Climate Policy
mcomstock@conservation.org

4risks, as well as risks from both human actions and impacts beyond human control (e.g., naturaldisturbances). In delivering mitigation outcomes, there are existing guidance and approaches toboth minimize and address any potential for reversals.
References in the text to “permanent” reductions should be replaced by language that is inclusiveof all sectors, such as “address risk of reversals.” This simpler language captures the intent of theoriginal text and is more precise because reversals can be detected, quantified, and addressed, andthe risks of reversal can be quantitatively estimated, whereas "permanence" can never be measured
or guaranteed.
This language should be included in Article 6 guidance, not the draft decision, because existing
IPCC guidance already sufficiently explains how Parties can address reversals when they occur, sono further technical work is needed on this topic. Furthermore, many countries have undertaken
instructive work to assess the risks that could trigger reversals, and Parties may find it helpful toconsult this literature and consider what issues are relevant to their own particular nationalcircumstances.
Article 6.2:



Draft SBSTA Bonn Text. Article 6.2 Draft decision, paragraph 4, bullet (l), sub-bullet (viii)
Draft SBSTA Bonn Text. Article 6.2 Annex, Section I, paragraph 1, bullet (a), sub-bullet (i)Draft SBSTA Bonn Text. Article 6.2 Draft Annex, Section XI, paragraph 60, bullet (h)Article 6.4:



Draft SBSTA Bonn Text, Article 6.4 Annex, Section VI, paragraph 39, bullet (e), sub-bullet (ii)

Adjust language on compensation for reversals
Adjust the reference to, “ensuring compensation of any material reversals.” “Ensuringcompensation” is unclear in this context and should be replaced by “address risk of reversals.”
Article 6.2:

Draft SBSTA Bonn Text. Article 6.2 Annex, Section VII, paragraph 40, bullet (b)Keep references to “emission removals by sinks”
Where bracketed, keep all references to “emission removals,” as this language was alreadyagreed in paragraph 36 of 1/CP.21.
Article 6.2:



Draft SBSTA Bonn Text. Article 6.2 Annex, paragraph 1, bullet (a), sub-bullet (ii)
Draft SBSTA Bonn Text. Article 6.2 Annex, paragraph 1, bullet (a), sub-bullet (vii)

Article 6.4:



Draft SBSTA Bonn Text, Article 6.4 Annex, Section VI, paragraph 39, bullet (a)Draft SBSTA Bonn Text, Article 6.4 Annex, Section VI, paragraph 40, bullet (c)See Joint Article 6 Analysis for COP 25: Recommended Options and Textual Edits in the June2019 Article 6 Text3 for detailed proposed language modifications for the relevant text
locations identified above.

3

Joint Analysis prepared by Conservation International, Environmental Defense Fund, International Emissions Trading Association,
Land Use and Climate Knowledge Initiative, The Nature Conservancy, and Climate Advisers and is available at
http://conservation.org/joint-article-6-COP25.

Maggie Comstock
Senior Director, Climate Policy
mcomstock@conservation.org

5

Koronivia Joint Work on Agriculture
SBSTA, Agenda Item 6
SBI, Agenda Item 8Relevant Documents: FCCC/CP/2017/11/Add.1; FCCC/SBSTA/2018/4; FCCC/SBSTA/2019/L.2
Under the Koronivia Joint Work on Agriculture (KJWA), countries are working to address issues ofagriculture and climate change. The KJWA is jointly implemented by the SBSTA and the SBI, with thegoal to move from technical knowledge towards the implementation of common strategies,arrangements and transformations needed to address climate change throughout the agricultural
sector. These discussions on implementation are essential to ensure agriculture does not drive
emissions from deforestation or other land use change, and to equip farmers with the tools and support
needed to increase resilience to climate impacts while ensuring food security.
To advance the negotiations at COP 25 under the KJWA and build momentum towards further work on
the topic of agriculture, we encourage Parties to: Link the KJWA workshop discussions with national-level policies and interventions that may
be integrated into countries’ NDC revisions, including an explanation of the technical andfinancial support needed. National institutions, processes, and plans are necessary to integrate
land use planning, sustainable landscapes, farming communities, and food security safeguards
into a resilient food system in the context of climate change.
Advance consideration of safeguards as a future topic for discussion, in particular, to prioritize
and ensure the full and inclusive involvement of key actors, such as smallholder farmers andindigenous peoples and local communities, who are crucial to protecting forest cover andensuring food security in a changing climate.

Local Communities and Indigenous Peoples’ Platform
SBSTA, Agenda Item 8
Meeting of the Facilitative Working Group
Relevant Documents: FCCC/SBSTA/2017/L.29; FCCC/CP/2017/11/Add.1; FCCC/CP/2018/10/Add.1;
Informal dialogue between representatives of constituted bodies on the three functions of the Local
Communities and Indigenous Peoples Platform
The Paris Agreement explicitly recognizes the rights of indigenous peoples and local communities in
the context of climate action. Parties agreed to develop a knowledge platform with local communities
and indigenous peoples (LCIP) as a first step to formally recognizing their contributions to addressing
climate change. Under the UNFCCC, countries agreed on the structure of a Facilitative Working Groupto undertake the work of the LCIP Platform with representation from countries, indigenous peoples andrepresentatives of local communities, upon recognition of the local communities’ constituency.
At COP 25, countries will need to finalize and approve the initial two-year work plan for implementing
the functions of the LCIP Platform. In finalizing the 2020-2021 work plan, the LCIP Platform should
ensure the full and effective participation of local communities and indigenous peoples.
The Platform should be accompanied by an effective program to build the capacities of its
constituencies at different levels. One ultimate aim of this work is to ensure that LCIPs’ are able to fully
participate in climate-related processes at the international and national levels, such as the update of
NDCs and National Adaptation Plans (NAPs).
Maggie Comstock
Senior Director, Climate Policy
mcomstock@conservation.org

6