Typical Challenges for
Vertically Integrated
Measurement, Reportingand Verification Systemsof Greenhouse Gas
Emissions

AUTHORS
Cesar Carreño (ICLEI World Secretariat)
Laura Noriega (ICLEI World Secretariat)
Carla Mariño (ICLEI World Secretariat)
Aurore Borsi (ICLEI World Secretariat)

ABOUT THIS REPORTThe report was compiled by the ICLEI World Secretariat as part of
The Climate Footprint Project. It provides an overview of the mostcommon barriers and constraints for an effective implementation

Maryke van Staden (ICLEI World Secretariat)of a national vertically integrated MRV System. Included are

EDITORin order to close the existing vertical gap in a more effective way.

Everica Rivera (ICLEI World Secretariat)
David Bonomo (ICLEI World Secretariat)

recommendations on how these common barriers can be overcome

The results compiled here are based on conducting personal
interviews with state representatives, desk research, and the

DESIGNoutcomes of 11 multi-level governance dialogues held in Brazil,

Matteo Franceschi

relevant literature and projects around the world managed or

COPYRIGHT© 2021 ICLEI - Local Governments for

Mexico, India and South Africa, in addition to desk research from
implemented by ICLEI. These activities took place between 2019and 2021 and relied on the institutional arrangement mapping andexpertise from relevant stakeholders.

Sustainability e.V. All rights reserved. The
ICLEI World Secretariat holds the copyrightof this publication, including text, analyses,
logos and layout designs. Requests to
reproduce or to quote material in part orin full should be sent to carbonn@iclei.org.
ICLEI encourages use and dissemination ofthis case study, and permission to reproduce

THE CLIMATE FOOTPRINT PROJECTThe Climate Footprint Project supported state and regional
governments to improve their efforts to monitor and reducegreenhouse gas (GHG) emissions, namely Pernambuco (Brazil),
Chhattisgarh and West Bengal (India), Baja California, Jalisco andthis material without modification will usually

Yucatan (Mexico) and KwaZulu-Natal (South Africa).

be permitted without charge for non-

Sub-national state and local level greenhouse gas (GHG)

commercial use.
ICLEI – Local Governments for Sustainability
is a global network of more than 2500 local

inventories provide important data to enable policy makers tounderstand GHG emission sources and trends, and, consequently,
improve the design and implementation of emission reduction

and regional governments committed to

strategies for their territories.

sustainable urban development. Active in

The Climate Footprint Project, implemented between February 2019125+ countries, we influence sustainability
policy and drive local action for low emission,
nature-based, equitable, resilient andcircular development. Our members andteam of experts work together throughpeer exchange, partnerships and capacity
building to create systemic change for urban

and February 2021, was led by The Climate Group, as Secretariatof the Under2 Coalition. It was implemented in coordination with
Ricardo Energy and Environment, Greenhouse Gas Management
Institute, CDP and ICLEI - Local Governments for Sustainability.
This project is part of the International
Climate Initiative (IKI). The German

sustainability.

Federal Ministry for the Environment,

CONTACT US(BMU) supports this initiative on the basis

Kaiser-Friedrich-Str. 753113 Bonn | Germany
Tel. +49-228 / 97 62 99-00
www.iclei.org

Nature Conservation and Nuclear Safetyof a decision adopted by the German
Bundestag.

Contents
Introduction4
1. Vertically Integrated MRV Systems

6

2. Data Management 7

2.1 Top-down vs Bottom-up Data Sharing7

2.2 Data Collection and Access8

2.3 Initial Data Collection and Access 8

2.4 Data Aggregation Processes

8

2.5 Diverse Data Sourcing9

2.6 IPCC Tiers and Data Quality

10

2.7 Enhancing Data Comparison and Aggregation
at National and Subnational Levels

10

3. Governance and Policy Making12

3.1 Lack of Decentralization 

123.2 No Clear Roles and Responsibilities 

13

3.3 Lack of Multi-level and Multi-sectoral Governance Policies14

3.4 Gaps in Vertical Cooperation

15

3.5 Misaligned Regional and National Goals

15

3.6 Lack of a Cross-cutting Sectoral Approach for Mitigation Measures

15

3.7 Challenges in Information Sharing 

16

3.8 Financial Resources as a Necessary Instrument

16

4 Capacity Building and Knowledge Sharing17

4.1 Designing a Capacity Building Plan

17

4.2 Individual Capacities

18

4.3 Organizational Capacities

18

4.4 Institutional Capacities and Coordination Mechanisms

19

5. General Recommendations20

Bibliography

233

INTRODUCTION
Tackling climate change requires a coordinated effort

limitations, as well as potentially lacking data collection

at all levels by all actors, from the local to the global

tools, expertise, previous studies, monitoringscale. Committed nations have agreed to do theirinstruments, and databases.

part, defining and implementing their commitments
and plans through their Nationally Determined
Contributions (NDCs), which are at the heart of theParis Agreement. To ensure compliance, it is important
for these countries to develop effective mechanisms
to measure both greenhouse gas (GHG) emissions

THE CLIMATE FOOTPRINT PROJECT: INTRODUCTION

and reductions derived from climate action.

To address these challenges it is suggested thatnational governments integrate their national MRV
system vertically with data and/or MRV systems of
subnational governments in their country. Manynational MRV systems do not include subnational
governance bodies in any substantial way (CIFOR,
2019). However, subnational governments (state,

National level reporting to the United Nations

regional and local governments) are key players in

Framework Convention on Climate Change (UNFCCC)

mitigating climate change, as their decisions influence

includes national communications (NCs), biennial

between 50% and 80% of GHG emissions (UNDP,

reports (BRs) and biennial update reports (BURs).

2009). Their in-situ knowledge and direct contact with

International assessment and review take place, andenvironmental concerns and local actors allow theminternational consultation and analysis are part of all

to react quicker than national governments. As suchtransparency arrangements under the UNFCCC. One

they often create more ambitious climate-relatedof the core mechanisms of the Paris Agreement andgoals and actions for climate change mitigation (NDC

other climate change mitigation agreements is the

Support Cluster , 2018). Having a vertically integrated

development of national Measurement, Reporting and

MRV system enables shared responsibilities, ideally

Verification (MRV) systems for signatory countries. A

with clearly defined roles for each level of government,

national vertically integrated MRV system will enablewith consideration of their respective (required)data aggregation of and data transparency on GHG

resources, objectives and mandates. The impact ofemissions to better predict GHG reductions, andactions can be amplified where both budget andmonitor the impacts of policies and governanceapproach can be aligned to secure coherence andmeasures. For developing countries, creating a MRV

consolidate visions.

system can be especially challenging due to budgetary

4The inclusion of subnational governments in a

WHY THIS MATTERS

vertically integrated national MRV system canbring a range of practical benefits:

States and regions are key to tackling•

ambitious targets; but many lack theclimate change and have set themselves

Accelerating the achievement or extension
of NDC goals, with the additional identified

technical resources and expertise to track

subnational contributions;••and measure their emissions. ThroughAiding in identifying and optimizing thethe Climate Footprint Project, states anddemand and supply of financial, technical, andregions have been equipped to make morehuman resources for all levels of government;

informed decisions on plans for cutting

Providing more accurate data, and relevant

emissions. The project has also supported
them in demonstrating their contributions todata at different scales to cross-check different

national government targets and in inspiring

aspects, offering a level of data sovereignty

further climate action.

for subnational governments to verify national
disaggregated data, also to improve territorial
policy and planning;•

Allowing for the identification of and response
to capacity building needs at all levels;•

Providing more effective and ambitious climatechange planning and implementation, at theappropriate level of government.

This approach can also provide increased
financing opportunities for national and
THE CLIMATE FOOTPRINT PROJECT: INTRODUCTION

subnational governments’ climate planning,accountability and action, due to the ongoingand growing interest in high data-and-reporting
quality standards.
The purpose of this document is to identify
approaches to optimize multi-level governancecommunications and coordination, withrecommendations to overcome common
challenges and constraints.
These are illustrated by case studies from several
countries, including Brazil, India, Mexico andSouth Africa - as part of the Climate Footprint
Project - addressing the differentiated roles ofnational and subnational governments, as well asprivate sector actors.

51. VERTICALLY INTEGRATED MRV SYSTEMS
Measurement, Reporting, and Verification (MRV)

SUBNATIONAL LEVEL:

systems are meant to streamline data collection andaggregation based on principles of accountability,•

action: Local data allows for more precise

efficiency, and data quality. MRV systems vary

understanding of policy needs and impacts,

considerably by approach and are tailored: country

allowing for informed planning of effective local

and/or case specific. Countries may use multiple
MRV systems for different stages of action—one formonitoring emissions, and another for monitoringclimate action.
•

can see that an effective strategy is in place andall stages. Similarly, MRV systems may monitor onlythat the approach being taken leads to results.

GHG outcomes or include non-GHG outcomes alongwith a range of other variables.

•such as the Global Protocol for Community-scale

introduces multi-level governance as a core principle.

GHG Emissions Inventories (GPC), subnational

It addresses communication, coordination, shared

governments can increase confidence levels of

THE CLIMATE FOOTPRINT PROJECT: VERTICALLY INTEGRATED MRV SYSTEMS

methods and responsibilities between two or moretiers. There are several advantages to using a verticallyintegrated MRV systems for both national andother stakeholders and authorities.
•

Create an enabling environment: Vertical MRV
systems are easy to build from and can serve to
streamline effective engagement for multi-level

subnational governments:

governance. Many policies that contribute to the

NATIONAL AND SUBNATIONAL LEVELS:

coherence and effectiveness of a climate action
plan or Low Emission Development Strategy (LEDS)

Support for achieving NDCs: Inclusion ofsubnational governments often results in more
ambitious climate actions, better distribution

do not necessarily have a linear impact on GHG
reductions but rather enhance effective processes
towards monitoring (ICLEI, 2016).

of tasks and more accurate data for informed•

Increase credibility of local action: Following
the latest standard for accounting and reporting,

A vertically integrated MRV system goes further andlevels of government along various administrative

Increase transparency of subnational actions:
Data transparency ensures that key stakeholders

actions—or a singular combined system that records•

Track impacts and benefits of local climate

planning.

Implementing an effective vertical MRV system

Ensure vertically integrated action andrequires understanding and change in three pillars ofreporting: Vertical MRV systems help clarify - for

Vertical MRV management:each level of government - its mandate, roles
and responsibilities. This process efficiency saves
time, clarifies communication and coordination
processes, and streamlines data production andMeasurement, Reporting, Verification Systemuse.
•

Attract national and international funds:
Properly recorded MRV data can be used to provethe effectiveness of the policies and actions for
GHG emission reduction and lead to other impacts
and co-benefits—a key component to securing
international and national funding.

Data Management

Governance andPolicies

Capacity Building

Figure 1. Work pillars for a vertically enhanced MRV system

6

Data Management addresses the access, collection,

2.1 TOP-DOWN VS BOTTOM-UPDATA SHARING

aggregation, organization, storage, and effective use

Before any significant changes are made to createof data. This is a critical pillar for the effective anda vertical MRV, governments must aim for a data

efficient implementation of a vertical MRV system.

sharing system that enables as many levels ofWithin a vertical MRV system, data management

government as possible, but prioritizes states/

works stage-by-stage through a unified, thoughprovinces as a first step.

separate, set of systems. Each stage requires someunderstanding of the common issues to better avoid
or overcome these common issues.
••

There are a range of data sharing frameworks
possible but they all inhabit two general categories;
top-down, or bottom-up. Top-down frameworks

Proper data management as a whole provides thefocus on the data needs and decisions of the nation

following benefits within a vertical MRV system:

level government. They follow a clear top-to-bottom

Provides easier data access for use, validation andhierarchy. Bottom-up data sharing focuses on theaggregation

data needs of those at the local level of government.

•

Saves time and resources in the long run

There are specific advantages to either approach,•Creates a clearer understanding of resultse.g., top-down leads on efficiency and economies•

Prevents data destruction and misplacementof scale, while bottom-up gains accuracy due to•Reduces data errors, offering a system of in-built
checks to identify errors•

Meets data quality requirements often required byfunders

The points elaborated here will help with
understanding what is needed to close the data gap
between subnational and national governments, inorder to implement an effective vertically integrated
MRV system that serves a multi-level aligned strategy.
Typical/common data management problem areas:•

Differentiated approaches (top-down vs bottomup, different data structure)

typically reporting on more data. Bottom-up systems
may also provide better aggregation of data, clarity
on the data confidence level (e.g. its reliability andaccuracy), simplified access for data collection (official
data repositories, hosting facilities and available
channels) and more clearly identified data sources.
Data managed at the local level implies a more direct
involvement in the data collection process, more sothan at the national level. So, in theory, it can be more
apparent when the data is inaccurate or incomplete(USDA, 2015).
The selection of a suitable system will also impact theadministrative mandate of governors and mayors,
who deal with many other localized issues. Bottom--up•

Difficult data collection and accessdata sharing helps to accurately determine troubled•

The differentiated data collection processareas such as local emissions, and clear up pollution•

Diverse data sourcing, reliability of source•

Lack of agreement on IPCC Tiers and data quality•

Data comparison and aggregation at different
levelssourcing issues which often have transboundary
concerns. A common example being transboundary
emissions from commuting, where the fuel waspurchased in one municipality, but used in another/others.

7

THE CLIMATE FOOTPRINT PROJECT: DATA MANAGEMENT

2. DATA MANAGEMENT

2.2 DATA COLLECTION AND ACCESS

2.4 DATA AGGREGATION PROCESSES

A main driver for data provision to an MRV system is

Accurate and uniform data aggregation processes

the timely collection and aggregation of quality GHG

are key to establishing high-quality data and timely

related data for use in national, state and/or local

analysis. However, in most cases, data aggregation

analysis and planning. In order to effectively link thesesystems are not streamlined across the various

data formats within one system, sub-systems whichgovernment ministries or subnational departmentsallow for different variables and constraints of thethat request the data, causing significant loss ofvarious jurisdictional contexts should be integrated.

resources for reporting organizations—public or

Trends that exist on a national scale may not be theprivate. Different government bodies working withsame at the subnational or local scale. Identifying

climate related activity data often request the sameand understanding these patterns enables governing

data but in differing templates, timelines, and data

bodies to better identify root problems and measurequality requirements. By not using streamlined

the effect of policy. Data collection addresses primarily

templates, timelines, and requirements, reporting

activity data, measuring human activity (e.g. kilowatt

stakeholders need to use significantly more resources

hour of electricity used or tons of waste generated) andto create the different data packages. Redundant but

associated relevant meta-data (e.g. when, how, what).

similar tasks to similar organizations often creates

Different countries often tailor MRV structures to suitunneeded friction and cumulative waste of time,

their own needs based on the available stakeholders,

human resources, budget, and technical skills.

resources, needs, and chosen methodologies.

governments), physical, and political limitations canmake data collection in different sectors or industries
difficult. Particularly in developing countries, access

TEMPLATE C

developing countries. Legal (especially for subnational

TEMPLATE B

Data collection and access is often difficult within

TEMPLATE A

THE CLIMATE FOOTPRINT PROJECT: DATA MANAGEMENT

2.3 INITIAL DATA COLLECTION
AND ACCESS

to information may be limited by privacy concerns or
the interests of the data supplier. Further, developing
countries often suffer from insufficient technicalcapacity and a significant lack of available tools,
such as previous studies, monitoring instruments
and databases at all levels. This requires the rapid
development of more permanent staff, effective plans,
technical capacity, and ongoing education—such as
the case in Kenya (Kenya Ministry of Environment
and Forestry , 2020). At the subnational level further
challenges exist. Decades of focusing on national level
reporting has left many subnational governmentswith a significant lack of existing activity data. In places
that do have data, the data is often hard to access,of doubtful quality, incomplete, or too complex.
Incomplete data collection and access for subnational
governments restricts effective policy building andhinders quick responses to local climate related issues.

8

Figure 2. The use of different templates for different
stakeholders requesting the same information from a uniquesource can complicate the data collection process

2.5 DIVERSE DATA SOURCINGMEXICO – THE IMPORTANCE OF UNIFIEDDATA COLLECTION TEMPLATES

Sourcing data for the MRV system will depend on

Throughout the Climate Footprint Project´swhat data is available, which can then determine

multi-level governance dialogues held

which tier (see next section) can be used.

between 2019 and 2021, the states ofHowever, sourcing data of similar complexity

Jalisco, Yucatan and Baja California inacross the different jurisdictional levels can be

Mexico identified that they had been using

challenging. The various types and quality ofdifferent templates and formats for data

data that a government collects from a variety ofcollection from the same supplier, when theydifferent sources often leads to large and hard toparticipated in working ‘tables’ together.

navigate databases with a range of data quality.

They then discussed the need to strengthen

In the absence of an integrated MRV system, thehorizontal communication and harmonize

methodology used can be selected independently

the process in a common effort in order toby each level of government. However, in an

observe more robust and timely responses

integrated MRV system, the tier and methodology(ICLEI, 2019).

selection should align between levels as much as
possible. This helps provide policy makers andexperts with more comparable data in the future.
The decision of which tier of data to use is bestreached through transparent dialogues among therelevant institutions.
Diverse data usage also impacts the need for
effective database management, as cataloging
the data’s various sources and units is important

THE CLIMATE FOOTPRINT PROJECT: DATA MANAGEMENT

to ongoing data quality efforts. Having a sharedtaxonomic and categorization system is imperative
as activity names, units and other details are often
different, although the data measures the exact
same activities and sources. This also has impacts
on meta-data used for enhanced transparencyof collected information. When saving data files,
a shared and established naming and metadata record system is crucial to maintaining
data accuracy. Timeframe, Source, Data Type,measurement methodology, modeling or
extrapolation methods, Data Tier and unit are allimportant information to include.

Photo source: ICLEI ©

9

SOURCE NAME IN

DATA USER’S NAME IN

NATIONAL TOOLSUBNATIONAL TOOL

Livestock Unit

Adult Bovine Unit

Energy intensity per

Per capita use

SECTOR

UNIT

Agriculture, Forestry, andHeads of cattle (inOther Land Use (AFOLU)

thousands)

EnergyKilogram of Oil Equivalent

capita(KOE)/GDP/capita

Units produced

Units generated

Energy - Electricity

Kwh

Number of Passengers

Number of users

Energy - Transport

Hundreds of people

Table 1 Examples of differentiated terminology between Source and End User. Changes which are unexpected and not properly
communicated could hinder the integration of subnational tools and national. These include terminology and sector identification.

2.6 IPCC TIERS AND DATA QUALITY
Often national governments and subnational

THE CLIMATE FOOTPRINT PROJECT: DATA MANAGEMENT

governments are limited by their mandates and2.7 ENHANCING DATA COMPARISON
AND AGGREGATION AT NATIONALAND SUBNATIONAL LEVELS

budgets in regard to the quality and type of data

Similar to issues of data aggregation for IPCC tiers,that is collected, and thus which IPCC data Tiers

subnational governments usually use their own

can be used. A national level government may

methods of data processing to meet their own uniquehave considerable data that would qualify for tierneeds. This may provide them with unique insights,

3 use on the energy drawn from the power grid. A

but it can also create problems when comparing

subnational level government may have similarly

results and data. Since the national standards for GHG

high-quality data on waste management or evenemission inventories are defined by the IPCC (2019)transportation that would qualify for tier 3 use.

Guidelines for National Inventory Compilers, national

However, neither government can use the other’s

governments are locked into using this method.

data without the communication and data sharing

However, by adopting similar methods, throughframework of a vertically integrated MRV systemproper communication and collaboration, subnationalin place. By combining data, governance can allow

governments can bridge the gap and contributefor leapfrogging from less accurate Tier 1 data andmore easily to data sharing while still addressing

analysis to more accurate Tier 3 data and analysis,

their unique situation and considerations - such as

which adds significant confidence.

transboundary emissions or upstream activities.

Further, by coordinating types of data collected and(Environmental Science and Technology, 2009).

IPCC tiers used for the NDC calculations, overall data

Comparability and database aggregation are

analysis, especially at the national and global level,also limited by a lack of understanding of vertical

can be improved by reducing the amount of gap fillingaggregation procedures. Integrating the subnational

needed in analysis that depends on high- and low-governments’ vision and needs may be technicallyquality data.

feasible, but only through political will and areasonable degree of assurance that integration canbe fully realized.

10

For reference, the Global Covenant of Mayors for

SOUTH KOREA – ENABLING

Climate and Energy, has published a guide to their

AGGREGATION THROUGH

Common Reporting Framework, which includes a

ADAPTED TOOLS

recommended mapping of sources and categories

During COP 25 in Madrid (2019), the Korea

to help practitioners aggregate inventories

Environment Corporation – KeCO (a Public

developed with different methodologies (Global

Sector Organization) presented their adapted

Covenant of Mayors for Climate and Energy, 2019).

tool for GHG inventory development, whichallows both IPCC and GPC aligned reportingand export, facilitating aggregation at thenational level. This work reflected the interestof the sub-national actors in showcasing
flexibility and empowerment of sub-national
governments, which are participating inseveral trans-national initiatives which
required The Global Protocol for CommunityScale Greenhouse Gas Emission Inventories(GPC) compliant GHG inventories. These
inventories are additional to the IPCC
inventories requested by the national
government for comparison and aggregation
purposes. KeCO, with support from ICLEIWorld Secretariat, adapted its already existing
tool to export GPC inventories, in addition to
single data input process, moving one step
closer to a successful vertical integration of
their MRV system. To achieve this, a lengthy
process was undertaken which included
mapping of sectors and sub-sectors, as wellas use of real data to test its application. Asof today, the tool is available for cities andstates wishing to have two versions of their
GHG inventory for different purposes. The
tool remains one of the few accredited tools
recognized by the “Built on GPC” seal thatserves sub-national governments.

Photo source: ICLEI ©

11

THE CLIMATE FOOTPRINT PROJECT: DATA MANAGEMENT

IPCC inventories. This was done through a

3. GOVERNANCE AND POLICY MAKING
Governance and policy making enable the conditions

Outside of the practical elements of policy for a

for successful vertical MRV integration and thevertical MRV, it’s important to note that strong

effective fulfillment of NDC goals. Through formal

multilevel governance and policy building can serve toarrangements such as mandates and frameworks,

strengthen stakeholder confidence in a government

policy impacts all anthropogenic environmental issues

as a whole and serve as a foundation for otheror solutions by fostering the development of public

programs. When done well, this framework canand private institutions and behavior. These features

create an increasingly resilient and flexible system

may allow for smoother data collection and will

for adapting to emerging local issues better than adefine the communication, data sharing, and capacity

single level of government can - making it ideal forbuilding systems for the most integrated and efficientaddressing the ever-changing problems presented by

MRV systems possible.

climate change.

Further, it is important that policy and governance

COMMON GOVERNANCE AND POLICY TROUBLE

is used to stipulate, encourage, or provide guidance

AREAS TO BE DISCUSSED ARE:

to all fields of concern within the vertical MRV. While•

Lack of decentralization

sharing are important, the co-creation of policy•

No clear roles and responsibilities

embedded knowledge sharing systems is key to the•Lack of multilevel and multisectoral governance

THE CLIMATE FOOTPRINT PROJECT: GOVERNANCE AND POLICY MAKING

levels of informal communication and knowledge

data heavy requirements of government (Holsapple& Joshi, 2002; Willem & Buelens, 2007). The absence

policies•

Gaps in vertical cooperation•

Misaligned regional and national NDC Goals•

Lack of Cross-Cutting Approach

are also important and serve to encourage and•Challenges in information sharing

empower other policies to be successful. Governance•

Financial Resources as a necessary instrumentof such a political frame in one field—such as capacity
building—may also impact other areas—such as
in-house technical skills. Policy mandates and goals

and policy frameworks for a vertical NDC-related MRV
system can easily be replicated and adjusted to otherdepartments for other fields or to entirely different
administrations, such as state-to-state adoption.

3.1 LACK OF DECENTRALIZATION
Decentralization is the cornerstone of effectivefrom subnational governments; including how data

multi-level governance. It ensures that subnational

and processes are managed and recorded. The

states and local governments are recognized as

development of policies and initiatives calling forsemi-autonomous but dependent, with their own

this might be a strenuous process, which requires alegal powers and relative financial independence

common front by the subnational governments and(Global Taskforce of Local and Regional Governments,

a long-term plan for climate action; indicating for

UN Habitat, UNDP, 2016). The need for effective

the strategy to align and enhance national targets

vertical integration calls for a proper devolution

through sectoral actions and how subnational

process, which can provide more room for action

contribution can only enhance these.

123.2 NO CLEAR ROLES ANDRESPONSIBILITIESINSTITUTIONAL COOPERATIONAPPROACH IN CHILE
In Chile, regional governors decided to

Establishing the roles and responsibilities ofchair a committee on climate change,

subnational states and local governments is

involving public authorities from all levels

challenging, especially where powers overlapof governance. Moreover, this committee

on topics such as transport and waste. Without

embraced both a vertical and a horizontal

clear distinction between levels of governance,

approach by summoning businesses, citizens,

cooperation is made more difficult and progress

non-governmental organizations (NGO)can be slow or ineffective. However, theand academics. This initiative managed toimportance of subnational governments has been

harmonize a climate change perspective

acknowledged in the Paris Agreement, which

within development plans and their local

advocates for a partition of management rights andimplementations (International Partnership

allocation of clear roles for all levels of government.

on Mitigation and MRV, Low Emission
Capacity Building Programme, 2014).

It is essential for both national and statelevels to encourage decentralization decision
making downwards, in order to adequately
empower all subnational actors for local action
and NDC participation (UNFCCC, 2016). Top-THE CLIMATE FOOTPRINT PROJECT: GOVERNANCE AND POLICY MAKING

down leadership and bottom-up action should
be cumulated, and in all cases, bottom-up
governance needs to be more supported,
especially through an apparent delineation ofroles and responsibilities (UNFCCC, 2016). Thoughsometimes a difficult process, clearing up roles
is one of the easiest and most effective ways toincrease efficiency and reduce wasted man hours
for both national and subnational governments.
Further, establishing roles and responsibilities
with the private sector is often challenging
due to differing mandates and goals. However,through dialogue and mutual problem solving,agreement can be reached where a countries’
NDCs and sectoral agendas can align in win-win
situations.
Political differences and power limitations cancreate further challenges in establishing firm roles.
Subnational governments are often not requiredby law to support NDC goals or data collection
for a vertical MRV. Without policy to establish
compliance, roles and responsibilities, subnational
governments are left to their own politicalwillingness, which may vary by administration. Thiscan lead to non-compliance and greater difficultyin establishing a vertically integrated MRV system.
Source: Pablo Garcia ©

13

3.3 LACK OF MULTI-LEVEL AND
MULTI-SECTORAL GOVERNANCE
POLICIES

SOUTH AFRICA – NATIONAL CLIMATECHANGE BILL DRAFT HIGHLIGHTS THE
NEED FOR MULTILEVEL GOVERNANCE
South Africa is currently developing

Multi-level governance refers to a form of politicala Climate Change Bill to support theorganization where authority is established on

coordination of integrated climate change

different scales and is constantly under negotiation

response, including strategies towards

between different levels of government (Daniell &emissions reduction. The draft bill aims

Kay, 2017). To be effective, multi-level governanceat ensuring a transition towards a climate

must be institutionalized with defined roles

resilience and low carbon economy across all

and responsibilities. Stakeholders at all levels

spheres of government in accordance withmust understand the co-benefits of a multi-level

the principles of cooperative governanceapproach, and reach a common understanding,(DEA, 2018). This means integrating all

such as the foundational acknowledgement thatlevels of governance to coordinate andno actor or sector can solve climate change byharmonize policies, plans, programmes anditself. For instance, while ministers of environment

decisions around climate change (Mkhize,

are often mandated to develop and monitor, they2018). According to the bill, a binding

usually lack the actual capabilities to influence

National GHG Emission Reduction Trajectory

sectoral policies (Climate Policy Initiative, 2016). In

THE CLIMATE FOOTPRINT PROJECT: GOVERNANCE AND POLICY MAKING

has to be established and aligned to thesome cases, a pivotal institution may be lacking.

National GHG Inventory and empowered

In other cases, there may not be a need to create

thro ugh Sectoral Emissions Targets (SETs,)

new structures, but instead, to modify and build

which leads to the definition of Sectoral

on to existing ones. In whatever way improvement

Emission Reduction Plans (SERPs) (Abdino,

is carried out, mainstream coordination across all2019). The bill empowers the provinces tolevels should be implemented to allow entry points

establish a Provincial Committee on Climate

into the vertical MRV system for subnational states

Change and indicates their role to prepare(International Partnership on Mitigation and MRV,

implementation plans based on their specific

Low Emission Capacity Building Programme, 2014).

needs (ICLEI Africa, 2018). It comprises thealready mentioned Sectoral Emission Targets(SETs) for key economic sectors and Carbon
Budgets, including a national carbon tax.

Discussion about National MRV, enabling
frameworks and Climate Change Bill in South Africa.
Photo source: ICLEI ©

14

Transition to a vertical MRV system requires not just

3.5 MISALIGNED REGIONAL AND
NATIONAL GOALS

national planning but also subnational planning

Subnational goals (also referred to as RLC – Regional(UNFCCC, 2016). Without planning and practice, there

and Local Contributions) often do not coincide withmay be a mass failure of the implementation of the

NDC goals despite their importance and are thus left

MRV system at subnational levels, as the governments

out of NDC planning. Subnational governments are

and relevant ministries struggle to get up to speed

rarely considered when setting up and carrying out

with a reporting and data collection system that, by

NDC goals. Consequently, subnational contributions

its nature, cannot slow down. Again, it is vital that any

and inventories have not always been taken into

subnational climate actions are aligned with national

account, resulting in real shortages of accurate data.

and international levels, and that communication is

Many countries show no coordination mechanisms

ongoing. Mandates, institutional arrangements, andbetween levels of governance. Communication is

strategies — top-down or bottom-up — can enhanceoften little to non-existent, especially regarding

consistency of decisions and cooperation in climate

climate mitigation actions, GHG inventories and thepolicy across all levels. With regard to institutional

impact of their contributions. But, creating national

agreements, deeply embedding them in policy frames

reporting mandates and guidance to subnational

is required for maximum effectiveness.

governments can be an excellent opportunity to open

Policy weaknesses in formal arrangements is mostoften the root of insufficient data access and data
sharing between all levels of governance. Formalizing
the integration of all actors involved, from the national
to the subnational governments, and dialogue isa way to partially fix this. Evidence suggests thathigher political commitment at a national level alsotrans-governmental communications for a sharedvertical MRV.

3.6 LACK OF A CROSS-CUTTINGSECTORAL APPROACH FOR
MITIGATION MEASURES

increases subnational buy-in and support for national

So far, a sector-by-sector perspective to emissions

GHG goals. This accelerates multi-level cooperation,

tracking is still predominant, either between

and encourages more successful and ambitious

ministries, or in the MRV organization. Each sector

subnational policies as a whole (Internationaltends to only target their own sectoral issues, without

Partnership on Mitigation and MRV, Low Emission

addressing shared intersectoral problems which

Capacity Building Programme, 2014).

may be parts of multiple different supply chains andindustry relationships, and services. In some cases,
MRV systems are not horizontally integrated asthey explicitly focus on one specific sector, such as
Agriculture, Forestry, and Other Land Use (AFOLU)
emissions and mitigation actions tracking, which can
result in a highly fragmented process. Since different
sectors contribute to various types of climate change
issues and concerns, it is important to include a crosssectoral approach to planning and implementing a
vertical MRV or any climate mitigation measures.

15

THE CLIMATE FOOTPRINT PROJECT: GOVERNANCE AND POLICY MAKING

3.4 GAPS IN VERTICAL COOPERATION

3.7 CHALLENGES IN INFORMATIONSHARING

3.8 FINANCIAL RESOURCES AS A
NECESSARY INSTRUMENT

A lack of information sharing is mainly based on

The challenges of meeting adequate climate funding

gaps in communication regarding existing systems,

at all levels cannot be over emphasized. Unfunded

tools, institutional processes, and a lack of adequate

mandates are dangerous and lead to policies not

examples to imitate for subnational governments.

being implemented. Therefore, it is necessary for

The lack of examples is typically due to the absence

national and subnational governments to conductof a dedicated communication space between

financial planning (NDC Partnership, 2017). However,

governments. States should also promote learning

developing countries are often severely strained whenacross relevant actors and levels of governance.

it comes to excess funds for development - even withThrough a vertically integrated MRV system,

international assistance.

regulations can provide a collaborative and knowledge
sharing approach for both the emissions and actions
pillars of an NDC goal.

Before addressing financial resources, institutional
mandates and roles should be clarified, andtransparency systems implemented to minimize
corruption and also map funding use. This is not
only best practice but is often a requirement forinternational funding. It is then imperative to facilitate
financial flows and enhance financial support to all

THE CLIMATE FOOTPRINT PROJECT: GOVERNANCE AND POLICY MAKING

stages of the MRV system (UNFCCC, 2016) in theform of capital flows—public, private, domestic or
foreign (OECD, 2016). International funds can help
subnational governments be more independent
from national funds. Policy can create new income
sources and promote green investment throughenvironmental taxes, pollution charges, subsidies
limited to green technologies, and the support ofearly-stage green sectors. Encouraging green sector
growth also encourages private investment flows,which are indispensable for green growth and private
actor engagement (OECD, 2016). All financial resourcesmust include precise and transparent accounting;addressing the appropriate institutions and actions
through mandates and regulations (Partnership on
Transparency in the Paris Agreement, 2017).

16

4 CAPACITY BUILDING AND
KNOWLEDGE SHARING

4.1 DESIGNING A CAPACITYBUILDING PLAN

Capacity building is at the heart of vertical MRV

A capacity building plan details the activities that will

implementation and development. Sharing skills

be undertaken in a specific time, in order to create

and knowledge between the different levels ofor improve the skills and competencies required togovernment is critical to achieving NDC targets. The

respond to the needs of the MRV system.

building at all levels. Capacity building is an interactive,
participatory and cross-cutting learning processthat highlights the importance of overall knowledge
sharing (United Nations, 2015). Within a vertical MRV,
capacity building should be widespread and carriedout where needed at every level.
Lack of capacity is an especially common issue atthe subnational level. It is often rooted in a lack of
coordination mechanisms and understanding of theoperation and needs of an integrated MRV system. A
shared multi-level governance capacity is important.
According to Corfee-Morlot, et al. (2009), multi-level

To increase the chance of strengthening thecapacities of all relevant stakeholders, the design ofthe plan should be inclusive and create ownership byidentifying and engaging with the target stakeholders
in early stages, and then involving them actively in
discussions and decisions as the process continues.
There are different levels at which capacities can becreated to support the performance of stakeholders
that contribute to the MRV system (Tusiime, Ahumuza,& Kimeze, 2018). The following sections provide
insights to building capacities at the individual,organizational and institutional levels.

governance (in this case, for integrated MRV systems)
helps to avoid gaps between local climate action plans
and national policy frameworks (vertical integration),while encouraging learning across sectors andbetween relevant departments, institutions, or
stakeholders at the local, regional, and national scales(horizontal integration). Multi-level knowledge transfer
allows the actors implementing national climate actionplans to benefit from local initiatives (Corfee-Morlot,
et al., 2009). Knowledge transfer and capacity building
helps to empower local climate action and policy
development while building expertise to address
existing issues around monitoring, reporting andverifying GHG emissions and mitigation actions.
Common capacity building trouble areas to be
discussed are:•Designing a capacity building plan•

Individual capacities•

Organizational capacities•

Institutional capacities and coordination
mechanisms

17

THE CLIMATE FOOTPRINT PROJECT: CAPACITY BUILDING AND KNOWLEDGE SHARING

Paris Agreement is based on country-driven capacity

4.2 INDIVIDUAL CAPACITIESDOMINICAN REPUBLIC –PARTIAL
KNOWLEDGE SHARING OF NATIONALGOALS WITH SUBNATIONAL

Like any nested system, the most basic levels

GOVERNMENTS

of action are as critical to address as higher ormore complicated levels. Individual capacity

In October 2020, a capacity building activity

building aims to enhance the managerial andwas held in the Dominican Republic as part

technical capacities and skills of people withinof the NDC Partnership – Climate Action

an organization (Tusiime, Ahumuza, & Kimeze,

Enhancement Package (NCDP-CAEP). This

2018). Building capacities within individuals

activity was oriented around subnational

will ensure that they have the knowledge andgovernments and intended to align national

competencies to use and apply the methods

goals with those locally implemented.

and tools needed to produce reports in line with

Many cities stated that there was a lack of

the national and international guidelines of thecommunication, as the local leaders were

MRV system. Skills required for reporting include

only partially informed about the Dominican

GHG emissions inventory compilation, Quality

THE CLIMATE FOOTPRINT PROJECT: CAPACITY BUILDING AND KNOWLEDGE SHARING

Republic NDC, which made it difficult toAssurance/Quality Control (QA/QC), utilizing

coordinate strategies. The need for a more

Information Technologies, and more. Internalrobust capacity building and disseminationindividual resourcing and support is criticalprogram was commonly agreed on.

to building larger organizational capacities(addressed in the next section) and facilitates

The Ministry of Environment and Naturalinternal growth capacity as individuals share

Resources, along with the Ministry ofknowledge with other staff and create a robust

Economy, Planning and Sustainablebase of knowledge (UNFCCC, 2020)

Development, agreed to enhance theirresources in order to formulate a robust

It is important to assess how best to retain andcommunication strategy to share timely

disseminate knowledge and individual skills within

and accurate information with subnational

the organization. Financial resources should begovernments (IPCC, 2019). By May 2021, theallocated for this purpose.

Dominican Republic NDC recognized therole of local governments as key for effective

4.3 ORGANIZATIONAL CAPACITIESMulti-Level Governance as an outcome ofthis process.

This dimension of capacity building aims at
establishing an effective and efficient management
at the organizational level. It entails tailored andspecialized training courses, knowledge sharing,membership in capacity building networks, networkbuilding events, collaborative learning, and otheractivities (Tusiime, Ahumuza, & Kimeze, 2018).
Beyond building capacities at the individual level,organizational capacity building aims to create
lasting systems and a base of knowledge that isembedded in an organization and not lost when
individual staff leaves the organization. Such systems
must be supported by sustainable structuresthat ensure long-term organizational knowledge
retention and sustained capacity building (Dagnet,
Cogswell, Bird, Bouyé, & Rocha, 2019).

Photo source: ICLEI ©

18

Providing consistent, timely and appropriate

PERNAMBUCO, BRAZIL –SHARING

guidance can also help to increase retention

KNOWLEDGE VERTICALLY TO ENHANCE

of institutional knowledge in the long run, as

TECHNICAL ASSISTANCE AT ALL LEVELS

ongoing capacity building can function as an

OF GOVERNMENT

incentive to stay in an organization.

In 2019, the State of Pernambuco compiled
its first GHG inventory with support from

4.4 INSTITUTIONAL CAPACITIESAND COORDINATIONMECHANISMS

the Climate Footprint Project, which
included technical assistance from Ricardo
Energy and Environment and WayCarbon
CITATION The19 \l 1033 (The Climate Group,

Enhancing capacities at the institutional level is2019). During this process, the State ofbased on the aim to strengthen inter-institutional

Pernambuco invited a specialist, who had

relationships as a core part of establishing thepreviously worked on the City of Recife’s

cooperative framework that the integrated MRV

inventory, to join the technical team tasked

system requires. As detailed above, capacity

way, the technical capacity developed inlevels ensures the existence of a strong teamthe project was enhanced by prior capacityof experts, capable of effectively performing

building in the URBAN-LEDS project, where

MRV activities within the different institutions.

ICLEI and other partners provided trainings

Institutional capacity building, in contrast, entails

at the local level during the construction ofbuilding the relationship-oriented skills needed to

Recife’s inventory.

enable and solidify partnerships amongst relevant
stakeholders, so they may cooperatively optimize ashared MRV system, or other multilevel and multisectoral systems (Dagnet, Cogswell, Bird, Bouyé, &Rocha, 2019; Tusiime, Ahumuza, & Kimeze, 2018).
Ultimately, an increased institutional capacity
supports the abilities required to develop
comprehensive, detailed and accurate GHG
emissions inventories, and to prepare theinformation needed for the country to submit andupdate its NDCs and BURs. The needs assessment
to design a plan for building institutional
capacities should consider different aspects ofthe partnering organizations—such as current
levels of technical, or staff capabilities to perform
MRV activities or the level of ambition present toimprove MRV-related capacities.

Announcement of Pernambuco’s first GHG Inventory
Source: (Reprodução/TV Globo, 2019)19

THE CLIMATE FOOTPRINT PROJECT: CAPACITY BUILDING AND KNOWLEDGE SHARINGwith compiling the state inventory. In thisbuilding at the individual and organizational

5. GENERAL RECOMMENDATIONSDATA MANAGEMENT
1. Standard template for data collection

4. Enable aggregation and comparison

A commonly shared template that can satisfy the

From a top-down perspective, one of the mostneeds of all involved parties. Such a templateraised concerns was that subnational governments

would reduce response time and increase

might use a different inventory compilation

efficiency in data collection. With a standard

methodology to the national government. This

template, data can be managed/analyzed faster,should no longer be cited as a barrier, as there are

and aggregation processes made more efficient,

several independent initiatives trying to breachserving the national GHG inventory in a morethis gap with the support of specialists or guiding

constructive manner while leveraging bottom-up

documents, along with knowledge sharing for datacooperation.

collection, processing, aggregation and hosting.
The wish to harmonize processes from the central

2. Common period for data collection

government should not limit the decision-making

A recommended shared timeframe for data

THE CLIMATE FOOTPRINT PROJECT: GENERAL RECOMMENDATIONS

collection will help secure proper participation

power of subnational governments, but rather lookof all stakeholders, as they could organize theirfor already available solutions.

resources more effectively according to the

From a bottom-up perspective, the demand forreporting period. The second quarter of the year

timely data on a sectoral basis is a continuous

might be the most suitable time for requesting anddiscussion. National governments often do notcollecting new data relevant to the development

have the most current data readily available dueof the NDC’s GHG inventory for the previous year.

to the fact that creating national inventories

This suggested late scheduling is mostly because it

often takes between 2 to 4 years. In comparison,

will allow time to process and handle any changes

subnational governments (particularly cities)

from post-COP results and communications whichdevelop inventories on a yearly basis and can act

occur in the first quarter of each year and still allow

as an easily accessible database for higher leveltime for data cleaning and consolidation.

government institutions. An effective MRV system

3. Identification of stakeholders and institutions
All relevant data providers must be identified
and synergies between different levels should

should consider the time-sensitive data needs ofstates and provinces.
5. Access to data and information

be highlighted; cities, states and national

Mandates, policies or formal agreements should

governments might have different data sources

secure data access and data sharing across

but eventually these sources feed into each othergovernment levels. The effectiveness of thisthrough different channels, and agreements, ormeasure depends largely on the political will of

mandates. Synergy mapping will help to develop

the policy makers and empowerment of relevant

better data sharing channels in the future.

stakeholders to understand their role in theprocess and the importance of accurate GHG data.
Should there exist conflict between constitutional
mandates and the need for collecting emissions
data, the more reliable course of action is thedevelopment of a bilateral agreement for data
sharing. However, this negotiation process canbe far more time consuming than a centralized
mandate either from the national government or
the state/province.

20

GOVERNANCE AND POLICY MAKING
Examples of mandate related corrective actions

mandates and roles

may include:

One of the most common barriers for effective•

vertical integration is a lack of understanding

properly included in the MRV structure or NDC

regarding the roles of each institution in thegoals

system. This limits the impact of all processes and•increases the gaps that already exist (e.g., political

relation to established targets

differences or lack of financial/technical resources).

•

A communication framework (or strategy) on roles

processes, tools, and capacity sharing platforms

and responsibilities should be included in policy•

development and stand as a critical support pillar

community

to the overall vertical MRV establishment.

Effective maintenance of a mandated direction

7. Enable conditions to reach ambitious

Assuring subnational levels of government are

Checking on GHG emission reductions in
Identifying simpler and more effective
Raising awareness of overall goals through therequires collaborative planning at multiple levels,

objectives

and the participation of not only highly-trained

The goal of a policy is typically to control thetechnical staff, but also experts in management,

behavior of organizations or define public

media, and communication.

strategy. Should these policies not exist or not

For subnational governments, the greatest

involve the relevant mechanisms or stakeholders
that they mean to, ambitious objectives become
untenable and the objectives that are in place
become more burdensome to achieve. A revisionof existing related policies, and creation of newpolicies focusing on the objectives of the vertical
MRV system should be undertaken. This will help
facilitate more effective MRV operations — suchas easier access to data or increased access tofinancial and technical resources.
8. Long-term planning and planned transitions
The need for mandates and long-term planning isparamount. Mandates create clear and apparent
direction and overall objectives. They are criticalto the prevention or correction of deviations fromoverall goals.

challenge is often transitioning into an integrated
vertical MRV system and maintaining theseprocesses through different administrations.
To successfully carry this out, a subnational
government must create plans for capacity
building prior to the initiation of an MRV system,
and also when staff come or leave. This isparticularly important in government systems
which may change staff when administrations
change; as climate planning for subnational
governments can include 10, 20, or even 30 year
goals— such as the 2050 Zero Carbon goal.
9. Enhanced fund management
The various funds and financial resources forclimate action can be centralized into a single,
but diverse “Climate Fund”. The fund MUST
have transparent control and evaluation froman independent and well recognized party. To
plan for a fundraising strategy, stakeholders(private sectors, subnational governments) must
know which financial flows are available or not,by when, and the mechanisms to unlock themaccordingly. They should also be informed on the
Key Performance Indicators (KPIs) prepared inadvance to measure transparency and success ofthe funding.

21

THE CLIMATE FOOTPRINT PROJECT: GENERAL RECOMMENDATIONS

6. Proper communication framework on

CAPACITY BUILDING AND KNOWLEDGE SHARING
10. Identify capacity needs

12. Enhance capacities and establish mechanisms

A capacity needs assessment provides anfor long-term expertise retention

invaluable overview of the existing gaps andA robust and integrated MRV system requires

capacities related to MRV activities, such as

niche expertise, management knowledge, technicaldata collection, GHG emissions accounting,knowledge, and a sustainable organizationaluse of templates for reporting, and abilities forstructure. Individual, organizational andcarrying out data analysis and QA/QC processes,

institutional capacities need to be enhanced

among others. A participatory, transparent, andwhile ensuring the establishment of mechanisms

systematic assessment is essential to identify thefor long-term retention of institutional memory.

needs and prioritize the required resources for

Individuals’ knowledge and expertise should

the establishment of targeted capacity building

guarantee a continuous and accurate processactivities.

for data collection, analysis, storage, monitoring
and reporting—especially in relation to GHG

11. Establish a capacity building planA capacity building plan should be establishedand contain all detailed activities necessary tocreate or improve the individual, organizational
and institutional capacities to fit the needs of thevertical MRV system. The plan should be inclusiveand guarantee ownership at early stages forthe impacts of mitigation actions. These capacities
and long-term expertise retention at the involved
institutions should ensure sustainability in the MRV
system’s operation. Therefore, it is essential tocreate ownership of the related systems, methods,
and processes to build in-house capacities, which

all relevant stakeholders engaged in the MRV
THE CLIMATE FOOTPRINT PROJECT: GENERAL RECOMMENDATIONS

accounting, the related inventories, and tracking

can be supported by external consultants. In

system, including non-governmental actors. It
should facilitate dialogue across stakeholders toenable efficient data flow, knowledge sharing andcommunication regarding ongoing developments
and opportunities for improvement of theintegrated MRV system.

addition, it is important to enable dialogue spaces
and provide continuous and effective access toknowledge while sharing good practices at alllevels.
13. Establish a cooperative framework to enablecapacity building
A cooperative framework for capacity building
should aim at strengthening inter-institutionaland cross sectoral relations for the development
and implementation of an integrated, vertical MRV
System. Strengthening institutional structures
through participatory and cooperative approaches
helps support the sharing of experiences andlessons learned. This in turn can improve thequality of data in the MRV system, through a better
understanding of functions among staff acrossdifferent sectors and institutions. Cooperative
frameworks should also involve agreements fordata and knowledge sharing for all governancelevels and their related stakeholders. Domestic
MRV capacities can also be strengthened byinternational cooperation through projects,
training and technical assistance initiatives
provided by international experts.

22

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23

THE CLIMATE FOOTPRINT PROJECT: BIBLIOGRAPHY• Abdino, B. (2019, July 11). Explainer: Here’s how climatechange law will affect the way you do business in South Africa.
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The views expressed on this document can in
no way be taken to reflect the official opinionof the European Union.

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