Spreadsheet: 2891f48a-4348-4edc-a59d-c05b955db52a
Sheet: Sheet1

The table below lists the 393 comments received between July and August 2011 from a large constituency of Policy Board members, independent reviewers (see second worksheet) | Unnamed: 1 | Unnamed: 2 | Unnamed: 3 | Unnamed: 4 | Unnamed: 5 | Unnamed: 6
and other stakeholders on version 2 of the Principles and Criteria (version of 30 June 2011)
We have indicated how these comments have been taken into account in Version 3 (October 2011), and invite you to review and comment on this new version.
If we have misinterpreted your comments please do not hesitate to contact us at [EMAIL]
Principle/Criterion (in version of 30 June) | Text (in version of 30 June) | Comment provider | # | Comment | Response from the UN-REDD Programme | #
General |  | Latin America - Caribbean Regional Consultation and Capacity-Building Workshop on Reducing Emissions from Deforestation and Forest Degradation in Developing Countries (REDD-Plus), Including on Relevant Biodiversity Safeguards - participant's report | 1 | It depends very much on their interpretation how comprehensive and strict they will be in practice, i.e. some read very general and may thus include everything - or not. | UN-REDD Programme interpretation will be elaborated in RIMT (Risk Identification and Mitigation Tool). | 1
 |  |  | 2 | It was felt that indigenous and local people's right to land and access to resources was not appropriately addressed in the P&C. | We have added a criterion on land tenure. In addition, the elaboration of indigenous rights to land and access to resources will be provided through the RIMT | 2
 |  | Expert reviewer | 3 | I was extremely pleased to review this paper whose relevance and  overall quality I can only praise.  I think it is important and positive that these "standards" (whose name could imply a normative, pass or fail approach) try to address not only risks but (possibly missed) opportunities too. Due to the disparity of situations among potential REDD+ countries, one could only expect from such a reference document a guidance for opening a sustained and inclusive dialogue towards continuous improvement rather than a one-shot checklist. Very helpful as well is the use of a glossary, a brave but dangerous endeavour indeed as definition talks (especially on "degradation", "forest" and "plantations") seem to have a mesmerizing attraction for negotiators. :-) Final compliment: the annex stresses the much needed consistency with the REDD+ safeguards as agreed in Cancun. | Thank you. The guidance to accompany the P&C has been modified. We will continue to pay attention to negotiated definitions in updating the glossary prior to its finalization. | 3
 |  |  | 4 | Several processes have already undertaken significant work in defining key benchmarks for REDD+ safeguards. In defining the S&E P&C, UNREDD adds its new perspective to (inter alia):  • CBD Technical series volume 59 • FAO framework on forest governance • UNREDD Chatham House Guidance for Provision of Information on REDD governance • FCPF work on the SESA and on the readiness package • CARE/CCBA REDD Social and Environmental Standards • Forest Investment Program Results Framework I would have liked the S&E P&C to mention this heritage and to explain how they build upon this collection, or what is their innovative angle/intent/added value | The P&C have indeed benefited from a rich body of work, and we have listed in in Annex 3 the list of sources consulted. | 4
 |  |  | 5 | Same goes with (un)secured land tenure and forest use rights, they do not appear explicitly anywhere in the text (although Criteria 6 and 9 lightly touches upon them) in spite of their broad recognition as key contextual drivers of deforestation and degradation. Here again the criteria should be very concrete: ensuring proper funding/staffing of government agencies essentially paralyzed by the lack of resources could often(a) resolve the claims of hundreds of communities left hanging and (b) prevent conflict around contentious overlapping claims or proposals for new communal reserves for instance. “Actions that could be taken to limit deforestation are generally known. Many concern the clarification of land rights. Mist of the aforementioned countries are characterised by a legal duality, where “modern” land legislation allows only for public or private ownership, without room for local tenure arrangements, whether customary or hybrid. Private titled property still plays a marginal role in the countryside. Augustinus and Deuninger (2005) explained that “in many countries, less than 1% of the country is covered by land titles and a cadastral system." (Source: http://www.pfbc-cbfp.org/doc_rech_en.html?file=docs/research_docs/CIRAD%20Can%20fragile%20state%20reduce%20deforestation.pdf ) | Please refer to the response to comment 2. | 5
 |  | Greenpeace International | 6 | These comments are being submitted in response to the UNREDD Programme Social and Environmental Principles and [NAME] for Consultation (30 June 2011).  These comments should not be viewed as comprehensive but rather indicative of some of the problems we see with the current draft “safeguards.”    Overall, the safeguards are still very vague, many of the criteria resemble in fact principles, it is not always clear what the difference is between the two. The document claims to support “operationalization” of the Cancun safeguards, but in fact it often simply repeats the [NAME] text in slightly different words (eg criteria 3, 11, 12, 13). Some principles are even more vague than the [NAME] text itself, (eg principle 1,2).  Safeguards/Criteria should be implementable and verifiable; it is important to ensure compliance. | We have revised the introduction that now better defines the purpose, structure and application of the P&C. The RIMT also further details how criteria can be operationalized. | 6
 |  |  | 7 | UN-REDD needs to develop clearer guidance as to when and how these safeguards are applied (eg at what point in the program cycle), and in what form and to whom their implementation is reported and how this will be monitored. A crucial element will be a compliance/accountability mechanism to ensure redress for affected people in case of non-compliance. | The points at which the P&C are envisaged to apply are clearly specified in the revised purpose section. We are also working on the development of UN-REDD procedures for reporting and accountability. | 7
 |  |  | 8 | Given the future implications of this work, we believe UN-REDD should distribute an updated draft for further comments before a final version is approved. | Agreed. The public consultation is taking place 15 October to 31 December 2011. | 8
 |  | WWF | 9 | Although WWF is not a member or official observer of the UN-­‐REDD programme, WWF is observing the process intensively and is willing to share lessons from our many decades of forestry, conservation and community development experience to provide input and support to UN-­‐REDD. We would have welcomed formal notification and invitation to provide feedback on the Draft UN-­‐REDD Programme, Social and Environmental Principles and Criteria. Nevertheless, please find below WWF’s comments and recommendations on the Principles and Criteria (P&C). | In this round of comments were actively solicited only from UN-REDD policy board, the Indpendent Advisory Group and a list of independent reviewers. However, we are very grateful for WWF input on the June 2011 draft as well as the earlier (March 2011) draft. | 9
 |  |  | 10 | Process[:] WWF is concerned that the process of developing the document is lacking transparency and appropriate procedures for stakeholder consultation. Recommendations: o Increase transparency and participation of relevant stakeholder. This could be done through direct timely notification and invitations for comments, through public comment periods via the UN-­‐REDD webpage or through notification via the UN-­‐REDD newsletter. | Agreed. Please see response to comment 8. | 10
 |  |  | 11 | Purpose[:] WWF welcomes the intention of the UN-­‐REDD programme to develop tools and guidance to enhance the multiple benefits of, and reduce risks from REDD+.  However, WWF raises concerns that the two purposes of the P&C as outlined in the document may not be achieved. While we do appreciate the more detailed interpretation of the safeguards as outlined in the Cancun agreement, we don’t see appropriate guidance on how these P&C should be applied by countries who are already receiving or are seeking for UN-­‐REDD funding.  It remains unclear how the P&C are harmonised with the ongoing process of providing guidance on information systems under the UNFCCC.  Finally, it seems that the overall purpose of the P&C is reactive rather than proactive, focusing on minimising harm rather than promoting positive change. More ambitious objectives would be welcome, similar to those included in the Forest Investment Program’s (FIP) Results Framework relating to reducing GHG emissions, reducing biodiversity loss and increasing resilience, increasing direct management of forests by forest dependent communities, addressing key pressures/drivers and ensuring predictable future funding. While we recognise that the two documents have different roles, it would be valuable to align the goals of these P&C with the high level objectives of other REDD institutions such as the FIP and FCPF.  Recommendations: o Provide more detailed guidance on policies and processes how the P&C should be applied in order to achieve the desired objectives to enhance multiple benefits and reduce risks of UN-­‐REDD programme activities and to support countries in operationalising UNFCCC agreements on safeguards. o Provide clarity on how monitoring and providing information on the P&C interlink with the guidance on information systems as to be defined by the UNFCCC. o Consider setting out a higher level of ambition in the Purpose section, including a statement to support the ambitions of the [NAME] text and promote the values ascribed to by the FIP. | We have reviewed the FIP results framework and clarified the role of the RIMT in applying the P&C in the "structure and application" section | 11
 |  |  | 12 | Principles and Criteria [:] WWF believes that the P&C, version 2 are generally well-­‐formulated and are a significant improvement compared to version 1. We strongly support the inclusion of the concept of free, prior and informed consent in Criterion 5. WWF is also pleased that a number of our comments and recommendations (as provided to the UN-­‐REDD secretariat on 15th April 2011) on version 1 have been incorporated. We welcome the formulation of Principle 2 on rights as well as an improved and more ambitious Principle 3 on livelihoods. WWF still sees some area of improvement in particular on Criteria 7, 8, 9, 10, 12, 13, 20 as well as Principle 5 and associated criteria 14 and 15. We propose an additional Criterion under Principle 6, to address the risks and potential benefits associated with forest restoration as per the Nagoya objective to restore 15% of degraded ecosystems by 2020. | Specific responses are provided for each principle below. | 12
 |  | IPAM | 13 | IPAM would like to thank you for the revised version of the document in which many of our previous suggestions were incorporated. We believe that this new version is better formulated and presents a significant improvement when compared to version 1. | Thank you | 13
 |  |  | 14 | However, we would like to recommend the Secretariat to come back to the previous intent expressed on page 7 (next steps) of the document “Update on Social and Environmental Principles” and offer a Public comment period via UN-REDD Programme website. In this sense, a formal notification and invitation to provide feedback on this new version would be sent to a greater community and not restricted to Policy Board members. Our suggestion would be that this document could be made available at the public UN-REDD website or using a tool such as Google documents or dropbox that could grant the easy access to a greater community. By doing this, the process would increase transparency and participation of relevant stakeholders. | Agreed. See response to comment 8. | 14
 |  |  | 15 | Some of the concerns we have received from our constituencies was exactly related to the lack of transparency and participation of a greater variety of stakeholders in the process of elaboration of this principles and criteria. We still believe that this set of Principles and Criteria can be improved and by saying this we strongly encourage the proper engagement of a broader community on the process of elaboration. Over the past two years the UN-REDD Programme has made an encouraging start in addressing the need for strong safeguards under the Global Programme, including pioneering global consultations on Free Prior and [NAME], important collaborations on REDD+ governance and the harmonized set of guidelines on stakeholder engagement. Nevertheless, the process of elaborating this set of Social and Environmental Principles and Criteria and corresponding risk assessment tools is being considered by some Civil society organizations as a non-inclusive and transparent one, and risk creating a race to the bottom in global REDD+ standards. This can undermine the work undertaken by UN-REDD Programme so far. | Agreed. Please see response to comment 8. | 15
 |  |  | 16 | Attached you can also find some comments provided by WWF [these were the same comments submitted by WWF independently]. Some other organizations have indicated to us they would be interested to provide comments on this new version of the UN-REDD Social and Environmental Principles and [NAME] but until now we have not received further comments. Maybe they have sent their comments directly to you on the e-mail indicated, since no guidance was expressly offered specifying they would need to forward their comments through the civil society representatives at the Policy Board of the UN-REDD Programme. | Noted. All comments are welcome during the public consultation period, preferably directly by email, and if more comfortable also through our Civil Society and Indigenous Peoples Policy Board representatives. | 16
 |  | Expert reviewer | 17 | I find it difficult to concretely provide other principles and criteria as I am not too familiar with the context / consolidated material that was used for the listing of P&Cs (i asked that this be used as the context section instead). I suggest better clarifying how this listing "practically" packages the Cancun Safeguards for operationalization purposes, because right now, this might not be clear. Especially want to avoid another listing of S&E P&Cs, thus suggested focusing Cancun Safeguards and not target, for now, application to other conventions. | We have noted and added a text box indicating how, while targeting other conventions is not the main focus, the P&C can help countries meet their commitments under a number of conventions. Annex 1 also shows the relationship of the proposed principles with the Cancun safeguards, while noting that they may not comprehensively cover all issues raised by the safeguards. | 17
 |  |  | 18 | Good luck. I think if the writers sat down with a clearer picture of how this consolidates the existing P&Cs of other standards/orgs/facilities then define what constitutes as "practical" P&Cs, then it should be ok as a first attempt to provide the elements of the "REDD+ system to provide info on how REDD+ safeguards are addressed." | The primary purpose of the P&C is not to provide elements of information system; however, in combination with other tools and approaches, the P&C can contribute to countries' efforts towards this. | 18
 |  |  | 19 | If I recall correctly back in Rome in November, there was talk of consolidating all UNDP,UNEP, FAO Social and Envi P&C into one more practical and streamlined version. Is this the one? If so  this has to be made clearer, or should be presented as an initial effort to do so. | The latest draft of the SEPC has been developed in collaboration between UNDP and UNEP, with input from FAO, under the UN-REDD Programme. | 19
 |  | Facilitated consultation - Viet Nam | 20 | Unfortunately, we made last minute arrangements and most participants did not see the P&C before the meeting. Please keep this in mind, when you read the comments (see attachment). I did not make any attempt to obtain consensus. I think some comments made by one participant are worthwhile considering without a consensus. It was not necessarily clear to all participants whether the P&C were for the UN-REDD Programme or for the REDD+ Viet Nam Program. It's not always easy to see the difference. Again, please keep this in mind when you review the input. In general we had a good session, although it was dominated by foreign staff, as the discussions were in English only. As a facilitator, I somewhat failed to involve the Vietnamese more. Regardless, I think there were some good comments. The comments consist more of questions than actual changes to the text. We (at least I feel that way) felt that it was up to the UNDP/UNEP team to respond to the questions than providing some new text. | Noted. | 20
 |  |  | 21 | There was a general comment from a number of participants that we should stick as much as possible to the text in the Cancun Agreement and do not invent new terminology. | While we have strived to improve this, some new terminology is unavoidable in order to elaborate on the Cancun Agreements. | 21
 |  | Expert reviewer | 22 | While the principles and criteria seem to fairly comprehensive, I am concerned that they are very high level and general, and that no guidance is provided on how they could be actually implemented on the ground.  To make these more useful for policymakers, they need to provide much more specific guidance on what countries would need to do to actually apply the principles and criteria and monitor their effectiveness. Otherwise, these will simply be a set of high level principles that no one knows how to operationalise. | The Risk Identification and Mitigation Tool seeks to address this comment | 22
 |  |  | 23 | I am also a bit concerned that some of the principles may be mutually exclusive- i.e., if a country designs its REDD+ activities to contribute to poverty reduction strategies, this may result in a very different set of REDD+ activities than if the country designs its REDD+ program to meet biodiversity and ES goals. There is no recognition in the document that  REDD+ cannot possibly fill all of these goals at the same time, and that tradeoffs will need to be carefully identified, explicitly articulated, and carefully managed.  It would be good to make this clear somewhere in the text. | Good point on trade-offs. Criterion 16 aims to ensure that they are considered in land-use planning. For further internal discussion with the aim of addressing in supporting text. | 23
 |  | Denmark | 24 | We find the proposed [NAME] to be both comprehensive and well written and can only support it becoming an official UN-REDD document. | Thank you | 24
 |  | Norway | 25 | Regarding the principles and criteria in themselves, we find these well drafted. | Thank you | 25
 |  |  | 26 | We still think that how the principles will work in practice should have been spelled out more clearly in the draft, e.g. where and how the principles will be used in the process of programme approval?  Will they apply only at national programme level, or also at e.g. project implemental levels? Are they a necessary criteria for UN funding – or merely guidance to countries? | Please refer to the response to comment 8 | 26
 |  |  | 27 | Relation to other standards and principles : with a wide range of standards and principles related to safeguards now co-existing within the REDD-space, a rationale for the UN-REDD principles and criteria must be well explained, as well as how the work burden on countries will be minimized: What are the added value off the UN-REDD P&C´s, particularly when seen in relation to other standards related to safeguards (e.g FCPF SESA, common approach, CBA-CARE; see below) and how will the application of such other standards be seen as proof that a country is complying with the P&C´s?  There has recently been an extensive process to open up the FCPF for additional implementation partners (the common approach). UNDP (and possibly FAO) will be central to this approach, as implementation partner(s) in countries that are members of the FCPF – and some of these countries are also members of the UN-REDD Programme.  Some FCPF-countries will not be requesting the services of UN-agencies as implementing partners within the FCPF, but are still members of both the FCPF and the UN-REDD.  It is therefore very important that there is a clear idea on the different safeguard procedures through each process (FCPF/FCPF common approach/UN-REDD) and how they are overlapping, in order to reduce the burden on the countries. | We hope that the P&C will serve as a contribution to common delivery standards; the fulfilment of the P&C can be demonstrated through existing processes when these exist. | 27
 |  |  | 28 | Further development and operationalization. One of our previous comments were that the “elaboration” column was unclear. The column is now deleted. This makes us wonder if not some indicators and “means of verification” should still be developed? How is this envisioned? | The Risk Identification and Mitigation Tool will address this. We were also seeking to have the P&C as clear as possible on their own and therefore not need elaboration. However the means of verification point is important. | 28
 |  |  | 29 | Finally, it is not clear what sort of approval will be sought in October at the PB meeting. Will the document presented be final or will you seek approval as a basis to begin testing the principles with a few countries? How will this “testing” be carried out? | The P&C are presented to the Policy Board for information in October. In Nigeria for example, ground-truthing the P&C involved technical consultation to review simultaneously the P & C and the national programme document, articulating the implications of each for the other and recommending changes as needed. October - December 2011 is the public consultation process and further pilot testing of P & C and RIMT with interested partner countries. | 29
 |  | Expert reviewer | 30 | The revised set and accompanying text is an improvement on the earlier draft, largely by making the principles and criteria more explicit, without the need for separate elaboration. Reorganising some of the principles and criteria, and adding two more criteria, also helps to sharpen their focus and coherence. | Thank you | 30
 |  |  | 31 | We could go on forever arguing about the details, but the value of these principles and criteria, however expressed, will only been known once they are implemented and their effects assessed. This is perhaps the weakest point of the current text: there is nothing on implementation (perhaps it is taken as read), and it isn't clear how or when the effectiveness of these P & C are going to be determined. | Please refer to responses to comments 7 and 29 | 31
 |  | WWF Viet Nam | 32 | Thank you for the opportunity to provide feedback on the UN-REDD Social and Environmental Principles and Criteria (P&C). Unfortunately we were unable to attend the consultation workshop on 5 August, however we hope that you will consider WWF’s comments when further improving the P&C. We are very pleased that UN-REDD is seriously considering these important social and environmental issues. We are also very pleased to note the inclusion of the concept of free, prior and informed consent in Criterion 5. Although the P&C are generally very well formulated, we propose the following amendments / additions: [amendments/additions are identical to those proposed by WWF International, although not all the WWF International amendments have been proposed by WWF Viet Nam] | Thank you | 32
 |  | Expert reviewer | 33 | In order to achieve Objective 1, in particular the review and assessment of national programmes, especially if the review and assessment will have an impact on funding from the UN-REDD programme, the P&C will need to be accompanied by a tool and process for assessing performance.  The proposed Risk Identification and Mitigation Tool will need to clarify what performance is ‘good enough’ and how this will be assessed, which bodies are responsible for what aspects of the assessment and will need to include a process to ensure accuracy of the assessment (eg. independent verification, stakeholder review or another approach).  The assessment mechanism needs to be given careful consideration due to the importance of these issues for people’s livelihoods and UN-REDD’s mission, the attention they receive from civil society organizations in the host country and internationally, and the sensitivities about evaluation of performance of a national programme related to sovereignty.  The REDD+ SES initiative has been developing a similar mechanism to address these issues since 2009, for a slightly different set of principles and criteria, working with a range of countries including several participating in the UN-REDD programme and we are keen to share this experience.   We look forward to learning more about UN-REDD’s Risk Identification and Mitigation Tool and we hope that there will be opportunities to collaborate prior to finalization of the next draft of the tool in December 2011. | Thank you for these relevant points about the tool (and associated policy / guidance); the input from the REDD+SES experience is very welcome, and we will continue to coordinate with the REDD+ SES teams during the development of the tool. | 33
 |  |  | 34 | When developing the REDD+ SES we followed a widely accepted structure of standards (see International Social and Environmental Labelling Alliance (ISEAL) and in particular guidance on setting standards   ) based around principles, criteria and indicators that define the issues of concern and the required levels of social and environmental performance:  Principles are fundamental statements about a desired outcome. They often provide greater detail about the Objectives. The criteria and indicators flow from the Principles.  Criteria are the conditions that need to be met in order to achieve a Principle.  Indicators are measurable states which allow the assessment of whether or not associated criteria are being met. Following this structure, the set of criteria for each principle are intended to be sufficient to demonstrate that a principle is being met.  This approach does not appear to have been followed for the UN-REDD P&C.   We recommend that you add an explanation of the functions of the principles and criteria. | A clearer definition of principles and criteria has been inserted, drawing on ISEAL definition. | 34
 |  |  | 35 | There needs to be greater clarity about what these principles and criteria apply to.  One assumes that they apply to the policies and measures of the National REDD strategy but this is not made explicit and there could be confusion if there is some expectation that these principles and criteria should apply more broadly. | Please refer to responses to comment 7 | 35
 |  |  | 36 | There is no requirement that REDD+ activities comply with national and local laws. | This is a cross cutting issue that will be addressed in the RIMT | 36
 |  |  | 37 | While principles 5 and 6 seem quite balanced with the social principles (ensure no harm and maintain and enhance), principle 7 seems overly detailed to merit position as a principle.  If there is an important emphasis on minimizing indirect adverse impacts on biodiversity and ecosystem services, there should surely be something similar for social impacts.  In practice, both principle 5 and principle 7 could be very appropriate as criteria within Principle 6 since they are both important elements of an overarching objective of maintaining and enhancing biodiversity and ecosystem services. | Principle 7 has been altered to cover all impacts non-forest ecosystems; more emphasis on protection of the non-forest value rather than avoidance of the impact also increases harmony between social & environmental principles. | 37
 |  |  | 38 | It should be made clear, as for the social benefits, that maintaining and enhancing biodiversity and ecosystem services should be evaluated against the conditions of the reference land-use scenario that is used for the assessment of emissions reductions. | A forest service is a REDD+ benefit when it is retained or enhanced because of REDD+. This could be evaluated against a reference scenario, but this is outside the frame of reference of the UNFCCC safeguards. But REDD+ activity in accordance with UNFCCC safeguards should aim to enhance other social and environmental benefits (not against ref scenario). Requirement for reference scenario is burdensome also desirable;  this may be included in the tool as best (rather than good) practice | 38
 |  | Facilitated consultation - DRC | 39 | Formulation is clear, simple and targeted - except for principle 4 -and should strive to remain this way | We have attempted to reformulate principle 4 more plainly | 39
 |  |  | 40 | Could be made clearer whether criteria are an exhaustive validation of the principles or specific elements derived from the principles | Please refer to the response to comment 34 | 40
 |  |  | 41 | The fiduciary principle makes the P&C different from other international tools | Noted - this observation links to whether we are focusing on a UN/UN-REDD specific reality or aiming to be more comprehensive. | 41
 |  |  | 42 | There lacks a specific mention of land issues in a principle of criterion | Please refer to the response to comment 2. | 42
 |  |  | 43 | The question as to whether there should be a principle targeting indigenous peoples specifically was debated, [[NAME], but no consensus was reached] | Noted. | 43
 |  |  | 44 | Proposal to have a principle for natural forests and a principle for planted forests | Principle 5 addresses protection of natural forest, Principle 6 addresses maintenance & enhancement of services in all forest. We felt that addressing the UNFCCC safeguard on conversion of natural forest directly was important; and equally that enhancement of environmental benefits should be encouraged across all REDD+ activities. We re-worded Criterion 17 to 'planted and natural' rather than 'new and existing' to ensure that planted forests are considered. The RIMT will then to address both explicitly and separately. | 44
 |  |  | 45 | Question on Collaboration/harmonization with the World Bank [comment: raised on several occasions by international (not national) participants in the DRC meeting] | Thank you for this valid point. While we have not directly addressed it in the new draft version of the P&C, we seek to continue engaging with partners on ways to articulate the relationship between different processes, which may vary according to national circumstances. | 45
 |  |  | 46 | Question on the level of teeth and monitoring/reporting on the P&C [comment: raised on several occasions by international (not national) participants in the DRC meeting] | As per the language in the revised draft, the UN-REDD Programme is committed to providing access to grievance mechanism to address complaints regarding the enforcement of the Programme's P&C and operational guidance, and is currently exploring ways to do so. | 46
 |  | Facilitated consultation - Nigeria | 47 | In discussing the P & C, participants frequently found that further elaboration and/or examples were needed to help with understanding the meanings of the P & C and how they should be applied | The RIMT will address this | 47
 |  |  | 48 | The need for elaboration and discussion [is] crucial; the role of the Tool here is vital | The RIMT will address this | 48
 |  |  | 49 | There is still a considerable difference between the ‘Social’ P & C (i.e. principles 1-3) and the ‘environmental’ ones (P5-7), with P4 being somewhere in the middle.  At least part of this difference is due to the fact that the social P & C (or at least P 1 & 2) deal principally with aspects of process, while the environmental ones are more related to outcomes.  On the whole, people are more used to thinking about process than about outcomes,  and there may be a need for being more explicit about  the different assessment and other implications here. | Noted, with thanks. We have included a clearer definition of the Principles and Criteria. Governance principles are often indeed both a matter of means and ends. The difference between Social and Environmental areas should be smaller in the RIMT. | 49
 |  |  | 50 | It would be helpful to make more obvious which terms and concepts have additional explanation included in the glossary, perhaps using formatting (and hyperlinking).  It would also be helpful to offer, for more complex terms, synonyms or substitutes that could be used in outreach materials aimed at a wider audience. | We have made efforts to clarify language in the glossary, which now has hyperlinks to the terms used in the P&C. | 50
 |  |  | 51 | A question was raised about whether the P & C should address somewhere the question of long term security of food resources | Thank you for this comment, which we have found relevant both as part of a sustainable development goals (Criterion 16) and as a driver of deforestation. The role of forest in providing food can also be relevant. the RIMT will  reflect this issue, but we feel that policy development on this area is outside scope of REDD+. | 51
 |  | Indian Law Resource Center | 52 | In general, we recommend that the Social and Environmental Principles and Criteria (Principles and Criteria) are reformulated to more specifically address the rights of indigenous peoples. | This will be elaborated in the RIMT, especially under criteria 7,8,9 and 11. We have also elaborated principle 2 that now refers to "human rights, statutory, customary and collective rights" | 52
 |  |  | 53 | As a UN agency, the UN-REDD Programme (UN-REDD) must adopt strong safeguard policies as established by the UN itself.  UN-REDD cannot have it both ways.  The United Nations Declaration on the Rights of Indigenous Peoples (UN Declaration) adopted by the General Assembly, the highest UN agency, and the UN Special Rapporteur report on “Indigenous Peoples’ Permanent Sovereignty over Natural Resources” are key instruments for UN-REDD policy development purposes.  We hope UN-REDD serves as a leader in this area to encourage other multilateral climate initiatives to incorporate full respect for the human rights of indigenous peoples in every REDD+ program. | UN commitment under each criterion will be elaborated in the RIMT | 53
 |  |  | 54 | Finally, the Indian Law Resource Center (Center) is disappointed that UN-REDD has not exhibited more openness and transparency with this process.  We note that UN-REDD did not publically disclose the Social and Environmental Principles and Criteria (Principles and Criteria).  Civil society organizations only obtained copies of this important policy document because an official on the UN-REDD policy board member shared it with select organizations.  In the future, we expect UN-REDD to share such important policy documents with the public and allow for a public comment period. | We hope that the current public consultation process (October- December 2011) on the latest draft is addressing these concerns. | 54
 |  |  | 55 | International law standards on the rights of indigenous peoples should be more effectively incorporated into the Principles and Criteria.  The current draft includes language on the process of FPIC, but provides no context.  It is not clear what decisions would be governed by FPIC.  Instead of just referring to FPIC, the Principles and Criteria should also emphasize the substantial rights of indigenous peoples to self-determination, self-government and to own and control their lands, territories and natural resources. | Please refer to response to comment 52 | 55
 |  | IAG (WRI participant) | 56 | It is great that the UN-REDD Programme has started thinking about social and environmental policies and procedures; however, there are some concerns with the document given what it states it is trying to do | Noted. We hope that the current version alleviates these concerns. | 56
 |  |  | 57 | Criteria seem incomplete. If other documents flesh out the P&C in more detail, they might complete the picture, but it is not easy to assess. Stated purposes include both using the SEPC when defining UN-REDD funding, and supporting countries in operationalizing Cancun safeguards and other international agreements. Unclear how the document will help to do this | Please see response to comment 7 | 57
 |  | IAG (Forest Peoples Programme participant) | 58 | Recommend a broader consultation process with civil society and IPs and make sure the necessary clarifications are made, including providing all the background material, so that constructive comments can be made regarding improvements | Please see response to comment 14 | 58
 |  |  | 59 | Suggest organizing a workshop back to back with Panama meeting, to give an opportunity for the SEPC to inform civil society about the rationale behind the SEPC and extra guidance, and get feedback. | While we could not organize such an event in Panama, we are considering this suggestion. | 59
 |  | Expert reviewer | 60 | In general, I find that the proposed P&C are comprehensive, well-defined and practical. Congratulations for the excellent job! As a result, I only have a couple of small comments | Thank you | 60
 |  | Expert reviewer | 61 | I am wondering whether we would like to refer anywhere to the principle “Do No Harm”. | The existing principles reflect this aspect, seeking to avoid harms and promote benefits. | 61
 |  | International Development Law Organisation (IDLO) | 62 | Our warmest thanks to FAO for the opportunity to review these interesting and helpful draft Criteria related to REDD+. We have only a few general comments to offer, and certain specific note, which we hope might useful to your review process. | Thank you | 62
 |  |  | 63 | First, as the stated purpose of the Social and Environmental Principles and Criteria (SEPC) is to support countries to implement the safeguards for REDD+, and to ensure that activities funded by the UN-REDD Programme promote social and environmental benefits and reduce risks from REDD+, careful attention might be given to ensure that SEPC is widely known to stakeholders and that consultation timing is appropriate, particularly at the national and the grassroots levels, in interested countries. Broad and structured consultation on the SEPC is necessary to ensure consistency with the essence of the safeguard itself. | We hope that the current public consultation process (October- December 2011) is addressing these concerns. | 63
 |  |  | 64 | Second, in terms of ways to further develop the document, we suggest that the SEPC might greatly benefit from a careful international legal analysis as compared to the treaties and policies mentioned in the Context section, in particular with regards to how it is supported by, and links to international obligations and practices in the UN Convention on Biological Diversity, its COP decisions and protocols, and other relevant treaties, well as the “Gold Standard” for voluntary carbon credit. | Noted. UN commitments under each criterion will be elaborated in the RIMT, and a legal review may indeed be helpful during the process to make sure this is comprehensive. | 64
 |  |  | 65 | Third, the current draft of the SEPC is still a bit broad and general, which might affect its ability to achieve its full potential for deep and lasting impacts. The SEPC might benefit by including more detailed analysis, as well as indicators by which performance in achieving human rights, economic and environmental protection can be measured. | The details of indicator questions will be elaborated in the RIMT. | 65
 |  | Expert reviewer | 66 | The UN-REDD S & E - P & C represent another set of generic guidelines to those already developed and/or currently being tested. | Noted. | 66
 |  |  | 67 | In the absence of either indicators or clear guidance on establishing baselines, it remains unclear how operational these will be. Furthermore, the S & S – P & C is not clear in terms of “….identifying the information needed to report on how the safeguards are being addressed and respected” (p. 2) | We have revised the language under the purpose statement to clarify this point. | 67
 |  |  | 68 | A notable gap in terms of key principles, is the public right of timely access to credible information, and attendant grievance/redress mechanisms associated with the design, validation, verification and implementation of REDD+ policies, programmes and projects. | Criterion 3 was revised and now addresses accessibility of information; criterion 2 now includes reference to feedback, complaints and grievance mechanisms | 68
 |  |  | 69 | The S & E – P & C are extremely weak with regard to good governance which, in effect, are limited to Principle 1 and Criteria 1-3. Given the poor governance contexts in many REDD+ countries that have benefited from and/or applied for UN-REDD and/or FCPF funding, this is a little surprising. Most of the drivers of deforestation and forest degradation exist outside the forest sector per se, and are invariably linked to weak governance arrangements. In contrast, there is, perhaps, an over-emphasis on biodiversity and ecosystem services. At minimum, there need to be criteria for i. a process to identify and prioritize the forest governance issues that a national or sub-national REDD+ programme may be able to address and ii. an MRV system of governance reforms. | The criteria under principles 1 and 2 have been revised and cover a more comprehensive set of governance issues . With regard to the second comment, the purpose of the P&C is not to establish an assessment process, but guidance and tools offered by the UN-REDD programme, included those referred to in the RIMT, address this aspect. | 69
 |  |  | 70 | The relationship of the S & E – P & C to other social and environmental guidelines and standards is unclear (cf. [NAME] alia the CCBA-CARE REDD+ Social and Environmental Standards; CIFOR’s Guide to Learning about REDD+ | Please refer to response to comment 4 | 70
 |  |  | 71 | Similarly, the relationship to other related national initiatives in response to the outcome of the AWG-LCA in Cancun is also unclear. For example, a national 3-phase consultative process was initiated in Indonesia by the Government of Indonesia in February 2011 | This will have to be taken into account in the context of each country. | 71
 |  |  | 72 | It is not clear at which scale (or scales) the S & E – P & C will be applied i.e. national, sub-national and REDD+ Project. | The P&C primarily apply to national UN-REDD Programmes, as defined in the purpose section, and can be adapted as suitable for other purposes. | 72
 |  | 22 Civil Society Organisations: joint letter | 73 | Over the past two years the UN‐REDD Programme has made an encouraging start in addressing the need for strong safeguards under the Global Programme, including pioneering global consultations on FPIC, important collaborations on REDD+ governance and the harmonized set of guidelines on stakeholder engagement. However, the Social and Environmental Principles and [NAME] (SEPC) and corresponding risk assessment tools threaten to undermine work undertaken thus far and risk creating a race to the bottom in global REDD standards. | Noted. | 73
 |  |  | 74 | The UN‐REDD Programme Social and Environmental Principles and [NAME] and associated Risk Identification and Mitigation tool (RIMT) are intended “to support countries in operationalizing the UNFCCC agreements on safeguards for REDD+” and to ensure that activities funded by the UN‐REDD Programme “promote social and environmental benefits and reduce risks from REDD+.”   However, the SEPC do not represent a robust, comprehensive or useful elaboration of the REDD+ safeguard provisions of the [NAME] decisions in relation to providing REDD finance. We also consider that they have not been developed in a sufficiently transparent or participatory manner to be viewed as credible by stakeholders in the UN‐REDD process. | Please see response to comment 14 and and direct feedback to IAG | 74
 |  |  | 75 | The first complete version of the SEPC was only made available to the Policy Board at its 6th meeting in March 2011 and has yet to be made available for public comment.  At the 5th meeting of the Policy Board in November 2010, a public comment period was included in the proposed process for elaboration of the SEPC in 2011, yet to our knowledge no such public consultation period is being planned prior to consideration of a final draft of the SEPC at the 7th Policy Board meeting this October.  The process for developing the RIMT has been even less transparent and inclusive. To our knowledge, these tools have not been subject to any formal review by the Policy Board or the broader group of stakeholders.  Tools such as the SEPC and RIMT, which are to be used for assessing national programme delivery, need to be developed and evaluated together in a transparent and participatory process to ensure legitimacy and efficacy in their stated aims. | Please see response to comment 14 and and direct feedback to IAG | 75
 |  |  | 76 | The SEPC contain significant gaps in their interpretation of the Cancun safeguards and lack sufficient detail in those elements that have been elaborated. Principles 1 and 2 on democratic governance and stakeholder rights, for example, are most notable for their deficient interpretation of the relevant [NAME] safeguards.  Given the now widespread recognition of the importance of land issues and indigenous rights, the failure to include reference to either tenure reform or to the UN Declaration on the Rights of Indigenous Peoples is a serous omission.  More broadly, all the criteria are insufficient, both in terms of the breadth of the interpretation and the detail concerning procedures that would be used in applying the criteria. There are a number of important processes that could be considered when looking especially at the first four Cancun safeguards, including related international agreements and practices, the UN‐REDD Programme’s own work in developing Guidance for the Provision of Information on REDD+ Governance and work by the World Bank and FAO on a framework for assessing and monitoring governance, or the REDD Social and Environmental Standards. We suggest a place to start may be looking at these documents. | Please see response to comments 2, 4, 7, 52 and 53. | 76
 |  |  | 77 | In addition we are very concerned with any language that indicates that this document could be used by countries in their interpretation of the Cancun language on safeguards, or “in identifying the information needed to report on how the safeguards are being addressed and respected.”  Apart from the incomplete interpretation of the safeguards themselves, the document provides a selective interpretation of the implementation language on the safeguards (i.e. paragraphs 69 and 71(d), which need to be interpreted completely and together). We note that Parties and observers to the UNFCCC are currently in the process of developing guidance on the provision of information on how the safeguards are addressed and respected. We are concerned that this language in the SEPC risks undermining that process by developing incomplete and deficient guidance in a non‐inclusive manner. In their present form the SEPC do not provide a useful elaboration of the Cancun safeguards or of the safeguard provisions. The process and outputs so far have not convinced us that the SEPC has any value added relative to other processes where safeguards are being elaborated. | We have revised the section on operationalization in the purpose statement, to clarify that SEPC are not intended as a substitute for the process under UNFCCC. The draft RIMT is to released during the current public consultation period for concurrent review with the SEPC, and will provide more detailed guidance. | 77
 |  |  | 78 | We think that for this document to be more useful, it should focus on providing clarity as to how the UN‐REDD Programme will ensure that social, environmental and governance risks are addressed.  Specifically, it should be clear how the Cancun safeguards will be applied to existing and future National and Global Programme activities being implemented through the three participating UN agencies.  Additionally, it should also be clear how the UN Declaration on the Rights of Indigenous Peoples and existing international obligations and commitments are being adhered to in the UN REDD Programme.  Meaningful implementation will require the elaboration of a more detailed framework and indicators along with policies and procedures to ensure adequate monitoring, oversight and accountability for how the standards are followed. | We hope that the RIMT addresses some of these concerns, as it draws from and points to specific guidance and tools developed by the UN-REDD Programme to support safeguards, including those regarding engagement of indigenous peoples and forest dependent communities and guidance on free, prior and informed consent. Further, the UN-REDD programme is also working on reviewing and reporting procedures with regards to the use and application of both the SEPC and the RIMT. | 78
 |  |  | 79 | Lastly, there is an urgent need to develop a common set of high standards for use by agencies involved in REDD+ finance when addressing social, environmental and governance risks.   Common standards will increase the efficacy of implementation and help ensure that REDD countries are not over burdened by aproliferation of disparate REDD standards.  The Forest Carbon Partnership Facility has recognized this need by requiring delivery partners to agree to implement a [NAME] to social and environmental safeguards, including the use of an independent accountability mechanism.  We note that as part of this process, it was identified that UNDP lacks an independent accountability mechanism equivalent to that of the World Bank. We welcome UNDP’s decision to develop such an institution‐wide mechanism and urge other UN agencies to examine gaps in their policies and procedures. The UN‐REDD Programme must make more systematic efforts to ensure the full application of the UNDRIP, including the right to lands, territories and resources as well as the right to free, prior, informed consent. This will help the UN‐REDD Programme to ensure that a strong set of high common standards are applied to the activities it funds. | Thank you for this advice. We are also working on the development of UN-REDD procedures for reporting and accountability. | 79
 |  |  | 80 | We therefore strongly urge the Policy Board to:  • Establish a robust, transparent and inclusive consultative process at its 7th meeting to develop high common standards on social, environmental and governance safeguards as well as independent accountability mechanisms, across the three UN‐REDD implementing agencies, incorporating work done by other relevant processes;   • Ensure that any standards developed represent a comprehensive and robust elaboration of the Cancun safeguards, and are based on a complete interpretation of the safeguard provisions;  • Elaborate detailed indicators for the standards, drawing on work by other relevant processes, and clarify what policies and procedures will be adopted by the Programme to ensure adequate monitoring, oversight and accountability for how standards are being adhered to; and  • Review work undertaken through such a process at its 8th meeting in 2012. | Please see response to comment 14 and and direct feedback to IAG | 80
 |  | Conservation International (CI) | 81 | Need for an open process We understand that the UN-REDD Program is in the process of articulating Social and Environmental Principles and Criteria.  We are concerned that this has not been an open process and believe that it would and should benefit from an open call for input and a transparent process.  We provide the below high-level comments on the 30 June version, which we have been able to review. | Please see response to comment 14 and and direct feedback to IAG | 81
 |  |  | 82 | Role of UNFCCC guidance We are glad that UN-REDD is examining how it can promote and support the Cancun REDD+ safeguards.  Any organization contributing to REDD+ implementation has a responsibility to implement those safeguards, which are the minimum standards that should be adhered to in REDD+ implementation.  As countries have also been instructed to develop systems to provide information on the safeguards, the development of those systems should also be part of REDD+ readiness.  However, the UNFCCC guidance is still under development, and it will be important that any policies and procedures developed by countries and agencies like UN-REDD be flexible enough to incorporate and respond to additional UNFCCC guidance as it is developed.   How UN-REDD will respond to additional UNFCCC guidance should be specifically articulated in this document. Will the P&C be revised to reflect additional guidance from the UNFCCC?  If so, that should be noted in the P&C.  If not, it should be acknowledged that while the P&C can help countries “devise a national system for information on how the UNFCCC safeguards are being addressed and respected in REDD+ implementation,” countries will also be responsible for adhering to the guidance developed by the UNFCCC in cases where the guidance goes beyond the P&C. | The purpose statement has been revised to emphasize the supportive nature of the P&C in promoting and building on the Cancun safeguards and providing information on how they are addressed and respected. The P&C are one element of the UN-REDD's body of work on safeguards. We however welcome targeted suggestions to ensure that the P&C are flexible to the outcome of the negotiated elaboration of the UNFCCC safeguards. | 82
 |  |  | 83 | Need for policies and procedures “Policies and procedures” rather than “principles and criteria” are needed to accomplish the articulated goals.  The “principles and criteria” in this document are little more than a re-interpretation of the Cancun safeguards.  Interpreting those safeguards is the role of the UNFCCC, not of UN-REDD.  Furthermore, what UN-REDD countries need at this stage are clear policies and procedures so that the [NAME] safeguards can be implemented as UN-REDD carries on its work. | Please see response to comment 7 | 83
 |  |  | 84 | Achieving the stated purpose The ambition to 1) “provide the UN-REDD Programme with a framework” and to 2) “support countries in operationalizing UNFCCC agreements on safeguards” is well-placed, but we are not convinced that the current document can achieve those two goals.  In particular, it is unclear how the P&C will accomplish the 3 uses relevant to the UN-REDD Programme itself, particularly given that many of the proposals have already been approved by UN-REDD.  In particular, for uses 2 and 3, countries will need to provide information regarding how the national programmes address the safeguards (principles and criteria in this document).  Guidance should be provided as to when and how that information should be provided.  For use 2, provision of that information would need to occur in advance of the submission for UN-REDD funding.  For use 3, information should be provided at regular intervals throughout the programme delivery, however it is not clear how this will happen under UN-REDD, which is only a readiness program. Overall, UN-REDD needs to take a more action-oriented approach.  The high-level language in this document is good rhetoric, but what is needed now is specific, focused guidance that will enable UN-REDD and UN-REDD countries to implement the Cancun safeguards. | Please see response to comments 1 and 7 | 84
 |  |  | 85 | Specific Comments: The above issues, such as establishing more transparent processes and developing policies and procedures, should be prioritized over tweaking the language in the current draft, which is insufficient to achieve its purpose.  However, to the extent that UN-REDD moves forward with the Principles and Criteria as articulated in this document, we feel that a few specific improvements should be made.  As such, below are some comments related to the details of the current draft of the P&C. | Please see response to comment 14 and direct feedback to IAG | 85
 |  | Global Witness | 86 | Based on discussions with interested civil society organizations and our own analysis, we continue to have concerns about the process for development of the Principles and Criteria and associated tools, their comprehensiveness, and how they will be implemented. While our comments reflect some of the concerns raised by other organizations, they should be viewed as the opinions of Global Witness. Other interested civil society organizations have expressed their intent to provide comments on the Principles and Criteria. [NAME] will provide these to the Secretariat separately and requests that they be also considered. Our comments should not be viewed as comprehensive but rather indicative of some of the problems we see with the current draft. They should also be read together with the submissions received from other civil society representatives. Our specific comments are as follows: | Please see response to comment 14 and and direct feedback to IAG | 86
 |  |  | 87 | The 30 June 2011 draft of the Social and Environmental Principles and Criteria gives an overview of proposed uses of the Principles and Criteria but still does not provide enough detail about how the objectives will be achieved using the Principles and Criteria. We would like more information about how, in practice, the Principles and Criteria will be used to review new National Programmes, to assess the delivery of existing National Programmes, and to support countries in operationalising the REDD+ safeguard provisions of the Cancun Agreement. In addition to our continuing concerns about the content of the Principles and Criteria, as elaborated below, we think the modalities for implementing the Principles and Criteria require additional clarity and discussion by the Policy Board. | We recognize the relevance of this comment and seek to elaborate guidance to accompany the P&C and the RIMT (including on reporting and reviewing procedures), based on feedback received by Policy Board members and other stakeholders. | 87
 |  |  | 88 | The application of the Principles and Criteria to activities funded by the UN-REDD Programme will require the development of specific indicators, minimum compliance standards, and policies and procedures that ensure effective and accountable implementation. This should be done in a transparent and inclusive manner, with meaningful input from members of the Policy Board and a full range of REDD+ stakeholders, and ensure coherence with other processes aimed at establishing common, high standards for the implementation of REDD+. We note that the UN-REDD Programme has led participatory processes in developing guidance on stakeholder participation, FPIC and the provision of information on REDD+ governance, that have received widespread support from civil society. The elaboration of the Principles and Criteria and associated tools should build on these efforts and involve a clear, transparent and inclusive consultation process prior to consideration of a final version of the Principles and Criteria by the Policy Board. We support the objective of developing a common set of social, environmental, and governance standards for REDD+ taking guidance from the UNFCCC, but the process should not be rushed, should demonstrate value-added with regards to other processes, and should not attempt to “reinvent the wheel” where guidance from other processes is already available. | Please see response to comment 4, 7, 8, 29. | 88
 |  |  | 89 | Content: We are especially concerned that the Principles and Criteria in their present form do not represent a very high bar for interpreting the REDD+ safeguard provisions of the Cancun Agreement. As you are aware, parties and observers to the UNFCCC are in the process of preparing submissions to SBSTA as it develops guidance on systems for providing information on how the safeguards are addressed and respected. It is critical that any guidance developed by the UN-REDD Programme should advance and not undermine efforts to establish high standards for elaborating [NAME] safeguards in this context. Unfortunately, we find that overall the Principles and Criteria in their present form still represent an incomplete and inconsistent elaboration of the safeguard provisions of the Cancun Agreements. For example: [provides comments on specific Principles and Criteria, included in relevant sections of spreadsheet] | The purpose statement has been revised to emphasize the supportive nature of the P&C to promoting and building on the Cancun safeguards and providing information on how they are addressed and respected. We welcome targeted suggestions to ensure that they are flexible to the outcome of the negotiated elaboration of the UNFCCC safeguards. | 89
 |  |  | 90 | In general, it would be helpful if each of the Principles and Criteria were accompanied by a description of what other processes and inputs informed their development. | Please see response to comment 4 | 90
 |  | CBD LAC Regional Consultation on REDD+ and biodiversity safeguards (co-Chairs summary) | 91 | [General comments on three existing frameworks reviewed: UN-REDD Programme S&E P&C; World Bank Safeguard Policies; and REDD+ Social & Environmental Standards]  These three frameworks were found to be a good basis for covering all main biodiversity risks in principle, and for addressing the '[NAME] safeguards' (UNFCCC decision 1/CP.16). However, not all safeguards are covered equally or sufficiently in all frameworks (a detailed analysis is provided in annex I). Key overall gaps include: | Noted | 91
 |  |  | 92 | (i) There are no specific safeguards that address the risk of inappropriate afforestation in areas of high biodiversity value. The guidance on afforestation, reforestation and forest restoration provided by the CBD in decision X/33 paragraph 8(p)5 could fill this gap, to cover the possibility that such activities are considered as part of 'enhancement of forest carbon stocks' under REDD-plus; | Good point with respect to non-forest ecosystems. This is now addressed in revised Principle 7, focused entirely on non-forest ecosystems. | 92
 |  |  | 93 | (ii) The potential loss of traditional knowledge and of the cultural and spiritual identity of indigenous peoples and local communities is not sufficiently covered. This includes the concern that REDD-related payments could alter and undermine the traditional way of life and related knowledge and customary practices of indigenous peoples and local communities. | Criterion  11 , which will be elaborated upon in the RIMT, covers respect and protection of traditional knowledge and cultural heritage and practices | 93
 |  |  | 94 | It would be useful to further harmonize existing frameworks, to simplify application at country level and allow for compatibility at global level. The standards, guidance, and other related tools developed at the international level should be harmonized to help countries to address safeguards. | Thank you for this valid point. We aim to continue engaging with partners on ways to articulate the relationship between different processes, which is likely to be different according to national circumstances. | 94
 |  | CBD LAC Regional Consultation on REDD+ and biodiversity safeguards (Working Group 2) | 95 | There is a need for greater clarity as to what is included in REDD-plus, e.g. is afforestation and reforestation included in enhancement of forest carbon stocks? This will determine whether current safeguards are actually adequate. | Our understanding is that forest restoration, afforestation and reforestation are all included in enhancement of forest carbon stocks. | 95
 |  |  | 96 | Potential loss of traditional knowledge and cultural and spiritual identity is not sufficiently covered under any safeguard. This includes the risk that REDD-plus and related payments could change and undermine the traditional way of life and related knowledge of indigenous peoples and local communities, potentially resulting in lack of food security. The holistic loss of indigenous peoples traditional knowledge, which includes the loss of spirituality, the lack of education through oral tradition because the forests are places to teach, the deterioration of relationship with the forest which is the center of life and the fundamental base for social and spiritual relationships of ILCs. | Criterion  11 , which will be elaborated upon in the RIMT, covers respect and protection of traditional knowledge and cultural heritage and practices | 96
 |  | CBD LAC Regional Consultation on REDD+ and biodiversity safeguards (Working Group 3) | 97 | [In reference to all three frameworks] Many of the principles cover the risks but are often very general and do not cover all aspects of biodiversity and community risks. | We anticipate that this issue will be resolved when the RIMT is available for review alongside the P&C | 97
 |  |  | 98 | Key gaps exist: o Non-forest ecosystems are not fully protected or considered o Non-carbon ecosystem services are also not protected or considered sufficiently | Please see revised [NAME] and 7 | 98
 |  |  | 99 | Problem of differences between safeguard frameworks – can cause confusion and additional burden on REDD countries. Yet, at the same time, there is a need to use locally accepted and locally appropriate safeguards. | Noted | 99
Introduction and Purpose |  | Expert reviewer | 100 | Move up the whole of section 2 and make it number 1 instead | We have modified these sections. Note that the primary purpose of the P&C is internal to the UN-REDD Programme | 100
 |  | Expert reviewer | 101 | [regarding earlier point about implementation (#31)] This is more than an academic point. Monitoring and assessing policy outcomes is critical to the evolution of effective policies. Is it not possible to have a section on monitoring and evaluation that briefly lays out how we might measure and assess the effectiveness of these P&Cs in serving the ends set out in paragraph 2 of the document ("The Principles and Criteria will serve:...")? What will be the indicators of each of these ends? Without this, how else will we know if these P&C, individually or collectively, are useful?  Trying to come up with useful indicators after the P&C have been adopted, as opposed to developing the P&C and their indicators of effectiveness more iteratively with each other, risks either that the P&C will not be sufficiently explicit for their effectiveness to be measured, or that the intended indicators will not accurately measure either the use or the utility of the P&C.   I appreciate the need to produce a brief document that captures just the essentials. Nevertheless, providing just a bit more detail on how these P&C will be implemented (one paragraph), and how their use and effectiveness will be monitored and assessed (another paragraph, or two), would make this document more workable, I believe. | The RIMT as a companion document will address monitoring and provide some pointers to indicators. Please also note response to comments 7 and 1 | 101
 |  | IAG (WRI participant) | 102 | The document may be perceived as trying to interpret the [NAME] language. Need caution in this sense. Language should be clear in this respect. Need clarity on what the entire basis for the document is. | We have revised the purpose statement to address this concern | 102
 |  | Expert reviewer | 103 | [Comment regarding no. 2 under "The Principles and Criteria will serve"] It seems misleading to place both possible uses of the P&C on the same level. Nb. 2 was not the original intent of the P&C which, probably as a result, are not comprehensive in their coverage of the provisions of the UNFCCC agreements on safeguards (especially the governance safeguards).  You may want to state clearly that the P&C can only help to operationalise some aspects of the safeguards and that this is not their primary purpose. [see revised text below] | We have revised the purpose statement to address this concern; please also see response to comment 82 | 103
 |  |  | 104 | [Comment regarding "devising a national system"] The P&C can help with providing information on (some parts of) the safeguards, but they do not address the wider range of issues countries have to consider when devising their national information systems. [see revised text below] | We agree; please also see response to comment 82 | 104
 |  |  | 105 | 2.  To support countries in operationalizing parts of the UNFCCC agreements on safeguards for REDD+. Countries can use these P&C for various purposes, such as:  • to promote, support and build on the Cancun safeguards .  • to provide  information on how some of the UNFCCC safeguards are being addressed and respected in REDD+ implementation • in demonstrating their achievements beyond carbon, for example in reference to efforts on poverty alleviation and biodiversity conservation | We have revised the purpose statement | 105
 |  |  | 106 | It would be useful to spell out the difference between a Principle and a Criterion. Is the latter a sub-element of the former? Do they perform different functions?  Also, it would be good to give some preliminary hint as to how they are to be used. For instance, should the set of principles only be taken as a whole, or can each principle stand on its own? | We hope we have made the distinction between P&C clearer in the current version. The P&C are intended to be used as a complete set. | 106
Process |  | Ecuador | 107 | It is mentioned that the indicators for social and environment effects of REDD+ will be developed at national level. On one hand, it allows to tailor indicators that suit the national context. On the other hand, it makes difficult to report and compare at the international level. How is it planned to assess REDD+ programmes that will be reporting on compliance with P&C or demonstration achievement based on different indicators? | Of necessity, indicators will differ according to differing goals across national programmes. As long as indicator rationale is sound and explicit, assessment can be made.  Differing indicators would only cause problems if aggregation across countries was anticipated, which it is not. Please also note that the RIMT will also play a role in providing specific indicators common to all national programmes. With regards to the secondary purpose, the P&C will be supportive to the national context. | 107
 |  | Expert reviewer | 108 | This process will support the initial operationalization of the [NAME] guidance and safeguards for REDD+, ... | We have revised the text in the purpose statement to highlight that point | 108
 |  |  | 109 | [Comment on "This process will support the initial operationalization of the [NAME] guidance and safeguards" text] I think this should be the clear objective of the P&C instead, and not the target conventions/agreements set out in the context that I note might be a bit too ambitious and would blunt the purpose of the P&C | We agree that the P&C can help countries to develop national approaches to promote, support and build on the Cancun Safeguards (as in the revised purpose statement) and that it can, as an added benefit, demonstrate how countries meet their commitments under other multi lateral agreements | 109
 |  |  | 110 | When I look at the glossary section, there seems to be bits and pieces of different things that have been picked up from other orgs/facilities (eg. FCPF, UNDP, FAO, UN-REDD, etc). that led rise to the P&C. Did the Capistrano 2010 paper get considered and how she outlines several relevant P&Cs? What were the range of docus referred to? | The glossary was developed using a range of sources; sources have been given when precise language was adopted. Capistrano 2010 will be reviewed for use in the next version. | 110
 |  | Expert reviewer | 111 | [Comment about text describing Risk Identification and Mitigation Tool, para 2] Does this tool provide greater guidance on how to apply the principles and criteria, and how to monitor whether they are being effectively implemented? | This is the intention indeed. | 111
 |  | Expert reviewer | 112 | [Regarding earlier general point about implementation (#31)] In the first paragraph of the section 'Process' the document states that it has been prepared "as a basis for the UN-REDD Programme to work with key stakeholders and individual countries in testing and further refining the P&C"  (my underlining), but nowhere is it clear how this will be done, or by whom. Perhaps it is covered later in this section when referring to the development of the Risk Identification and Mitigation Tool. If so, the reference is oblique and should be made more explicit. | The section on process has been revised to clarify his point | 112
 |  | IAG (Forest Peoples Programme participant) | 113 | Based on the draft it is very difficult to interpret the process that led to the current version of the Social and Environmental Principles and Criteria (SEPC), and the relation of the SEPC to the Cancun Agreements and UNDRIP | The section on process has been revised to clarify this point | 113
 |  |  | 114 | SEPC are limited and do not take into account the full spectrum of aspects that should be taken into account. For example, for indigenous peoples’ rights, what has been the logical process that has led to the identification of P&C for indigenous peoples’ rights? Consider it difficult to understand why some elements from UNDRIP were incorporated and others not, and without knowing the rationale behind the selection, cannot provide comments. | Please see responses to comments 2 and 53 | 114
 |  |  | 115 | The document refers to the development of additional guidelines on social and environmental principles. Is this reinventing the wheel? Difficult to give consistent input if the reviewer doesn’t know what this additional guidance is, or what kind of information it contains. Also difficult to interpret intended use of SEPC without this guidance. | [NAME] has been revised to clarify this linkage. The RIMT will clarify how other pieces of UN-REDD policy and guidance relate to the P&C | 115
 |  |  | 116 | Understand that the FCPF is also reviewing and providing inputs, in this sense how will it be applied in a country where FCPF and UN-REDD are both present? How does it relate to SESA? Would it be a double regime? How can both be mainstreamed into a coherent process? | This is indeed an issue we are considering with our World Bank partners. | 116
 |  | IAG (WRI participant) | 117 | Transparency on which agreements were taken into account. Also it would be helpful for people reviewing this document to know which existing international agreements and principles were referenced and analyzed in the development of this document. | Annex 3 lists sources that were consulted | 117
 |  | Expert reviewer | 118 | This process will support, along with the use of other UN-REDD tools and approaches, the initial operationalization of the [NAME] guidance and safeguards. | The purpose statement has been reworded. | 118
 |  |  | 119 | [Comment on development of indicators for REDD+ at the national level, last para].  Can you be a bit more specific on what these indicators would be for? Performance, impact, compliance? | The text now refers to 'practical indicators for the social and environmental effects of REDD+ at the national level" (i.e. Impacts) | 119
 |  | Global Witness | 120 | We are particularly concerned about the process by which the Risk Identification and Management Tool (RIMT) is being developed and seek further clarity on the relationship between the RIMT and the implementation of the Principles and Criteria. The latest draft of the Principles and Criteria document states that the Risk Identification and Management Tool “may” be used to develop indicators for the “social and environmental effects of REDD+”. Given the lack of detail in the Principles and Criteria, however, it appears that the more substantive decisions about what social, environmental and governance standards will be applied to National Programme activities, and how the Cancun safeguards should be interpreted, are likely to rely heavily upon the RIMT. However, to our knowledge, the Policy Board has not been given an opportunity to formally comment on the RIMT, and we are unclear which stakeholders have been involved in its development. We think the Principles and Criteria, RIMT and related indicators should be elaborated together in a process that is more coordinated, transparent and inclusive than it has been to date. This process should take into account other relevant processes and guidance, as well as inputs from a full range of stakeholders, and clearly indicate how this has being done. | The RIMT will also be open to the public for comments during the consultation process | 120
Context |  | Ecuador | 121 | It is mentioned that the Principles and Criteria do not include monitoring and reporting. How is it planned to ensure that REDD+ Programs are monitored and adapted based on the assessment realized through the Principle and Criteria at national level? | Please refer to response to comment 7 | 121
 |  | Expert reviewer | 122 | Last para of page 2 should also refer to the UN Convention Against Corruption. REDD+ is likely to involve huge financial transfers and we should be explicit about the need for REDD+ countries to develop in advance the means for investigating, identifying and prosecuting possible corruption on such a scale. Criterion 1, 2 and 9 address part of it but recent research on the matter suggest that objective steps like the installment of the Freedom of Information Acts (FOIA) can, in the presence of an active civil society and attentive opposition to the governing structures, significantly decrease levels of corruption in a country more than any institutional or administrative systems: " much of the advice emanating from the works of the global ‘good governance’ on how to curb corruption assumes the access to the kind of administrative praxis and institutions that highly corrupt societies lack. The problem hence lies in the inbuilt inertia  of the corrupt institutional system, which will self-correct to maintain its corruption just as the predominantly non-corrupt system will self-correct to deal with corrupt individuals". "The risk exists that anticorruption measures put in place by the international community  will be taken over by corrupt or semi-corrupt networks. When output from the public sector thus depends on one’s connections, ability to bribe or participation in various clientilistic networks, the establishment of new “western style” institutions will not decrease corruption rates. Rather, such institutions will become impregnated by the dominating particularistic political culture. This confirms that selected formal anticorruption institutions may be so widely viewed as appropriate that the ruling elites will adopt them instantly, not in the pursuit of the ends for which they are designed but rather in search of an international or domestic legitimacy". (Source: http://www.againstcorruption.eu/uploads/norad/BEYOND-GOOD-GOVERNANCE-PERFORMANCE-OF-THE-INTERNATIONAL-ANTICORRUPTION-INSTITUTIONAL-ARSENAL-PUT-TO-THE-TEST.pdf)  In other words, the criteria for tackling corruption in REDD+ should be more concrete and oriented towards this overall paradygm transition in the society (transparency, access to justice, empowerment of civil society), not towards REDD+ activities themselves. I would suggest raising FOIA,  and the explicit involvement of law enforcement and oversight community in REDD discussions: the Dep’t of Justice/Public Ministry/Prosecutor’s office (however defined in each country), particularly any environmental unit or money laundering unit; the military, to the extent that it is involved in deforestation/forest protection activities; government ombudsman entities charged with defending citizens’ rights, or a Comptroller (court of auditors) charged with oversight on government spending/activities; etc. It could also include Customs, police, etc. depending on the dynamic in country. | Agreed. The reference to UNCAC has been clarified in the text box under the introduction and context. And will be used in the RIMT. | 122
 |  | Expert reviewer | 123 | I think citing all these conventions  is too ambitious and disproportionate to the elements of the P&C | The revised introduction highlights how the P&C can help countries demonstrate their commitments under these conventions. The primary purpose of the P&C is to apply to UN-REDD programmes and it is in UN bodies' mandates to uphold the principles and terms of these conventions. | 123
 |  |  | 124 | I strongly suggest, in replacement of the “context” section, a visual demonstration/diagramming  of the different safeguards approaches under different orgs/facilities as they exist and potentially overlap, and then how this P&C PRACTICALLY consolidates them. Then describing briefly what constitutes as practical. This is the only way to quickly justify the choice of principles and criteria as they appear here. | While we have not provided such a visual, we hope that the revised Annex starts addressing these processes and antecedents. | 124
 |  | Expert reviewer | 125 | [Comment on last para describing how principles are organised] It would be good to clarify WHY they do not include suggestions on how to implement the principles and criteria and how to monitor their effectiveness. Is this simply because the UN is waiting for UNFCCC discussions to determine whether or not monitoring and reporting will be required? Or is this simply the first stage of a  process, and the next step will be providing more information on how to implement this on the ground? | UNFCCC policy on monitoring and reporting has yet to be determined; UN-REDD policy will evolve in response to UNFCCC policy, keeping in mind that these P&C primarily refer to activities under the UN-REDD programme. See also see response (to Greenpeace) above on UN-REDD policy; Risk Identification and Mitigation Tool will take process further. | 125
 |  | Norway | 126 | Given the importance of anti-corruption and good governance as a work area for the UN-REDD Programme, we would recommend to also include a reference to the  UN Convention Against Corruption in the “context”-paragraph. | Agreed, as per response to comment 122 | 126
 |  | Expert reviewer | 127 | The Social and Environmental Principles and Criteria are coherent with and draw from the Cancun safeguards, and emerge from the existing rich body of knowledge and literature on safeguards, standards and certification. While they primarily seek to address the major potential opportunities and risks from REDD+, they can also assist countries in promoting and supporting some aspects of the safeguards in the implementation of their REDD+ activities as well as in identifying the information needed to report on how the safeguards are being addressed and respected, as called for in the UNFCCC Cancun decision (FCCC/CP/2010/7/Add.1 ; 69, 71d, 72, Appendix 1, Appendix 2 ]). | Please see revised purpose. | 127
 |  |  | 128 | The relation between this P&C and draft guidance for the provision of information on REDD+ governance should be made explicit. | The document refers to the draft Guidance in the Sources. Its content has informed the revisions made to [NAME] and 2 | 128
 |  | Conservation International (CI) | 129 | We appreciate the reference to the other Multilateral Agreements and the intention of the P&C to help countries meet those commitments.  We also appreciate UN-REDD’s support of a human rights based approach. | Thank you | 129
Principle 1 | Comply with standards of democratic governance | Expert reviewer | 130 | [From track changes document] Principle 1– Meeting national commitments for democratic governance and to relevant Multilateral Agreements Comply with standards of democratic governance | This suggestion has informed the reformulation of Principle 1, which now reads " Apply norms of democratic governance, including those reflected in national commitments and Multilateral Agreements" | 130
 |  | Greenpeace International | 131 | Principle 1 and the subsequent criteria are too vague to be meaningful. The [NAME] agreement calls for "transparent and effective national forest governance structures". Elements of the recent processes, such as World Bank/FAO, Chatham House/FAO and the WRI Forest Governance Initiative should be incorporated in the criteria here. The Criteria read more like principles, whereas measurable criteria should be included for example on functioning institutions, adequate legal frameworks, law enforcement and corruption. | The UN-REDD/Chatham House draft Guidance for the Provision of Information on REDD+ Governance has informed a revision of Principle 1 in this version. We agree that the criteria under principle 1 reflect what is commonly understood as broad principles of good governance. We do not feel that this diminishes their importance. The revised criterion also highlight specifics that are particularly relevant; further specifics will be addressed in RIMT. | 131
 |  | Facilitated consultation - Viet Nam | 132 | Some participants questioned the very strong term (in legal terms) “comply”. | Considering this suggestion and the terms "standards", we have rephrased to use "apply" and "norms", which are defined in the glossary | 132
 |  |  | 133 | [Comment regarding "standards"] This would require further elaboration in the glossary. What exactly are the standards? The text looks very much like UNDP textbook stuff. Perhaps, there is nothing wrong with it. | Please see response to comment 132 above | 133
 |  |  | 134 | [Comment regarding "democratic"] While the Vietnamese participants did not object to “democratic” others where wondering whether something like “good” governance might be sufficient. | Like "good" governance, democratic governance is concerned with the efficiency of institutions and rules, but also with their fairness and the way they are developed. This has been clarified in the glossary, and is a principle that we are committed to. | 134
 |  | Expert reviewer | 135 | Are these three criteria meant to refer to ALL governance systems, or only to those systems set up especially for REDD+? Please clarify. | The principles and criteria only to refer to the governance systems that are necessary to enable REDD+, which ahs been clarified in the text | 135
 |  | Expert reviewer | 136 | It would be good if this principle provided greater clarity on what is meant by ‘standards of democratic governance’.  What standards are these?  How have they been agreed?  Who are they published by?  Is it not important to include the term ‘good governance’ as part of the objective? | Please see response to comment 132 above | 136
 |  | Facilitated consultation - DRC | 137 | Would be good to have footnote to refer to the adopted definition of « democratic governance » and « degradation » | We have made hyperlinks to the glossary to facilitate access to clarification on key terms | 137
 |  |  | 138 | Replace « comply with » by « apply » | Please see response to comment 132 above | 138
 |  | Expert reviewer | 139 | These three criteria are incomplete. All the principles of democratic/good governance are not captured (no mention of equity and effectiveness, among others - see my note on definition below), and neither are all the governance issues included in the safeguards.   Table 1 of the Guidance for the Provision of Information on REDD+ Governance – the result of a consultative process -  provides an overview of these issues. The WB/FAO Framework for the Assessment and Monitoring of Forest Governance would also be a useful reference to ensure that all the components of forest governance are covered in the P&C.  Reformulating Principle 1 to “Ensure transparency, accountability and participation of national REDD+ processes” could be a quick fix to provide more coherence between Principle 1 and the first 3 criteria. | See response to comment 128, above | 139
 |  |  | 140 | The term “democratic governance” is not consistent with the Cancun agreement, and is therefore confusing. A considerable effort has been made to harmonise UN-REDD products with provisions in the Cancun agreement, you may want to do the same with the P&C. | Please see response to comment 134 | 140
 |  | Expert reviewer | 141 | Which “standards of democratic governance” are being referred to? (p.3). In effect, the Glossary of these guidelines merely reaffirm that the S & E – P & C can cross-refer to other (UN) guidelines | Please see response to comment 132 | 141
 |  | 22 Civil Society Organisations | 142 | [See comment no. 76 in "general" comments section] | Please response to comments 2, 4, 7, 52, 53. | 142
 |  | Global Witness | 143 | Principle 1 and related criteria still do not represent a comprehensive interpretation of “effective and transparent national forest governance structures”. It is stated in the Comments and Response matrix provided with the latest draft of the Principles and Criteria that the FAO/Chatham House work will be encompassed in a revised version, but this is not reflected in the version from 30 June 2011. The outputs of other forest governance-related work directly and indirectly referred to in our original submission are not discussed in the response matrix or reflected in the latest version of the Principles and Criteria. As a result, the criteria still represent a narrow interpretation of governance. The Principles and Criteria should build on recent expert processes on governance for REDD+ such as those led by Chatham House/UN-REDD, World Bank/FAO, and the WRI Forest Governance Initiative. | A comparison with the 6 principles in the draft Guidance for the Provision of Information on REDD+ Governance shows that efficiency and effectiveness appear under criterion 5, equity under criterion 7, 8 and 12, accountability under criterion 2, transparency under criterion 3 and participation under criterion 4. The elements developed in the draft [NAME], as well as other tools, will inform the RIMT. We welcome and invite more concrete formulations to address these concerns if unmet. | 143
 |  | CBD LAC Regional Consultation on REDD+ and biodiversity safeguards (Working Group 2) | 144 | [On the issue of exclusion from designing and implementation of policies and measures] Indigenous peoples and local communities must be included from the very beginning in the development (e.g. in REDD, this was not the case in the 2007 Bali discussions). | Agreed. This is the basis for criterion 4, which will be detailed in the RIMT based on our operational guidance on engagement of indigenous peoples and other forest-dependent communities. | 144
 |  | CBD LAC Regional Consultation on REDD+ and biodiversity safeguards (Working Group 3) | 145 | [On issue: lack of communication and adequate transfer of information to local communities can create misunderstandings and inappropriate implementation of REDD] partially [covered by], UNREDD p1 | Accessibility of information is now reflected under criterion 3 | 145
Criterion 1 | Ensure the integrity and transparency of fiduciary and fund management systems | Expert reviewer | 146 | [From track changes document] Ensure proper staffing, training and funding of law enforcement and oversight bodies  in charge of justice and of the Integrity and transparency of fiduciary and fund management systems. | The criteria do not provide this levels of details, but we will consider in the development of the RIMT. | 146
 |  |  | 147 | [From track changes document; Define law enforcement and oversight bodies above in glossary] For the glossary: The Dept. of Justice/Public Ministry/Prosecutor’s office (however defined in each country), particularly any environmental crime unit or money laundering unit; the army to the extent that it is involved in deforestation/forest protection activities; government ombudsman, entities charged with defending citizens’ rights, Controller (court of auditors) charged with oversight on government spending/activities; etc. It could also include Customs, police, etc. depending on the dynamic in country | The criteria do not provide this level of details, but we will consider in the development of the RIMT. | 147
 |  | Facilitated consultation - Nigeria | 148 | [Comment regarding "fiduciary"] This term is problematic and needs clear connection to full explanation in glossary and provision of substitute language | "Fiduciary and fund management systems" are now defined in Glossary | 148
Criterion 2 | Develop and implement activities in a transparent, accountable, legitimate and responsive manner | Expert reviewer | 149 | [From track changes document] Develop Freedom of Information Acts and implement REDD+ activities in a transparent, accountable, legitimate and responsive manner. | The criteria do not provide this levels of details, but we will consider in the development of the RIMT. | 149
 |  | Facilitated consultation - Viet Nam | 150 | [Comment regarding "accountable"] The issue of upward and downward accountability was mentioned. The focus of many governments is the first. What exactly are we trying to say here? | We understand this suggestion to mean that both the demand and the supply side of accountability should be addressed. We believe that the principles cover both and wil seek to further define how to identify risks that they are not considered in the RIMT. | 150
 |  |  | 151 | Other text related to governance also refers to the “efficient use of resources”. | Please see response to comment 134 | 151
 |  | Expert reviewer | 152 | The phrase ‘in a transparent, accountable, legitimate and responsive manner’ seems very broad and open to a lot of interpretation.  These individual terms should be added to the glossary and greater clarity will be needed on how to interpret this in guidance notes. | We have rephrased the criteria under principle 1 and more details will be provide through the RIMT | 152
 |  | Centre for Indigenous Cultures of Peru | 153 | Original P&C text in Spanish: Desarrollar e implementar actividades en [NAME], responsable, legítima y competente. Suggested wording: Desarrollar e implementar actividades de manera transparente, responsable y participativa que permita la rendición de cuentas con las partes interesadas. Suggested wording translation: Develop and implement activities in a transparent, accountable and participatory to enable accountability to stakeholders. | This is encompassed in criterion 4 and will be elaborated  in the RIMT | 153
 |  | Facilitated consultation - Nigeria | 154 | [Comment regarding "legitimate"] This term similarly needs to be well defined – the group took it to relate to legal status, but is this correct? | Legitimacy has been added to the glossary | 154
 |  | Mexican Environmental Law Center (CEMDA) | 155 | Original P&C text in Spanish: Desarrollar e implementar actividades en [NAME], responsable, legítima y competente. Suggested wording: Desarrollar e implementar actividades en forma transparente y proactiva, responsable, legítima y competente Suggested wording translation: Develop and implement activities in a transparent, proactive, responsible, legitimate and competent | We have rephrased the criteria under principle 1 and more details will be provided through the RIMT | 155
Criterion 3 | Ensure the full and effective participation of relevant stakeholders in policy design and implementation, with special attention to the most vulnerable and marginalized groups | Ecuador | 156 | Dissemination of information on REDD+ to stakeholders, provided in a culturally appropriate manner and in a timely way, is one of the key elements of governance. Although it is included in the Risk and Mitigation Tool, it would be important for the Principles and Criteria take it into account. It could be included in Criterion 3: ‘Ensure appropriate information and full and effective participation of relevant stakeholders in policy design and implementation, with special attention to the most vulnerable and marginalized groups’ since information is a pre-requisite to participation and decision-making. | Agreed. We have noted the need for accessibility of information under criterion 3, which will be further elaborated in the RIMT. | 156
 |  | Expert reviewer | 157 | [From track changes document] Ensure the full and effective participation of relevant stakeholders in policy design and implementation, with special attention to the most vulnerable and marginalized groups and to the commercial activities driving deforestation or the degradation of forests. | For further internal discussion & consideration | 157
 |  | Greenpeace International | 158 | [In reference to general comment about vagueness (#6)] Example 2: Rather than simply repeating the [NAME] text as in criterion 3, a more meaningful criterion that would help operationalizing the UNFCCC safeguards could read for example:   “provide local and indigenous peoples (women and men) timely and culturally appropriate access to relevant information and ensure their informed participation in decision making, implementation and monitoring with regards to land use planning, forest management, and in projects and programs affecting them.” | For further internal discussion & consideration | 158
 |  | Expert reviewer | 159 | At CIFOR we found the wording of some of the “FPIC” documents to in fact require things that truly disempowered local people (e.g., when you ask illiterates people to sign forms; or explain complex and new processes that they may not understand right away, in a quick manner).  I would feel more comfortable if the document focused on clarifying what is meant by participation, in such a way that FPIC is inherent in the process----as stated, there’s a danger that it could be a form that actually means nothing in reality… | We agree with these concerns and they are reflected in the UN-REDD draft FPIC guidelines, which has an emphasis on using culturally appropriate methods, e.g. in working with illiterate communities | 159
 |  | Expert reviewer | 160 | UNFCCC Cancun agreement specifies that REDD+ activities be undertaken with the full and effective participation ‘in particular, indigenous peoples and local communities’.   It seems appropriate to include this emphasis and also to include, ‘with special attention to the most vulnerable and marginalized groups’. | Agreed, and we have revised criterion 4 | 160
 |  |  | 161 | Why restrict full and effective participation to policy design and implementation and not use a broader term that applies to all policies and measures of the REDD+ programme? | We have revised the criterion, and refer to our Guidelines on Stakeholder Engagement which clarify this point | 161
 |  | Facilitated consultation - Viet Nam | 162 | [Comment regarding "relevant stakeholders"] Two issues where brought up here that may need attention, also in some other criteria. The term “relevant” is used very loosely and subsidiarity should be brought in. | "Relevant stakeholders" now defined in Glossary | 162
 |  | Centre for Indigenous Cultures of Peru | 163 | Original P&C text in Spanish: Garantizar la participación total y efectiva de los actores relevantes en el diseño y la implementación de políticas, con especial atención a los grupos más vulnerables y marginalizados. Suggested wording: Asegurar la participación plena y [NAME], en especial de los más vulnerables y marginalizados como la mujer indígena en el diseño e [NAME]. Suggested wording translation : Ensure the full and effective participation of stakeholders, especially the most vulnerable and marginalized as indigenous women in the design and implementation of policies. Comment: La opinión de la mujer no es visibilizada por ella misma sino que en muchos casos [NAME] aún [NAME] poder de opinión. Translation of comment: The opinion of the woman is not made visible by itself but in many cases the male still concentrates the power of opinion. | Women included in definition of most vulnerable and marginalized groups in Glossary | 163
 |  | Facilitated consultation - Nigeria | 164 | [Comment regarding "vulnerable and marginalised groups"] Expand glossary entry to explicitly include women, youth and the disabled | Agreed and revised as suggested | 164
 |  | Mexican Environmental Law Center (CEMDA) | 165 | Original P&C text in Spanish: Garantizar la participación total y efectiva de los actores relevantes en el diseño y la implementación de políticas, con especial atención a los grupos más vulnerables y marginalizados. Suggested wording: Garantizar la participación oportuna, total y efectiva de los actores relevantes en el diseño y la implementación de políticas, con especial atención a los grupos más vulnerables y marginalizados. Suggested wording translation: To ensure timely participation, total and effective stakeholders in the design andimplementation of policies, with special attention to the most vulnerable and marginalized groups. | We understand that this is implied under "total" and refer to our SE guidelines | 165
 |  | Conservation International (CI) | 166 | Amend Criterion 3 to read:  “…with special attention to indigenous peoples and local communities, the most vulnerable, and marginalized groups.” | We have revised criterion 4 | 166
Additional suggested criteria under Principle 1 |  | Expert reviewer | 167 | [From track changes document] Criterion 4 – Promote and enhance gender equality and women’s empowerment. [This criterion was formerly criterion 4 under Principle 2; suggests moving it from Principle 2 to Principle 1] | Although this categorization is intellectually sensible, moving gender equality from under a "rights" principle to under a "governance" principle would somewhat weaken it, since it would de-emphasize the existing relationships to human rights instruments addressing the issue.  We have therefore left it under principle 2. | 167
 |  |  | 168 | [From track changes document] Criterion 5 – Seek free, prior and informed consent of indigenous peoples and other forest dependent communities. [This criterion was formerly criterion 5 under Principle 2; suggests moving it from Principle 2 to Principle 1] | See response to comment 167 above | 168
 |  | Expert reviewer | 169 | There is no requirement for a grievance mechanism.  This could be included as a criterion under Principle 1.  In REDD+ SES it is a criterion under Principle 6 on full and effective participation. | We have rephrased the structure and application section to emphasize the UN-REDD Programme's commitment to providing access to grievance mechanisms; in addition criterion 2 specifies the need for complaints and grievance mechanism | 169
 |  |  | 170 | There is no requirement for access to information, which could also be included as a criterion under Principle 1. | Accessibility of information is specified in criterion 3; in addition this is implied under the "informed" of FPIC in criterion 9 | 170
 |  | Facilitated consultation - Nigeria | 171 | It would be good for this [Principle] to include a criterion relating to Human Rights | We have rephrased principle 2 to specify human rights | 171
 |  | Mexican Environmental Law Center (CEMDA) | 172 | Proposed criterion: [NAME] las capacidades de las comunidades dependientes de los bosques. English translation of proposed criterion:  Strengthening the capacity of forest dependent communities. | We feel that this is too vague | 172
Principle 2 | Respect and protect stakeholder rights | Ecuador | 173 | It may be interesting to distinguish between ‘rights holders’ who are those whose rights are being potentially affected by the REDD+ program and ‘stakeholders’ who are ‘those whose interests/stakes are potentially affected by the program’. How are the relevant stakeholders being identified? | We have clarified in the glossary that "relevant stakeholders" includes rights holders as well as those who will be affected by REDD+ activities | 173
 |  |  | 174 | Principle 2 ensures the respect and protection of stakeholder rights but does not consider rights to lands, territories and resources, both statutory and customary. Clarification, recognition and respect of land rights being a pre-requisite to REDD+ implementation and goes with the respect of the free, prior and informed consent for any activities affecting lands, territories and resources as well as avoiding involuntary resettlement. Thus it should be considered in a new criterion. | We have added a criterion (criterion 7) on land tenure and carbon rights | 174
 |  | Greenpeace International | 175 | Principle 2: This Principle appears even more vague than the Cancun agreement text. The UNFCCC text mentions respecting traditional knowledge and rights of IPs and LCs and makes explicit reference to UNDRIP. UNDRIP is not only about FPIC, but also includes for example customary and tenure rights.  Furthermore, the text to “seek free prior informed consent” is too weak, and should state “ensure”. | Re: FPIC - agreed; Re: tenure - see addition of criterion 7. Re: Traditional knowledge - see criterion 11. | 175
 |  | Expert reviewer | 176 | There is no requirement to respect customary rights as well as statutory rights.  This is very important, especially for indigenous peoples, local communities and generally for marginalized groups. | This has now been made explicit in principle 2 | 176
 |  | Facilitated consultation - DRC | 177 | Principle 2 is articulated as « all stakeholders », but all the corresponding criteria actually relate to indigenous peoples and forest dependent communities. Suggestion to add « all stakeholders affected by forests » or « indigenous peoples and forest-dependent communities. | See glossary definition | 177
 |  |  | 178 | Suggestion to have « human rights » instead of « rights of stakeholders » | See revised principle 2 | 178
 |  |  | 179 | Principle 2 should be more specific about who the stakeholders are  (ex : the public sector). | revised Principle 2 has been expanded to identify which types of rights are intended | 179
 |  |  | 180 | Equality should not solely be between genders, but between all citizens, and the principle should reflect this | This is too broad and we have left as is. | 180
 |  | Centre for Indigenous Cultures of Peru | 181 | Original P&C text in Spanish: RESPETAR Y PROTEGER LOS DERECHOS DE LOS ACTORES RELEVANTES Suggested wording: PROMOVER, RESPETAR Y PROTEGER LOS DERECHOS DE LAS PARTES INTERESADAS MÁS VULNERABLES. Suggested wording translation: PROMOTE, RESPECT AND PROTECT THE RIGHTS OF INTERESTED PARTIES MORE VULNERABLE. Comment: La frase “actores relevantes” podría ser interpretada en desmedro de los pueblos indígenas. Translation of comment: The phrase "relevant actors" could be interpreted to the detriment of indigenous peoples. | This is a translation inconsistency that has been now corrected, thank you for spotting it. | 181
 |  | Mexican Environmental Law Center (CEMDA) | 182 | Comment in Spanish: Los titulares de derechos y actores pertinente tienen la capacidad [NAME], implementar y monitorear los requisitos legales relacionados con REDD+. Translation of comment: Rights holders and stakeholders have the ability to understand, implement and monitor legal requirements related to REDD +. | This will be covered by the RIMT | 182
 |  | IAG (Forest Peoples Programme participant) | 183 | Why are there no references to land tenure and land rights (a key issue in UNDRIP)? | See addition of criterion 7 | 183
 |  | International Development Law Organisation (IDLO) | 184 | Principle 2 – The Cancun Agreements not only ask governments to assess and mitigate potential adverse effects but to actively enhance social benefits. Moreover, they protect human rights, rights of indigenous peoples and encourage the use of traditional knowledge in designing forest management. This requires positive commitments from government, whereas Principle 2 is currently framed negatively. The Cancun Agreements also seek to ensure a just transition of the workforce that creates decent work and quality jobs. | We do not believe that principle 2 and associated criteria are solely framed as mitigating adverse effects | 184
 |  | 22 Civil Society Organisations | 185 | [See comment no. 76 in "general" comments section] | Please see response to comments 2, 4, 7, 52, 53. | 185
 |  | Global Witness | 186 | As with most of the Principles, the individual criteria in Principle 2 are important but do not cover all relevant considerations. The criteria omit important considerations for respecting and protecting the rights of indigenous peoples and forest communities, in particular how issues of land tenure, including customary rights, and associated carbon rights will be addressed. They fail to provide for a redress mechanism, such as a complaints body or conflict resolution mechanism, that can respect and protect stakeholder rights through recognition of traditional laws and customs. Similarly, the criteria should include express reference to the need to provide local people with timely and culturally appropriate access to relevant information. | See addition of criterion 7 and response to comment 7 | 186
 |  | CBD LAC Regional Consultation on REDD+ and biodiversity safeguards (Working Group 2) | 187 | [On the issue of lack of tangible livelihood benefits to indigenous peoples and local communities and lack of equitable benefit-sharing] Risk of lack of benefit sharing is a concern for the success of REDD-plus, and this point should be a priority at national level. | Please see revised criterion 12 | 187
Criterion 4 | Promote and enhance gender equality and women's empowerment | Expert reviewer | 188 | [From track changes document] Promote and enhance gender equality and women's empowerment [track changes; suggests moving this criterion to Principle 1] | Please see response to comment 167 | 188
 |  | Solomon Islands | 189 | Promote and enhance gender equality and women and youth empowerment. Note: There needs to be systems/guidelines/mechanisms/processes/frameworks  in place  to meet/achieve the above principles and criteria | We feel that addition of youth in this context is too broad | 189
 |  | Facilitated consultation - DRC | 190 | Criterion 4 : Gender issues are a governance issue and should be under principle 1. | Please see response to comment 167 | 190
 |  |  | 191 | What are verifiable, qualitative indicators to measure gender equality ?   [comment: This will have to be addressed in the Risk identification and mitigation tool] | This will be addressed in the RIMT | 191
 |  |  | 192 | It should be noted that in the translation presented, “gender equality” is translated as “sex equality” and “Women’s empowerment” as “autominiaztion of women”. | The French translation now refers to gender equality | 192
 |  | Centre for Indigenous Cultures of Peru | 193 | Original P&C text in Spanish: Promover y mejorar la igualdad de género y el empoderamiento de las mujeres. Suggested wording: Promover y fortalecer el rol [NAME] mujer indígena, su empoderamiento, [NAME] y [NAME] mujer en el manejo del bosque. Suggested wording translation: Promote and strengthen the political role of indigenous women's empowerment, gender equity and revaluation of the activities of women in forest management. Comment: Se ha resaltado la figura de la mujer indígena en su rol político y [NAME] clave [NAME] que las políticas y programas REDD+ no afecten las actividades tradicionales de la mujer en el manejo sostenible de los bosques. Translation of comment: It has highlighted the figure of indigenous women in their political role as key actors to ensure that policies and programs affecting REDD + not the traditional activities of women in sustainable forest management. | This is too specific for this criterion and will instead be addressed in the RIMT. | 193
 |  | Facilitated consultation - Nigeria | 194 | [Comment regarding "equality"] Important to replace this word with ‘Equity’ | We have added equity and clarified the terms in the glossary | 194
 |  | Mexican Environmental Law Center (CEMDA) | 195 | Original P&C text in Spanish: Promover y mejorar la igualdad de género y el empoderamiento de las mujeres. Suggested wording: Promover y mejorar la equidad de género y el empoderamiento de las mujeres para la libre elección Suggested wording translation: Promote and enhance gender equality and empower women to free choice | We have fixed that translation inconsistency | 195
Criterion 5 | Seek free, prior and informed consent of indigenous peoples and other forest dependent communities | Latin America - Caribbean Regional Consultation and Capacity-Building Workshop on Reducing Emissions from Deforestation and Forest Degradation in Developing Countries (REDD-Plus), Including on Relevant Biodiversity Safeguards - participant's report | 196 | The wording 'to seek' in the criterion on FPIC was questioned as it wasn't clear whether FPIC is a requirement or whether it is sufficient to seek it, even if unsuccessful | We have revised  criterion 9 to "Seek free, prior and informed consent of indigenous peoples and other forest dependent communities and respect and uphold the decision taken (whether consent is given or withheld)." | 196
 |  | Expert reviewer | 197 | [From track changes document] Seek free, prior and informed consent of indigenous peoples and other forest dependent communities [suggests moving this criterion to Principle 1] | See response to comment 167 above | 197
 |  | Facilitated consultation - Viet Nam | 198 | [Comment regarding "consent"] What exactly would be the consent for, was a question that was asked. For the UN-REDD Programme (which phase) or REDD+. | FPIC Guidelines are now referenced in Glossary | 198
 |  | Expert reviewer | 199 | Perhaps consider also adding 'other local communities who will be directly impacted by REDD+ activities'- as there are many local communities that are not strictly forest-dependent but who live near the forest and will be impacted by REDD+ activities, and who should be included in any consultation process | This the language that has been accepted through the consultation process on the FPIC guidance. No action taken | 199
 |  | Expert reviewer | 200 | Why only ‘seek’ FPIC?  The French version of the same P&C uses ‘obtenir’ or ‘obtain’ which seems more appropriate and explicit. | Please see response to comment 196 | 200
 |  |  | 201 | What is FPIC applied to?  Is it applied where rights are affected or where people (ie economic or livelihood interests) are affected?  Is it applied where these issues are affected just by the REDD+ strategy or more broadly?  Is it applied to rights to territories, lands and resources and knowledge where these are potentially affected by the REDD+ strategy, or more broadly?  It is applied to customary as well as statutory rights? | Please see response to comment 198 | 201
 |  |  | 202 | In general, we heard from indigenous peoples and local communities during consultations on REDD+ SES that they want to ensure that their rights to lands territories and resources are recognized and respected (Principle 1 of REDD+ SES) and that any activity affecting those rights should be subject to their FPIC.  None of the criteria explicitly ensures that rights to lands, territories and resources are recognized and respected. | Please see addition of criterion 7 | 202
 |  |  | 203 | Note that not all indigenous peoples are forest dependent.  Do these P&C (or FPIC in particular) only apply to forest dependent indigenous peoples and local communities or those who may be affected whether or not they are forest dependent, such as REDD+ policies and measures like changes to agricultural subsidies or land tenure reform. | This applies to all affected indigenous peoples | 203
 |  | Facilitated consultation - DRC | 204 | Suggestion to replace « local communities » with «  forest-dependent local communities and vulnerable communities » | The text as it is  what has been agreed and used in the draft FPIC guidance | 204
 |  | Centre for Indigenous Cultures of Peru | 205 | Original P&C text in Spanish: Obtener el consentimiento libre, previo e informado de los pueblos [NAME] dependen de los bosques. Suggested wording: [NAME] libre, previo e informado de los pueblos indígenas y otras comunidades dependientes de los bosques de manera transparente e independiente. Suggested wording translation: Guarantee the right to free, prior and informed consent of indigenous peoples and other forest-dependent communities in a transparent and independent. | Please see response to comment 196 | 205
 |  | Facilitated consultation - Nigeria | 206 | [Comment regarding "indigenous peoples"] It is important to note that “indigenous people” is not a relevant term in Nigeria (and other places), and it would be helpful if a glossary entry reflected this | See definition of indigenous peoples in Glossary | 206
 |  | Mexican Environmental Law Center (CEMDA) | 207 | Comment in Spanish: REDD debe validar a través de actas de asamblea ejidal/comunal aprobadas Translation of comment: REDD must be validated through meeting minutes ejido / communal approved | We feel this is covered in criterion 3 | 207
Criterion 6 | Avoid involuntary resettlement as a result of REDD+ | Expert reviewer | 208 | [From track changes document] Avoid Prevent involuntary resettlement as a result of REDD+ activities by ensuring proper staffing, training and funding of government agencies in charge of clarifying and enforcing land tenure and use rights so that unequivocal cadastral systems can progressively be built up and land ownership is respected. | We have reworded criterion 10 that now reads "ensure that there is no involuntary resettlement", and have added a criterion on land tenure under criterion 7 | 208
 |  | Expert reviewer | 209 | The term ‘avoid’ is too weak for involuntary resettlement.  Surely the P&C should ‘ensure no’ involuntary resettlement.  If there are cases where UN-REDD would sanction involuntary resettlement (as defined in the glossary) then it will be very important to define the conditions under which this would be acceptable, requirements for fair compensation etc. | Agree. We have revised to "ensure no involuntary resettlement" | 209
 |  |  | 210 | Does resettlement include both physical and economic relocation or displacement, and is economic relocation only applied in cases of creation of legally protected areas as in World Bank OP 4.12?  This needs to be explicit in the glossary definition. | Glossary entry now covers physical and economic displacement explicitly | 210
 |  | Centre for Indigenous Cultures of Peru | 211 | Original P&C text in Spanish: Evitar el reasentamiento involuntario como resultado de REDD+. Suggested wording: Proteger la tierra, recursos, prácticas culturales de los pueblos indígenas entre otros a fin de evitar conflictos como resultado de REDD+; además proteger a los pueblos indígenas y [NAME] indígenas en aislamiento del reasentamiento voluntario e involuntario como resultado de REDD+. Suggested wording translation: Protecting the land, resources, cultural practices of indigenous peoples and others to avoid conflicts resulting from REDD +; also protect indigenous peoples and indigenous peoples in isolation from the voluntary and involuntary resettlement as a result of REDD +. | Phrasing has been improved in the new version | 211
 |  | Facilitated consultation - Nigeria | 212 | It would be good for the Risk Identification & Mitigation Tool to include an entry on community land use planning in relation to this criterion | We will consider this in the RIMT | 212
 |  | Conservation International (CI) | 213 | Criterion 6, add “respect traditional and customary rights, including to land and territories, of indigenous peoples and other forest dependent communities.” | Please see additional criterion 7 | 213
Criterion 7 | Respect and protect cultural heritage and traditional knowledge | WWF; WWF Viet Nam | 214 | Criterion 7: Respect and protect cultural heritage, traditional knowledge (add) and way of life (eg nomadic groups) | We have added "Practices" to the wording in criterion 11 to reflect this suggestion | 214
 |  | Facilitated consultation - Viet Nam | 215 | [Comment regarding "protect"] It was noted that some traditional knowledge is actually a driver of deforestation or forest degradation. How would be deal, for example, with the use of fire fore hunting in some societies. | Noted, and will inform the RIMT | 215
 |  |  | 216 | Respect and protect cultural heritage and traditional and indigenous knowledge | Definition in glossary now focused on indigenous knowledge | 216
 |  | Facilitated consultation - DRC | 217 | Replace « respect and protect » with « promote » | We feel that the current wording is appropriate and have not changed the wording, and welcome more discussions as needed. | 217
 |  | Centre for Indigenous Cultures of Peru | 218 | Original P&C text in Spanish: Respetar y proteger el patrimonio cultural y el saber tradicional. Suggested wording: Reconocer, promover y proteger el patrimonio cultural en especial las leyes consuetudinarias y el manejo sostenible de los bosques en concordancia con lo consignado por la Declaración de las Naciones Unidas sobre [NAME], el Convenio sobre la Diversidad Biológica y la UNESCO. Suggested wording translation: Recognize, promote and protect cultural heritage in particular customary law and sustainable management of forests in line with what was noted by the United Nations Declaration on the Rights of Indigenous Peoples, the Convention on Biological Diversity and UNESCO. | We will seek to include references to these instruments in the RIMT | 218
 |  | Facilitated consultation - Nigeria Consultation | 219 | the wording of this criterion considered to be very vague and therefore the group emphasised the importance of using the Risk Identification & Mitigation Tool to make specific examples available | Noted with thanks | 219
 |  | Mexican Environmental Law Center (CEMDA) | 220 | Comment in Spanish: REDD debe dar lugar a que el conocimiento indigena y campesino se aplique directamente a la estrategia Translation of comment: REDD must lead to indigenous and peasant knowledge is applied directly to the strategy | This will be addressed in the RIMT | 220
 |  | Conservation International (CI) | 221 | Criterion 7, add “ incorporate [. Comment:] respect and protect doesn't mean incorporate or promote the use of traditional knowledge. This is more passive rather than an active use of traditional knowledge in the forest activities in redd+ context. | For further discussion and consideration - Criterion currently amended to "Criterion 11 – Respect and protect traditional knowledge and cultural heritage and practices". | 221
Additional suggested criteria under Principle 2 |  | Expert reviewer | 222 | Criterion—access to information Criterion—build Capacity of stakeholders as appropriate | Access to information is part of criterion 3. Capacity building underpins a number of criteria and is a fundamental component of the activities of the UN-REDD Programme | 222
 |  | Expert reviewer | 223 | Consider adding a criterion on capacity building- i.e., ensuring that all key stakeholders have the appropriate information on what REDD+ will entail (and how it may impact them), and have sufficient capacity to make informed decisions regarding their potential participation in REDD+ | Please refer to responses to comments 210 and 222 | 223
 |  | Centre for Indigenous Cultures of Peru | 224 | Proposed criterion: Asegurar la inclusión de los pueblos y mujeres [NAME] los procesos de toma de decisiones que pueden afectarlos directa e indirectamente. Translation of proposed criterion: Ensure the inclusion of peoples and indigenous women in decision-makingprocesses that may affect directly and indirectly.  Comment: Sugerimos la inclusión de este criterio [NAME] que los pueblos [NAME] estando [NAME] accedan a los espacios de toma de decisiones, especialmente en las áreas que les afecten. [NAME] y mujeres [NAME] un rol activo en la promoción y respeto de sus derechos individuales y colectivos en las políticas y programas REDD+. Translation of comment: We suggest the inclusion of this criterion to ensure that indigenous peoples haveto be mechanisms for access to well-informed decision-making spaces, especially in areas that affect them. In this way the indigenous peoples and women have an active role in promoting and respecting their individual and collective rights in REDD policies and programs. [Note: this additional criterion was placed first - before criterion 4] | These elements are covered by revised criteria and we did not feel that a stand alone criterion was necessary. | 224
 |  | Facilitated consultation - Nigeria | 225 | It might be helpful to add a criterion on building knowledge and awareness of rights, and capacity to exercise them. | This is an element that we feel is covered implicity under the existing criterion, and that touches more on the how to concretely ensure adherence to the P&C. We will seek to take this into account in the RIMT | 225
 |  | Mexican Environmental Law Center (CEMDA) | 226 | Proposed criterion: Garantizar el derecho de las comunidades a aprovechar sus recursos forestales y garantizar la soberania e [NAME] English translation of proposed criterion:  Guarantee the right of communities to exploit their forest resources and ensure food sovereignty and identity of communities | See response to comment 51 | 226
 |  | Expert reviewer | 227 | The first one [comment] concerns land tenure rights. We know that landholders linked to agribusiness usually tend to have formal tenure rights over their lands. Cattle ranchers don’t always have formal ownership rights but nonetheless tenure tends to be secure. In contrast, tenure rights of smallholders and indigenous peoples are often informal and less secure.   Thus, in my opinion under Principle 2 (Respect and protect stakeholder rights) it could be worthwhile to consider the inclusion of another Criterion that specifically addresses land tenure rights, for example something like ‘Acknowledge and respect land tenure claims by indigenous peoples and other local communities’ OR ‘Respect and promote the recognition and exercise of land tenure rights by indigenous peoples and other local communities’. | Please see additional criterion 7 | 227
Principle 3 | Promote and enhance sustainable livelihoods | Ecuador | 228 | Define ‘livelihoods’ in the glossary. The definition should take into accounts social, cultural, human, financial, physical, natural and political capitals. | Sustainable livelihoods now defined in Glossary | 228
 |  | Expert reviewer | 229 | According to the  widely quoted definition of sustainability (Brundtland Commission of the United Nations on March 20, 1987) “sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs." At the 2005 World Summit it was noted that this requires the reconciliation of environmental, social and economic demands - the "three pillars" of sustainability. I would therefore suggest to merge [NAME] and 4 into "ensuring the long term resilience of emission reductions in tropical forests by promoting sustainable development, social justice and biodiversity" | Merging Principles 3 and 4 takes away the emphasis of Principle 4 on protecting natural forests from degradation and conversion. I believe that we want to maintain this focus.  We have reworded principle 4 to  include 'sustainable development' | 229
 |  |  | 230 | In my view criteria 16 (Ensure that land use planning for REDD+ explicitly takes account of ecosystem services) would better fit under principle 3  (Promote and enhance sustainable livelihoods). The 2 reasons why we MUST conserve forest biodiversity under REDD+ are  1) Biodiverse ecosystems provide a wealth of services to local populations (food , water and energy security, remedies and shelter, fodder), which increase their (non commercial) standing value and 2) Biodiverse ecosystems are more resilient and can therefore better prevent climate induced dieback (hence reversals). [NAME] is therefore redundant as it should already be picked up in criteria 16 and in the overall architecture of REDD+ (MRV and accounting). | We will retain criterion 16 in its current position to account for values other than livelihoods; Criterion 11 explicitly addresses the risk of reversals point of the Cancun safeguards.  Biodiversity is not the only determinant of resilience, so risk of reversals needs a separate mention. | 230
 |  |  | 231 | [From track changes document] Ensuring the long term durability of emission reductions in tropical forests by promoting overall sustainable development, including social justice and healthy, resilient ecosystems Promote and enhance sustainable livelihoods [track changes] | For further internal discussion & consideration | 231
 |  | Facilitated consultation - Viet Nam | 232 | Some participants felt that the issue of sustainable income generation was missing here, although income does not necessarily mean financial income. | Sustainable livelihoods now defined in Glossary | 232
 |  | Expert reviewer | 233 | Sustainable livelihoods’ needs definition in the glossary.  REDD+ SES defines livelihoods as being based on social, cultural, human, financial, natural, physical and political capabilities/assets. | Noted and for further discussion | 233
 |  | Facilitated consultation - DRC | 234 | Principle 3 : to the benefit of which category of communities ? Should there be an indigenous peoples-specific criteria under this principle? | The assumption is that this is for all affected stakeholders including Indigenous Peoples, and that therefore no specific criteria is needed here. | 234
 |  |  | 235 | There are not enough criteria under this principle. For example, there should be mention of the freedom to undertake local entrepreneurial initiatives, and labor rights should be explicitly mentioned | We did not feel that this was in the scope of the P&C | 235
 |  | Facilitated consultation - Nigeria | 236 | Suggest rewording to read “Promote and enhance forests’ contribution to sustainable livelihoods”. Possibly add a new criterion: ‘Minimise adverse impacts on livelihoods’. | Principle 3 reads "Promote and enhance forests’ contribution to sustainable livelihoods”. Criterion 3 specifies minimizing adverse impacts | 236
 |  | Expert reviewer | 237 | Looking at the developments in Asia, I am not sure what is really means and whether it will be understood by many people. Millions are people are on the move here as their current livelihoods are not “sustainable”. Additional income through REDD+ may facilitate a move towards alternative livelihoods (e.g. out of the primary into the tertiary sector). I am always coming back to the question of whether we should support forest-dependency or help people to reduce such dependency. Is this covered by the principle? Should I raise such concerns at all. Perhaps what we really want is enlarging the number of options people can choose from. | This is a very good question, although we are not sure this can be addressed under the P&C and we welcome further inputs for discussion. | 237
 |  | International Development Law Organisation (IDLO) | 238 | Principle 3 – The criteria under Principle 3 do not include addressing the drivers of deforestation and forest degradation. These elements could be considered in this section. The drivers of deforestation and forest degradation are related to social principles insofar as they often provide ecosystem services to communities, such as food and energy. Therefore, addressing the drivers not only entails sanctions on certain activities but a cross-sectoral approach to policy coherence that requires that human needs still be met, albeit in ways that relieve the human pressure on forests (see III.C 68, 72). Additionally, Principle 3 could address actions to reduce the displacement of emissions, including through subnational and national monitoring systems as appropriate  (see III.C.71(a) and footnote 7, [NAME] I 2(g)). | For further discussion | 238
 |  | Global Witness | 239 | The criteria under Principle 3 appear to be aimed more at promoting livelihoods co-benefits than at avoiding negative impacts on forest-dependent livelihoods. However, the criteria under Principle 2 on respecting and protecting stakeholder rights are not sufficiently robust and comprehensive to address the potential threats posed by REDD+ to the livelihoods of forest-dependent communities. | Please refer to response to comment 225 | 239
Criterion 8 | Ensure equitable and transparent benefit distribution among relevant stakeholders | WWF; WWF Viet Nam | 240 | Criterion 8: Ensure equitable and transparent benefit distribution among relevant stakeholders (add) with special attention to the most vulnerable and marginalized groups. | Agreed - see revised criterion 12 | 240
 |  | Expert reviewer | 241 | Ensure equitable and transparent benefit sharing and distribution among relevant stakeholders | Agreed - see revised criterion 12 | 241
 |  | Expert reviewer | 242 | Define what you mean by 'relevant' | "Relevant stakeholders" is now defined in Glossary | 242
 |  | Expert reviewer | 243 | Benefits should be defined to include costs, benefits and risks.  REDD+ SES explains that ‘All analysis of costs, benefits and risks should include those that are direct and indirect and include social, cultural, human rights, environmental and economic aspects.  Costs should include those related to responsibilities and also opportunity costs.  All costs, benefits and risks should be compared against the reference scenario which is the most likely land-use scenario in the absence of the REDD+ program.’ | This is very relevant for the development of the RIMT | 243
 |  | Centre for Indigenous Cultures of Peru | 244 | Original P&C text in Spanish: Garantizar una distribución de beneficios equitativa y transparente entre los actores relevantes. Suggested wording: Garantizar que la distribución de beneficios sea equitativa, transparente, entendible y comunicable entre las partes involucradas asegurando que la mayor parte de los beneficios retorne a los pueblos [NAME]. Suggested wording translation:  Ensure that the distribution of benefits is equitable, transparent, understandable and communicable between the parties involved to ensure that most of the profits return to the indigenous peoples of the forest guards. | Revised criterion 12 includes " non -discriminatory" | 244
 |  | Facilitated consultation - Nigeria | 245 | [Comment regarding "equitable and transparent benefit distribution"] The group recognised that this covers a complex process, and therefore the Risk Identification & Mitigation Tool should address: analysis & research; formulas and ratios; planning; development of a mechanism; implementation of a mechanism; and oversight. | Thank you, we will take this into account in the RIMT | 245
 |  | Expert reviewer | 246 | Not sure how this promotes and enhances sustainable livelihoods. | Noted. We welcome more details on this comment. | 246
 |  | International Development Law Organisation (IDLO) | 247 | Lastly, Principle 2, Criterion 8 should also refer to the principle of non-discrimination: “Ensure equitable, non-discriminatory, and transparent benefit…”. (see [NAME], I.8 and [NAME] I 2(e) and footnote 1, 2(2(a)). | Please see response to comment 244 | 247
 |  | Conservation International (CI) | 248 | Criterion 8 and 9, add “with special attention to indigenous peoples and local communities, the most vulnerable, and marginalized groups.” | Criteria now refer to most vulnerable & marginalized groups. Relevant stakeholders defined in detail to include indigenous peoples & other forest-dependent communities. | 248
 |  | CBD LAC Regional Consultation on REDD+ and biodiversity safeguards (Working Group 2) | 249 | With reference to the lack of clarity of equitable benefit-sharing, some participants expressed concerns that women are not sufficiently included in the REDD-plus mechanism and this is creating confusion within the indigenous peoples and local communities. | Criteria are not to be taken into isolation, and criterion 8, which now includes gender equity, addresses this. | 249
Criterion 9 | Respect and enhance economic, social and political well-being | Greenpeace International | 250 | [In reference to general comment about vagueness (#6)] Example 1: Instead of vaguely referring to “respect and enhance economic, social and political well-being” [criterion 9], clearer criteria should be used, such as for example: “reduce poverty and improve the quality of life of forest dependent communities and indigenous peoples”. | We have provided a definition in the glossary for economic, social and political well-being. To discuss further. | 250
 |  | WWF | 251 | Criteria 9 and 10: These criteria could be re-­‐worked to be more precise and measurable. | Details will be elaborated in RIMT | 251
 |  | Expert reviewer | 252 | This is too generic to be useful. Perhaps “demonstrate impact on poverty reduction and alleviation” | Please see above comment 250 | 252
 |  | Facilitated consultation - Viet Nam | 253 | Some participants questioned the term “political well-being” and were wondering by “human well-being” did not appear. | "Economic, social and political well-being" now defined in Glossary | 253
 |  | Expert reviewer | 254 | This is very vague. Well-being of whom? The entire country? the key stakeholders? How will this be measured? | "Relevant stakeholders" now defined in Glossary | 254
 |  | Expert reviewer | 255 | ‘Respect and enhance economic, social and political wellbeing’ is very broad and could be interpreted in many different ways. Greater clarity will be needed on how to interpret this in guidance notes.  We question whether political well-being should be included as we are not aware of this being a recognized concept as far as I know. | See comment 250, and 253 on political wellbeing | 255
 |  | Centre for Indigenous Cultures of Peru | 256 | Original P&C text in Spanish: Respetar y mejorar el bienestar económico, social y político. Suggested wording:  Garantizar y respetar [NAME], social, cultural y político. Suggested wording translation:  Respect and ensure the economic, social, cultural and political wellbeing. Comment:  El manejo de fondos podría traer conflictos al interior de las comunidades y entre comunidades. Por ello, [NAME] económico no puede ser visto sin el aspecto cultural. Translation of comment: The management of funds could lead to conflict within communities and between communities. Therefore, economic welfare can not be seen without the cultural aspect. | The rephrased criterion 13 now reads "protect and enhance, while minimizing adverse impacts.." | 256
 |  | Facilitated consultation - Nigeria | 257 | It was felt that this criterion is very complex: consider splitting it. | The RIMT will help clarify this criterion | 257
 |  | Conservation International (CI) | 258 | Criterion 8 and 9, add “with special attention to indigenous peoples and local communities, the most vulnerable, and marginalized groups.” | Criteria now refer to most vulnerable & marginalized groups. Relevant stakeholders defined in detail to include indigenous peoples & other forest-dependent communities. | 258
Additional suggested criteria under Principle 3 |  | Centre for Indigenous Cultures of Peru | 259 | Proposed criterion: Asegurar la transparencia, rendición de cuentas y eficiencia en costos de los mecanismos de financiación de los programas REDD+. Translation of proposed criterion: Ensuring transparency, accountability and cost efficiency of funding mechanisms of REDD +. [Note: this additional criterion was placed first – before criterion 8) | This is covered in criterion 2 | 259
 |  | Facilitated consultation - Nigeria | 260 | Possibly add a new criterion: ‘Minimise adverse impacts on livelihoods’. | Criterion 13 now reads: Protect and enhance, while minimizing adverse impacts on, economic, social and political well-being of relevant stakeholders with special attention to the most vulnerable and marginalized groups | 260
 |  | Mexican Environmental Law Center (CEMDA) | 261 | Proposed criterion: REDD debe de respetar y fortalecer [NAME] local English translation of proposed criterion:  REDD must respect and strengthen local governance structures | This comment will inform the RIMT | 261
 |  | Expert reviewer | 262 | My second comment concerns the subsequent Principle 3 (Promote and enhance sustainable livelihoods). The contribution of forest resources to local livelihoods has been widely researched (for example, recent results of CIFOR’s PEN study indicate that forests/woodlands contribute around 22-23% of total household income on average over the year); however, the two criteria of Principle 3 do not make any specific reference to the safeguard of local forest-based livelihoods. In my opinion it would be important to add a third criterion on this important aspect, for example something like ‘Minimise negative impacts on local peoples’ livelihoods based on access and use of forest resources’. | Principle 3 has been rephrased to now read: Promote and enhance forests’ contribution to sustainable livelihoods; and see comment 260 | 262
Principle 4 | Contribute to coherent low-carbon, climate-resilient and environmentally sound development policy, consistent with commitments under international conventions and agreements | Japan | 263 | Principle 4 should capture an element of Cancun Agreement 2 (a) more clearly, especially ‘’the objectives of national forest programmes’’, therefore should be modified as follows:  Contribute to low-carbon, climate-resilient and environmentally sound development policy, consistent with the objectives of national forest programmes and commitments under international conventions and agreements. | National Forests Programmes are covered in Criterion 13; [NAME] has more general focus | 263
 |  | Expert reviewer | 264 | According to the  widely quoted definition of sustainability (Brundtland Commission of the United Nations on March 20, 1987) “sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs." At the 2005 World Summit it was noted that this requires the reconciliation of environmental, social and economic demands - the "three pillars" of sustainability. I would therefore suggest to merge [NAME] and 4 into "ensuring the long term resilience of emission reductions in tropical forests by promoting sustainable development, social justice and biodiversity" | While recognising point about pillars of sustainable development, consider that 'bundling' the 2 principles would reduce clarity, imply linkages that may not hold true in all cases, and give insufficient  weight to sustainable livelihoods. | 264
 |  | Expert reviewer | 265 | All those statements about “Ensure consistency with and contribution to….” Are likely to involve some internal inconsistencies, since many of the issues requiring fairness are already not consistent with government policies in many countries…I understand the political need to say this, but I’m just warning that it may just be words…or else some of the other more substantive policies/principles may turn out just to be words on paper… | Good point; see response to comment 23 | 265
 |  | Expert reviewer | 266 | [Comment on "low-carbon"] I think this is risky/limiting to be put as a lens for reviewing performance, esp if some countries are not politically aligned to such a term. I think looking for “consistency” with national climate policy is enough as per the criteria, so perhaps omitting this. But not too fussy about it | For further internal discussion & consideration | 266
 |  | Facilitated consultation - Viet Nam | 267 | Some participants were wondering why there was no reference to the “+” in REDD+. This issue came up again in Principle 5, which was viewed as far too protectionist, after so many decades of working towards sustainable forest management. | SMF/SFM is covered both by criterion 13 and under Principle 6 (multiple functions) | 267
 |  | Expert reviewer | 268 | Why only ‘environmentally sound’ development policy  and not ‘socially sound’ or something equivalent.  Environmentally sound needs definition. | Agree. Principle amended. | 268
 |  | Facilitated consultation - DRC | 269 | Principle 4 : these should take into account traditional knowledge of Indigenous peoples. | These issues mainly addressed under criterion 7. | 269
 |  |  | 270 | Proposing to add « national » in the principle | Agree. 'National development strategies' included in revised Principle. | 270
 |  | Centre for Indigenous Cultures of Peru | 271 | Original P&C text in Spanish: CONTRIBUIR CON POLÍTICAS DE DESARROLLO COHERENTES DE REDUCCIÓN DEL CARBONO, ADAPTADAS AL CLIMA Y MEDIAMBIENTALMENTE APROPIADAS, CONSISTENTES CON LOS COMPROMISOS [NAME] LAS CONVENCIONES Y ACUERDOS INTERNACIONALES. Suggested wording:  CONTRIBUIR CON LAS POLÍTICAS DE DESARROLLO BAJO EN CARBONO, ADAPTADAS AL CLIMA Y MEDIAMBIENTALMENTE APROPIADAS, CONSISTENTES CON LOS COMPROMISOS ASUMIDOS EN LAS CONVENCIONES Y ACUERDOS INTERNACIONALES. Suggested wording translation:  CONTRIBUTE TO THE DEVELOPMENT POLICY IN CARBON, suitable to the climate mediambiental APPROPRIATE, CONSISTENT WITH THE COMMITMENTS IN INTERNATIONAL CONVENTIONS AND AGREEMENTS. | Translation advice noted with thanks; has been addressed in new version | 271
 |  | Mexican Environmental Law Center (CEMDA) | 272 | Comment in Spanish: [NAME] legislación local o nacional no es coherente con los estándares, se debe llevar a cabo un proceso de revisión que resulte en un plan para resolver las incoherencias.   Translation of comment: When the local or national legislation is not consistent with the standards, must conduct a review process that results in a plan to resolve the inconsistencies. | Recognise need to rephrase Spanish version, but note that proposed version changes the meaning, as criterion refers to national programme and its consistency with national policy (not ensuring consistency of national policy overall) | 272
 |  | Global Witness | 273 | Although Principle 7 addresses the need to minimise the effects of displacement of changes in land use on carbon stocks, biodiversity and ecosystems services, Principle 4 nor any other does not include a criterion to ensure overarching actions to reduce leakage. | Noted. [NAME] and 7 may be clearer on this. | 273
 |  | CBD LAC Regional Consultation on REDD+ and biodiversity safeguards (Working Group 3) | 274 | [On the issue of displacement of deforestation and forest degradation to areas of lower carbon value and high biodiversity value] Covered partially in those mentioned above [UN-REDD P&C 4,5 and 6] but lacks explicit inclusion of the low carbon/high biodiversity issue.                                                                                                                                                                          [On issue of increased pressure on non-forest ecosystems with high biodiversity value] As above [covered partially in those mentioned above [UN-REDD P&C 4,5 and 6]] but failure to explicitly cover non-forest ecosystems | Criterion 19 did cover this issue for forest and non-forest ecosystems. But revising Principle 7 to draw greater attention to non-forest ecosystems. | 274
Criterion 10 | Ensure consistency with and contribution to national climate policy objectives, including mitigation and adaptation strategies and international commitments | WWF | 275 | Criteria 9 and 10: These criteria could be re‐worked to be more precise and measurable. | Retain current form for consistency with other criteria; to discuss further in next round of revision | 275
 |  | Expert reviewer | 276 | This is a good criterion but it would be helpful to have more information on what would actually entail and how it would be carried out on the ground. | Details are likely to be covered in Risk Assessment & Mitigation tool, which will give examples of relevant national climate policies (NAPA etc) | 276
 |  | Centre for Indigenous Cultures of Peru | 277 | Original P&C text in Spanish: Garantizar la consistencia con y la contribución a objetivos de políticas climáticas nacionales, incluyendo estrategias de mitigación y adaptación y compromisos internacionales. Suggested wording:  Contribuir y garantizar [NAME] objetivos [NAME] nacionales sobre [NAME] con [NAME], adaptación, biodiversidad y compromisos internacionales. Suggested wording translation:  Contribute to and ensure the consistency of the objectives of national policies on climate change mitigation strategies, adaptation, biodiversity and international commitments. | Translation issue noted with thanks, also see comment 272. | 277
Criterion 11 | Address the risk of reversals including potential future risks to forest carbon stocks and other benefits to ensure the efficiency and effectiveness of REDD+ | Ecuador | 278 | Define ‘efficiency’ and ‘effectiveness’ in the glossary. | "Efficiency and effectiveness of REDD+" added to glossary | 278
 |  | Expert reviewer | 279 | In my view criteria 16 (Ensure that land use planning for REDD+ explicitly takes account of ecosystem services) would better fit under principle 3  (Promote and enhance sustainable livelihoods). The 2 reasons why we MUST conserve forest biodiversity under REDD+ are  1) Biodiverse ecosystems provide a wealth of services to local populations (food , water and energy security, remedies and shelter, fodder), which increase their (non commercial) standing value and 2) Biodiverse ecosystems are more resilient and can therefore better prevent climate induced dieback (hence reversals). [NAME] is therefore redundant as it should already be picked up in criteria 16 and in the overall architecture of REDD+ (MRV and accounting). | Please refer to the response to comment 230 | 279
 |  |  | 280 | [From track changes document] Address the risk of reversals including potential future risks to forest carbon stocks and other benefits to ensure the efficiency and effectiveness of REDD+ | Please refer to the response to comment 230 | 280
 |  | Expert reviewer | 281 | Clarify what you mean by reversals . Add this term to the glossary. | "Reversals" have been added to glossary | 281
Criterion 12 | Ensure consistency with and contribution to national poverty reduction strategies and other sustainable development goals | Japan | 282 | This criterion should be moved to Principle 3. | To further discuss | 282
 |  | WWF; WWF Viet Nam | 283 | Criterion 12: Ensure consistency with and contribution to national poverty reduction strategies and other sustainable development goals, (add) including alignment with the development and other strategies of ministries, regional governments and other government bodies that may have an impact on the forest sector, direct and indirect land use change. | Will cover these issues in the RIMT | 283
 |  | Expert reviewer | 284 | This is a good criterion to aim for, but several recent studies have suggested that REDD+ mitigation goals are not always compatible with poverty reduction strategies- so tradeoffs are likely. I would suggest adding something about how to deal with tradeoffs when these arise. | Please refer to response to comment 23 | 284
 |  | Centre for Indigenous Cultures of Peru | 285 | Original P&C text in Spanish: Garantizar la consistencia con y la contribución a las estrategias de reducción de pobreza y otros objetivos de desarrollo sustentable nacionales. Suggested wording: Garantizar consistencia y contribución a las estrategias [NAME] pobreza y otros objetivos del desarrollo sustentable nacional y [NAME] del Milenio. Suggested wording translation:  Ensure consistency and contribution strategies poverty reduction and other national sustainable development goals and Millennium Development Goals. | The RIMT will be covered in the RIMT | 285
 |  | Mexican Environmental Law Center (CEMDA) | 286 | Original P&C text in Spanish: Garantizar la consistencia con y la contribución a las estrategias de reducción de pobreza y otros objetivos de desarrollo sustentable nacionales. Suggested wording: Garantizar la consistencia con y la contribución a las estrategias de reducción de pobreza, respeto a los derechos de los pueblos indígenas y otros objetivos de desarrollo sustentable nacionales Suggested wording translation: Ensure consistency with and contribution to poverty reduction strategies, respect the rights of indigenous peoples and other national sustainable development goals | For further internal discussion & consideration | 286
 |  | Expert reviewer | 287 | Add “objectives of national forest programmes” (see REDD safeguards text) | This point is now covered in Criterion 13 | 287
 |  |  | 288 | The terms “goals”, “objectives” and “strategies” are used almost interchangeably. I think there could be more consistency. | To a degree, this reflects common usage in the different contexts, but will continue to check for consistency. | 288
 |  | Conservation International (CI) | 289 | Criterion 12, add “Ensure consistency with development and other strategies of ministries, regional governments and other government bodies that may have an impact on the forest sector, direct and indirect land use change.” | This is a useful point on subnational plans & strategies - for further consideration and discussion. | 289
Criterion 13 | Ensure consistency with and contribution to national biodiversity conservation, other environmental and natural resource management policy objectives, national forest programmes, and international commitments | Japan | 290 | Considering the importance of national forest programmes mentioned on Cancun Agreement 2 (a), national forest programmes and national resource policy objectives should be singled out. Therefore, criterion 13 should be divided and modified as follows:  Criterion 13:  Ensure consistency with and contribution to national biodiversity conservation, other environmental and natural resource management policy objectives, national forest programmes, and international commitments  And   Criterion 13 bis: Ensure consistency with and contribution to national forest programmes as well as environmental and national resource management policy objectives | This is a difficult balance difficult to strike -  for further consideration and discussion. | 290
 |  | WWF; WWF Viet Nam | 291 | Criterion 13: Ensure consistency with and contribution to national biodiversity conservation, other environmental and natural resource management policy objectives (add) and associated land-use planning, national forest programmes and international commitments. | For further consideration & discussion: could be added to Principle or to Criteria 12 & 13 (not exclusively associated with environmental goals) | 291
 |  | Facilitated consultation - Viet Nam | 292 | [Comment regarding "national forest programmes"] Why have nfps under international commitments. Why have other national policies or strategies under international commitments. | Principle is not intended only to address international commitments; hope that this is clearer in revised version | 292
 |  | Expert reviewer | 293 | It might be worth also highlighting the need for consistency with agriculture, biofuel (energy) and mining policies. | These should be covered by reference to development & natural resource management policies. | 293
 |  |  | 294 | Again, this is a great criterion in principle- but difficult to imagine how it would be implemented on the ground and what it would actually entail. | Please see response to comment 276 | 294
 |  | Solomon Islands | 295 | Include the word sustainable  as the current statement sound too broad So should read: National Sustainable Forest Programmes. Note :There needs to be systems/guidelines/mechanisms/processes/frameworks  in place  to meet/achieve the above principles and criteria | We would rather stick with Cancun terminology.  Systems are indeed required but separate from P&C themselves: to be developed. | 295
 |  | Centre for Indigenous Cultures of Peru | 296 | Original P&C text in Spanish: Garantizar la consistencia con y la contribución con [NAME] nacional, otros objetivos de políticas medioambientales y de manejo de recursos naturales, programas forestales nacionales y compromisos internacionales. Suggested wording: Garantizar consistencia y contribución con [NAME], otros objetivos de políticas medioambientales, [NAME] naturales y programas forestales con los compromisos internacionales. Suggested wording translation:  Ensure consistency and contribution to the conservation of biodiversity, other objectives of environmental policies, natural resource management and forestry programs with international commitments. | Translation issue noted with thanks; criterion has been reformulated | 296
 |  | Expert reviewer | 297 | [Comment regarding "natural resource management policy"] Not clear what exactly this aims to refer to. Land use? Energy? | "Natural resource" added to glossary | 297
Additional suggested criteria under Principle 4 |  | Expert reviewer | 298 | The word "drivers" does not appear anywhere. A demonstrated political commitment to identifying all the major drivers of deforestation and degradation is needed to tackle REDD+ in a way that does not expose populations and ecosystems to inconsistent policies: Infrastructure (e.g .roads), energy (e.g. dams) and foreign direct investment in agriculture, forestry and mining projects are not politically comfortable to discuss, but if countries are simply leaving them out of their REDD+ assessment, this is a sure sign that their plans will almost certainly fail. Countries should at a bare minimum be able to report on major infrastructure projects, on trade data in key commodities, and on robust mitigation strategies for the relative impacts of these different sectors/drivers. I would therefore advise to introduce another criterion under Principle 4. | Agree that where existing policies drive deforestation then coherence will entail policy change. This thinking should inform the development of the RIMT, especially with respect to risk of reversals. | 298
 |  |  | 299 | [From track changes document] Criterion 13 – Identify the major drivers of deforestation and degradation related to infrastructure (e.g .roads), energy (e.g. dams), agriculture, forestry and mining projects and develop strategies for addressing the impacts on forests of major infrastructure projects, and of the production, consumption and trade of relevant commodities. Criterion 14 – Ensure that land use planning for REDD+ explicitly takes account of ecosystem services and biodiversity conservation in relation to local and other stakeholders’ values, and potential trade-offs between different benefits. | We will tackle proposed new criterion in RIMT (see comment 298); we feel that Criterion 16 should stay where it is as it is specifically about REDD+ impacts rather than overall policy / land-use coherence. | 299
 |  | Expert reviewer | 300 | Why are the only references to international commitments under climate policy and biodiversity criteria?  Many groups are concerned that governments will not respect their international commitment under ILO 169 and UNDRIP.  It would be better to create a separate criterion requiring consistency with and contribution to all commitments related to international treaties, conventions and other instruments ratified or adopted by the country.  There is no mention of human rights in any principle or criteria and we recommend addressing this explicitly.  The only reference to rights is P2 where the criteria only cover women’s rights and land/resource rights. | On rights, see rewording of Principle 2: "Respect and protect stakeholder rights, including human rights, statutory and customary rights, and collective rights", with associated criteria.   On international commitments, we prefer to address this in details in the RIMT. | 300
 |  | Mexican Environmental Law Center (CEMDA) | 301 | Proposed criterion: REDD debe de desarrollarse en un marco de alineación de políticas publicas  English translation of proposed criterion:  REDD must be developed within a framework of public policy alignment | Not all countries have such an over-arching framework in place, and its development is beyond the scope of REDD+; the approach here has been to check consistency of REDD+ with relevant sectors, but not to address overall consistency between sectors. Tool to encourage framework development. | 301
Principle 5 | Protect natural forest from degradation or conversion to other land uses, including plantation forest | Expert reviewer | 302 | As regards principles 5, 6 and 7, the criteria are fine but I would have arranged them otherwise and would recommend highlighting the importance of soils. Please see the track changes here attached | We think the new sequence makes sense - natural forest; multiple functions of (all) forest; non-forest ecosystems | 302
 |  |  | 303 | [From track changes document] Protect forest biodiversity and natural forests from direct degradation or conversion to other land uses, including  plantation forests | This principle addresses the UNFCCC safeguard on all natural forest. Biodiversity maintenance is tackled in Principle 6. Have moved Criterion on indirect impacts into tihs Principle, in separating impacts on forest (new version of P5) from those on other ecosystems (new version of P7). | 303
 |  | Greenpeace International | 304 | Principle 5 and its criteria 14 and 15 fail to prioritise intact forest landscapes and their crucial role in mitigating and adapting to climate change, biodiversity and livelihoods as evidenced in CBD Technical Series No 10, 41 and 59 (see also the attachment of our new report: Intact [NAME]) | Agree that intactness and extent foster resilience; and the maintenance of large forests is essential for emissions reduction. UNFCCC safeguards are intended to protect all natural forest, not just IFLs. Consider addressing IFLs directly in RIMT. | 304
 |  | WWF | 305 | Principle 5, Criteria 14 and 15: This principle and the associated criteria should also aim to protect other natural (non forest) habitats such as natural peat, grassland and freshwater habitats from conversion and degradation. WWF is aware that only natural forests are mentioned in the Cancun agreement, however, this would be a significant improvement of the biodiversity safeguard and would also provide consistency with the UN CBD. | Principle 7 now focuses specifically on non-forest ecosystems, including direct impacts of REDD+ activities. Separate criteria provided on direct and indirect impacts on forest ecosystems. | 305
 |  | Facilitated consultation - DRC | 306 | Principe 5 should become a criterion under principle 6 | Good thought, but specifically addressing both natural forest & multiple functions language from [NAME] at Principle level seems important. Also emphasises importance of both reducing harms and promoting benefits. | 306
 |  |  | 307 | The principle should be formulated as « and » or « and/or » rather than simply « or » | Reformulated to "protect natural forest from degradation and/or conversion..." | 307
 |  | Centre for Indigenous Cultures of Peru | 308 | Original P&C text in Spanish: PROTEGER LOS BOSQUES NATURALES DE LA DEGRADACIÓN O DE LA CONVERSIÓN A OTROS USOS DEL TERRENO, INCLUYENDO LAS PLANTACIONES FORESTALES. Suggested wording: PROTEGER LOS BOSQUES NATURALES DE LA DEGRADACIÓN Y CAMBIO DE USO DE LA TIERRA, INCLUYENDO LAS PLANTACIONES FORESTALES. Suggested wording translation:  PROTECT NATURAL FOREST DEGRADATION AND CHANGE OF USE OF LAND, INCLUDING THE FOREST PLANTATIONS. Comment:  [NAME] sugiere utilizar la palabra “tierra” como [NAME] palabra “land” y evitar el uso de la palabra “terreno”. Translation of comment: We suggest using the word "tierra" as a translation of the word "land" and avoid using the word "terreno." | Translation suggestion noted with thanks and addressed in new version | 308
 |  | Facilitated consultation - Nigeria | 309 | [Comment regarding "natural forest"] The glossary and tool need to include some discussion of implications of varying national definitions of forest | Glossary entry updated  to recognise variation in national definitions | 309
 |  | Global Witness | 310 | Although it is welcome that Principle 5 recognises the importance of natural forest, the Principles and Criteria should also specifically emphasise the need for protection of intact forest landscapes in recognition of their significant value for mitigating and adapting to climate change, biodiversity and livelihoods. | Please refer to response to comment 304 | 310
 |  | CBD LAC Regional Consultation on REDD+ and biodiversity safeguards (Working Group 3) | 311 | [On the issue of displacement of deforestation and forest degradation to areas of lower carbon value and high biodiversity value] Covered partially in those mentioned above [UN-REDD P&C 4,5 and 6] but lacks explicit inclusion of the low carbon/high biodiversity issue.                                                                                                                                                                             [On issue of increased pressure on non-forest ecosystems with high biodiversity value] As above [covered partially in those mentioned above [UN-REDD P&C 4,5 and 6]] but failure to explicitly cover non-forest ecosystems | Please refer to response to comment 92 | 311
Criterion 14 | Ensure that REDD+ activities do not cause the conversion of natural forest to other land uses, including plantation forest, and make reducing conversion due to other causes (e.g. agriculture, timber and fuelwood extraction, infrastructure development) a REDD+ priority | Expert reviewer | 312 | [From track changes document] Ensure that REDD+ activities do not cause the conversion of natural forest to other land uses, including plantation forests., and make reducing conversion due to other causes (e.g. agriculture, timber and fuelwood extraction, infrastructure development) a REDD+ priority | We feel that it is useful to indicate that while substantial deforestation is occurring, REDD+ activities should focus on reducing that deforestation (over e.g. creating new forest) | 312
 |  | Facilitated consultation - DRC | 313 | Criterion 14 : it is unclear who this is directed to | All criteria are intended in the first instance to inform development of National Programme - is the problem in understanding the potential risk from REDD+ activities to natural forest?  The RIMT may help here. | 313
 |  | Centre for Indigenous Cultures of Peru | 314 | Original P&C text in Spanish: Garantizar que las actividades de REDD+ no causan la conversión de los bosques naturales a otros usos del terreno, incluyendo las plantaciones forestales y hacer [NAME] reducción en la [NAME] a otras causas (por ejemplo agricultura, extracción de madera y leña, desarrollo de infraestructura) sea una [NAME] Suggested wording: [NAME] que [NAME] eviten cambios en el uso de la tierra de los bosques naturales, incluyendo las plantaciones forestales; además REDD+ [NAME] en el uso de la tierra (por ejemplo agricultura comercial, extracción de madera, [NAME], minería, hidrocarburos y [NAME]). Suggested wording translation:  Ensure that REDD + avoid changes in land use from natural forests, including forest plantations as well REDD + prioritizes other causes of change in land use(eg commercial agriculture, logging, urban expansion , mining, oil and road construction). | Translation advice noted with thanks and addressed in new version | 314
 |  | Facilitated consultation - Nigeria | 315 | There was considerable discussion for both this criterion and 15 about how conversion or degradation could possibly happen as a result of REDD activities.  Eventually the group came up with several examples/scenarios, but it will be crucial to include such illustrations somewhere, so that they can make the risks clearer to those who have not thought about them previously | Please refer to response to comment 313.  E.g. for degradation: enhancement of forest carbon stocks by enrichment planting with selected species may reduce biodiversity and related services | 315
Criterion 15 | Minimise degradation of natural forest by REDD+ activities and make reducing degradation due to other causes (e.g. agriculture, timber and fuelwood extraction, infrastructure development) a REDD+ priority | Greenpeace International | 316 | Criterion 15: “minimize degradation of natural forests by REDD+ activities”  is open to confusion as REDD+ activities should not cause the degradation of natural forests in the first place (as that would defeat the purpose of REDD). | Please refer to response to comment  315. | 316
 |  | Expert reviewer | 317 | [From track changes document] [NAME] forest monitoring, reporting and verification systems that can capture the conversion or degradation of natural forests.  by REDD+ activities and make reducing degradation due to other causes (e.g. agriculture, timber and fuelwood extraction, infrastructure development) a REDD+ priority | Please refer to response to comment  312. Reference to monitoring systems is omitted from all P&C; it is a cross-cutting issue and the decision was taken to refer to them in the RIMT. | 317
 |  | Facilitated consultation - Nigeria | 318 | The group thought this could be stronger, using ‘avoid’ rather than ‘minimize’, but after some discussion understood the reasoning behind this phrasing | Noted with thanks. | 318
 |  | Global Witness | 319 | It is unclear why Criterion 15 calls for countries to “Minimise degradation of natural forest by REDD+ activities”. REDD+ activities should not cause any degradation of natural forest and should instead reduce degradation. | Please refer to response to comment 315. | 319
Additional suggested criteria under Principle 5 |  | Expert reviewer | 320 | Criterion or separate principle—(ensure proper collection, monitoring and reporting of science-based REDD+ related information / integrity of data). This could similarly be a separate principle with criterion stopping short of meddling into the actual data quality, but providing minimum safeguard on source and verification of data by national body ( just as an example) | Please refer to response to comment 317. | 320
Principle 6 | Maintain and enhance multiple functions of forest to deliver benefits including biodiversity conservation and ecosystem services | Ecuador | 321 | Define ‘ecosystem services’ in the glossary. | Ecosystem services definition added to Glossary | 321
 |  | Expert reviewer | 322 | As regards principles 5, 6 and 7, the criteria are fine but I would have arranged them otherwise and would recommend highlighting the importance of soils. Please see the track changes here attached | Reorganised with different aim in mind, see comment 307 | 322
 |  |  | 323 | [From track changes document] Maintain and enhance multiple functions of forest to deliver benefits including biodiversity conservation and ecosystem services | Please refer to response to comment 322 | 323
 |  | Expert reviewer | 324 | Maybe Principles 6 & 7 can be collapsed, because they are very similar | Please refer to response to comment  322 | 324
 |  | Facilitated consultation - DRC | 325 | Suggestion to have principle 6 reworded as « preservation of the environment, conservation of biodiversity and production of ecosystem services » [Footnote: also has bearings on Principle 7] | While combining the idea of minimising impacts with that of maintaining ecosystems in a single Principle has some merit, there is also a case to be made for keeping these ideas separate, especially with a view to highlighting indirect impacts and non-forest ecosystems. See also comment 307 | 325
 |  |  | 326 | Principe 6 and 7 should be merged  and address maintain and improve. [comment: This was brought up by 4 different participants in various forms. Similar proposals were to combine criteria 16 and 18, and 17,19 and 20] | Please refer to response to comment 325 | 326
 |  | CBD LAC Regional Consultation on REDD+ and biodiversity safeguards (Working Group 3) | 327 | [On the issue of displacement of deforestation and forest degradation to areas of lower carbon value and high biodiversity value] Covered partially in those mentioned above [UN-REDD P&C 4,5 and 6] but lacks explicit inclusion of the low carbon/high biodiversity issue.                                                                                                                                                                             [On issue of increased pressure on non-forest ecosystems with high biodiversity value and afforestation in areas of high biodiversity value. (lack of consensus on definitions)] As above [covered partially in those mentioned above [UN-REDD P&C 4,5 and 6]] but failure to explicitly cover non-forest ecosystems | Please refer to response to comment  92 | 327
Criterion 16 | Ensure that land use planning for REDD+ explicitly takes account of ecosystem services and biodiversity conservation in relation to local and other stakeholders' values, and potential trade-offs between different benefits | Expert reviewer | 328 | In my view criteria 16 (Ensure that land use planning for REDD+ explicitly takes account of ecosystem services) would better fit under principle 3  (Promote and enhance sustainable livelihoods). The 2 reasons why we MUST conserve forest biodiversity under REDD+ are  1) Biodiverse ecosystems provide a wealth of services to local populations (food , water and energy security, remedies and shelter, fodder), which increase their (non commercial) standing value and 2) Biodiverse ecosystems are more resilient and can therefore better prevent climate induced dieback (hence reversals). [NAME] is therefore redundant as it should already be picked up in criteria 16 and in the overall architecture of REDD+ (MRV and accounting). | Please refer to response to comment  230 | 328
 |  |  | 329 | [From track changes document] Ensure that land use planning for REDD+ explicitly takes account of ecosystem services and biodiversity conservation in relation to local and other stakeholders' values, and potential trade-offs between different benefits | Please refer to response to comment 322 | 329
 |  | Facilitated consultation - Viet Nam | 330 | [Comment regarding "land-use planning"] One participant noted positively the link to a particular action, i.e. land use planning, which was noted was missing from most principles. Instead they read more like statements of intent. | The Risk Identification and Mitigation tool will provide links between principles and actions to be taken | 330
 |  |  | 331 | [Comment regarding "other"] What is meant by other, what hierarchical level? | This means potentially all other stakeholders. Non-local stakeholders may have values that are relevant but different, e.g. national or global values attached to particular components of biodiversity. | 331
 |  | Expert reviewer | 332 | Clarify what 'takes account' means here. What gets priority- those forests that are of extremely high importance for biodiversity and/or ES, or those that are valued by stakeholders? We know from experience that the two do not always match up- so it would be helpful to be more specific here. | Agree that there will be trade-offs, but outcome cannot be dictated by P & C; the aim is to ensure that they are considered in land-use planning | 332
 |  | Centre for Indigenous Cultures of Peru | 333 | Original P&C text in Spanish: Garantizar que la planificación de uso del terreno para REDD+ tenga en cuenta explícitamente los servicios [NAME] y [NAME] en relación a los valores de los actores relevantes locales y otros y las potenciales soluciones de compromiso entre los diferentes beneficios. Suggested wording: Garantizar que la planificación en el uso de la tierra para REDD+ considere explícitamente los servicios ecosistémicos y conservación de la biodiversidad en concordancia con la valoración de las partes interesadas. Suggested wording translation:  Ensure that planning in the use of land for REDD + explicitly considersecosystem services and biodiversity conservation in accordance with the valuation of the parties concerned. | Noted with thanks, addressed in new version | 333
 |  | Mexican Environmental Law Center (CEMDA) | 334 | Original P&C text in Spanish: Garantizar que la planificación de uso del terreno para REDD+ tenga en cuenta explícitamente los servicios [NAME] y [NAME] en relación a los valores de los actores relevantes locales y otros y las potenciales soluciones de compromiso entre los diferentes beneficios. Suggested wording: Garantizar que la planificación integral de los recursos  en congruencia con [NAME] REDD+ tenga en cuenta explícitamente los servicios [NAME] y [NAME]  biodiversidad en relación a los valores de los actores relevantes locales y otros, y las potenciales soluciones de compromiso entre los  diferentes beneficios Suggested wording translation: Ensure integrated planning of resources consistent with the land use for REDD +take explicit account of ecosystem services and biodiversity conservation in relation to the values of actors relevant local and other, and the potential trade-offs between different benefits | New suggested wording seems unclear, if it refers to all land use planning, is beyond scope of UN-REDD Programme. Partially addressed in new version | 334
 |  | Conservation International (CI) | 335 | Amend Criterion 16 to read:  “Ensure that land use planning for REDD+ explicitly takes account of ecosystem services and biodiversity conservation in relation to local and other stakeholders’ values, and potential synergies and trade-offs between different benefits.” | Agreed, updated to include 'synergies' | 335
Criterion 17 | Ensure that new and existing forests are managed to maintain and enhance ecosystem services and biodiversity important in both local and national contexts | Japan | 336 | Since it is unclear when forests become “new” forests., “new and existing” should be deleted. | Criterion altered to planted & natural forest; "planted forest" added to glossary | 336
 |  |  | 337 | While this principle mentions multiple functions of forest, criterion seems to limit to ecosystem and biodiversity.  So this criterion should be modified to capture the essence of para 2(e) in Appendix II of the Cancun Agreement in practical manner as below:  Ensure that new and existing forests are managed in accordance with appropriate forest management practices  to maintain and enhance multiple functions of forests to deliver a wide range of environmental and social benefits and economic viability ecosystem services and biodiversity important in both local and national contexts | Ecosystem services do deliver the full range of multiple functions of forest; the intention is to address social and environmental benefits as raised by Cancun 2e across Principle 3 and Principle 6. See also rewording of Principle 3 on forests' contribution to livelihoods. | 337
 |  | Expert reviewer | 338 | [From track changes document] Ensure that new and existing commercial forests are managed to maintain and enhance ecosystem services and biodiversity. important in both local and national contexts | Management is not restricted to production forests, and may include, e.g. conservation management, community forest management, etc. See also comment 336. | 338
 |  | Greenpeace International | 339 | Criterion 17: It is not clear what is meant by “new forests” here. Furthermore, global importance should be added to local and national importance. | Please refer to response to comment  336. Global importance so far excluded because of strength of criterion language ('ensure'; 'enhance'). | 339
 |  | Facilitated consultation - Viet Nam | 340 | [Comment regarding "national"] Similar to the comment above, biodiversity does not stop at national borders. What about transboundary, regional and global contexts. | Please refer to response to comment 339 | 340
 |  | Expert reviewer | 341 | For 'new forests' (which I assume means new forest plantations), we should include a criterion that new forest plantations should, whenever possible, be planted with a diverse mix of native tree species, to enhance their biodiversity and ES value. | Agree this is a good ambition, but difficult to make absolute requirement; detailed guidance like this will be part of the RIMT | 341
 |  | Global Witness | 342 | Under Criterion 17, forest management should not only maintain and enhance those ecosystem services and biodiversity that are important in local and national contexts but also prioritise those that are important at the global level. | Please refer to response to comment 339 | 342
 |  | CBD LAC Regional Consultation on REDD+ and biodiversity safeguards (Working Group 2) | 343 | [ Comment regarding afforestation in areas of high biodiversity value]: It was unclear whether afforestation is contemplated under REDD-plus (request clarification from UNFCCCS)? Clarification of the Cancun safeguards is needed with regard to afforestation and reforestation and forest restoration. There is also no specific mention of A/R in the three safeguard approaches, although several principles and criteria address it indirectly. This also goes for the introduction of biofuel crops through plantations for biofuels  Afforestation in degraded areas (of low biodiversity value) is acceptable, as it can relieve pressure on areas of high biodiversity value The form and modalities of afforestation should be taken into account; Cancun safeguards do not clarify type of afforestation (mono-culture, exotic species, etc.) Whether or not biodiversity concerns are addressed depends to a large degree on the interpretation of certain terms, including 'natural forests' and | Our understanding is that forest restoration, afforestation and reforestation are all included in enhancement of forest carbon stocks.  Principle 5/Criterion 14 explicitly refers to plantation forest as a REDD+ activity. RIMT will draw on & refer to CBD guidance. | 343
Additional suggested criteria under Principle 6 |  | WWF; WWF Viet Nam | 344 | We suggest an additional criterion to address the risks and potential benefits associated with forest restoration: “The enhancement of forest carbon stocks, afforestation and reforestation should seek to match the original biodiversity of the area, prioritizing the use of a mix of locally native tree species and should be conducted only on ecologically appropriate lands in order to ensure, or restore when degraded, ecosystem integrity and function.” | Please refer to response to comment 341 | 344
 |  | Mexican Environmental Law Center (CEMDA) | 345 | Proposed criterion: Promover la gestión integral del territorio English translation of proposed criterion:  Promote integrated land management | To a large degree, this is covered by Criterion 16 and C. 13, which address land use planning for REDD and coherent natural resource management.  While integrated land management is indeed desirable, it may exceed the remit of UN-REDD Programme. | 345
 |  | Conservation International (CI) | 346 | Add Criterion X under Principle 6:  “Under enhancement of forest carbon stocks, afforestation and reforestation should prioritize the use of a mix of native tree species and be conducted only on ecologically appropriate lands in order to ensure ecosystem integrity and function.” | Please refer to response to comment  341 | 346
Principle 7 | Minimise indirect adverse impacts on ecosystem services and biodiversity | Ecuador | 347 | Define ‘ecosystem services’ in the glossary. | Ecosystem services definition added to Glossary | 347
 |  |  | 348 | ‘Minimise’ may be too broad and may not guarantee the mitigation of harmful impacts. Actions should be preventive. ‘Minimise’ could be replaced by ‘Prevent indirect adverse impacts on ecosystem services and biodiversity’ | Absolute prevention of harmful impacts is unlikely to be feasible in most cases, therefore suggest 'minimize' is more appropriate wording. | 348
 |  |  | 349 | Harmonize the three criteria either with ‘impacts’ or ‘effects’ | Agree:  Use "impacts" for all these criteria | 349
 |  | Expert reviewer | 350 | As regards principles 5, 6 and 7, the criteria are fine but I would have arranged them otherwise and would recommend highlighting the importance of soils. Please see the track changes here attached. | Please refer to response to comment  322 | 350
 |  |  | 351 | [From track changes document] Minimise indirect adverse impacts on soils, ecosystem services and biodiversity | While soils have high importance, they seem to be covered already in the mentions of both carbon and ecosystem services (and biodiversity). Elaboration in RIMT will refer to soils explicitly. | 351
 |  | Expert reviewer | 352 | Maybe Principles 6 & 7 can be collapsed, because they are very similar | Please refer to response to comment  322 | 352
 |  | Centre for Indigenous Cultures of Peru | 353 | Original P&C text in Spanish: MINIMIZAR LOS IMPACTOS ADVERSOS INDIRECTOS SOBRE LOS SERVICIOS DE ECOSISTEMAS Y LA BIODIVERSIDAD. Suggested wording: MINIMIZAR LOS IMPACTOS NEGATIVOS INDIRECTOS SOBRE LOS SERVICIOS ECOSISTEMICOS Y LA BIODIVERSIDAD. Suggested wording translation: MINIMIZE indirect negative impacts on ecosystem services and biodiversity. | Noted; relevant criterion has been revised | 353
 |  | Facilitated consultation - Nigeria | 354 | [Comment regarding "indirect adverse impacts"] There needs to be a good glossary entry for this term | Direct and indirect impacts now tackled separately, with examples of indirect impacts in the criteria. | 354
 |  |  | 355 | There was some constructive discussion of whether an additional criterion is needed to deal with “downstream impacts” and aquatic systems – the resolution was that these are adequately covered by criteria 19 and 20. Ensure that these are adequately covered in glossary. | To ensure that RIMT covers these impacts. | 355
Criterion 18 | Minimise harmful effects on carbon stocks of forest and non-forest ecosystems resulting from displacement of changes in land use (including extractive activities) | Expert reviewer | 356 | [From track changes document] Minimise harmful effects on carbon stocks of forest and non-forest soils and ecosystems resulting from displacement of changes in land use (including extractive activities). | Please refer to response to comment 351 | 356
 |  | Facilitated consultation - Viet Nam | 357 | We are aware of displacement of emissions. Displacement of changes in land use, we found confusing. We believe that criteria 18 and 19, need some serious rewriting, but we did not have the time to do so. | Updated glossary entry | 357
 |  | Centre for Indigenous Cultures of Peru | 358 | Original P&C text in Spanish: [NAME] efectos [NAME] [NAME] forestales y no forestales que resultan de variaciones en los cambios en el uso del terreno (incluyendo actividades extractivas). Suggested wording: [NAME] efectos negativos en las reservas de carbono de los ecosistemas forestales y no forestales como resultado de los cambios en el uso de la tierra (incluyendo actividades extractivas). Suggested wording translation: Minimize negative impacts on carbon stocks in forest ecosystems and forest as a result of changes in land use (including mining activities). Comment:  [NAME] sugiere utilizar la palabra “tierra” como [NAME] palabra “land” y evitar el uso de la palabra “terreno”. Translation of comment: We suggest using the word "tierra" as a translation of the word "land" and avoid using the word "terreno." | Translation advice noted, with thanks.  Criterion has been re-formulated | 358
 |  | Facilitated consultation - Nigeria | 359 | Tool could usefully include reference to measures that enhance efficiency of use of forest products | Agree examples to be included in RIMT, e.g. More efficient charcoal production and use reduce likely displacement of fuelwood harvest | 359
Criterion 19 | Minimise harmful effects on biodiversity and other ecosystem services of forest and non-forest ecosystems resulting from displacement of changes in land use (including extractive activities) | Facilitated consultation - Viet Nam | 360 | We are aware of displacement of emissions. Displacement of changes in land use, we found confusing. We believe that criteria 18 and 19, need some serious rewriting, but we did not have the time to do so. | Please refer to response to comment 357 | 360
 |  | Centre for Indigenous Cultures of Peru | 361 | Original P&C text in Spanish: [NAME] efectos dañinos sobre la biodiversidad y otros servicios [NAME] forestales y no forestales que resultan de variaciones en los cambios de cambios en el uso del terreno. Suggested wording:  [NAME] efectos negativos en la biodiversidad y otros servicios ecosistémicos forestales y no forestales como resultado [NAME] en el uso de la tierra. Suggested wording translation: Minimize negative impacts on biodiversity and other forest ecosystem services and non-forest as a result of the change in land use. Comment:  [NAME] sugiere utilizar la palabra “tierra” como [NAME] palabra “land” y evitar el uso de la palabra “terreno”. Translation of comment: We suggest using the word "tierra" as a translation of the word "land" and avoid using the word "terreno." | Translation advice noted with thanks.  Criterion re-formulated and reference to extractive activities included | 361
 |  | Conservation International (CI) | 362 | Criterion 19 should also address the risk that efforts to enhance forest carbon stocks under REDD+ could include afforestation on land with high biodiversity value or otherwise providing important ecosystem services.  It should, thus, be amended:  “Put measures in place to reduce or avoid negative impacts on biodiversity and other ecosystem services in forest and non-forest ecosystems resulting either from displacement of changes in land use or directly from REDD+ activities.” | Revised criteria for Principle 7 now deal separately with direct and indirect impacts on non-forest ecosystems | 362
Criterion 20 | Minimise other indirect impacts on biodiversity, such as those resulting from intensification of land use | WWF | 363 | Criterion 20: Minimise other indirect impacts on biodiversity (add) and ecosystems services, such as soil or water pollution, resulting from intensification of land use. | This is a good point, but seems to us to go beyond the [NAME] text; in theory addressing biodiversity protection should help to protect other ecosystem services.  We have however included carbon stocks, the other service that is addressed by [NAME] ("reduce displacement of emissions") | 363
 |  | Expert reviewer | 364 | [From track changes document] Minimise other indirect impacts on soils and biodiversity, such as those resulting from intensification of land use. | Please refer to response to comments  351 and 363 | 364
 |  | Centre for Indigenous Cultures of Peru | 365 | Original P&C text in Spanish: [NAME] otros aspectos indirectos sobre [NAME], tales aquellos que resultan de la intensificación del uso del terreno. Suggested wording:  [NAME] otros impactos indirectos sobre la biodiversidad, como aquellos que resultan de la intensificación del uso de la tierra. Suggested wording translation:  Minimize other indirect impacts on biodiversity, such as those resulting from the intensification of land use. Comment: Se sugiere utilizar la palabra “tierra” como [NAME] palabra “land” y evitar el uso de la palabra “terreno”. Translation of comment: We suggest using the word "tierra" as a translation of the word "land" and avoid using the word "terreno." | translation advice noted with thanks; criterion re-formulated | 365
 |  | Facilitated consultation - Nigeria | 366 | The tool should reference a range of effects and examples | To ensure that RIMT covers a range of examples of indirect impacts. | 366
Additional principles proposed |  | Greenpeace International | 367 | A principle on the need to establish national accounting and monitoring systems in order to avoid leakage and the development of subsequent criteria is completely missing from the text, as is a safeguard to ensure the permanence of forests.  Any set of safeguards that does not adequately address these two critical environmental considerations cannot be considered sufficient for purposes of REDD. | To be addressed in tool treatment of criteria 15, 20, 23, 24 and 25, which address leakage (impacts on carbon stocks) and permanence (risk of reversals) | 367
 |  | Expert reviewer | 368 | It would be good, given the influence of population increase on global warming and a variety of other important issues (like biodiversity loss, global poverty and marginalization, etc.), if there could be something about maintaining or reducing population (with the usual safeguards against forced population control programs)---I see this as a win win strategy since the Earth benefits if there are fewer people, and women benefit (and indirectly their families) if they have some control over their own fertility. | We believe that this is outside the scope of the P&C | 368
 |  | Confederation of Indigenous Peoples of Bolivia | 369 | En la confederación [NAME] hemos analizado los principios y criterios [NAME] enviados y concluimos, basado en nuestra experiencia, que es importante incluir el siguiente principio y los cirterios que van continuación: [NAME] : Gobernanza Forestal  Mejorar los sistemas de regulación y [NAME] legislación vigente de los países con participación social para el control  Criterio 1.- Promover y mejorar la participación de las organizaciones productivas forestales en el control social  [NAME] Las estructuras publicas nacionales garantizan la aplicación [NAME] normativa  [NAME] bosques por la falta de control, de los bosques haciendo que esta sea una actividad prioritaria para  REDD+                                                                                                                                                                                     Google Translate:  The Confederation of Indigenous Peoples of Bolivia have discussed the principles and criteria for UN REDD sent and conclude, based on our experience, it is important to include the following principle and the factors to go below: Principle: Improving Forest Governance systems for regulating and implementing the legislation of the countries with social participation for the control Criterion 1 .- To promote and enhance the participation of forestry production organizations in the social control Criterion 2 .- The national public structures ensuring the transparent application of the rules Criterion 3 .- minimize degradation of forests by the lack of control, making this forest a priority for REDD + | * Principle one covers governance systems, encompassing forest governance as it relates to REDD+ *Forest production organizations would be regarded among the relevant stakeholders and we feel there is no need to create a specific criteria for this one stakeholder group, noting the revised criterion 4 covers that issue *Transparency is covered in criterion 3 *Law enforcement is covered in criteria 5 and 6 | 369
 |  | Indian Law Resource Center | 370 | We recommend an entire principle on respect for indigenous peoples’ permanent sovereignty over natural resources (PSNR).  This concept encompasses the right of indigenous peoples to exercise self-determination and self-government, and to own, control and manage their lands, territories and natural resources.   Principle 3 – Respect of Indigenous Peoples’ Permanent Sovereignty over Natural Resources Criterion 8 – Respect for indigenous peoples’ self-government rights and right to self-determination Criterion 9 – Respect the rights of indigenous peoples to full ownership over their lands, territories and natural resources Criterion 10 – Ensure equitable benefit-sharing with indigenous peoples when using or selling their natural resources Criterion 11 – Indigenous peoples shall not be relocated without their free, prior and informed consent Criterion 12 – Respect for the rights of indigenous peoples to access their sacred sites in private Criterion 13 – No project supported by UN-REDD shall alter the land tenure systems of indigenous peoples nor shall it regulate the customary use of natural resources by indigenous peoples on the lands and territories that they may own, possess, or use without the affected community’s free, prior and informed consent Criterion 14 – Projects affecting indigenous peoples in voluntary isolation shall not be supported   [For detailed text explaining rationale for Principle 3 and each criterion , please refer to original comments document submitted by the Indian Law Resource Center] | We are guided by UN human rights standards which are based on international law, and as such we support the adherence to principles and norms laid out in key international instruments. The main one pertaining to IP rights is the UNDRIP; this has no reference to PSNR, therefore we have no mandate to promote this concept in the context of the UN-REDD Programme. Many of the specific criterion that are elaborated in this suggestion are very important and included in the UN-REDD Programme Guidelines on FPIC which informs the development of the RIMT; therefore they are go beyond the level of detail of the SEPC, but are contained within other programmatic guidance. | 370
 |  | International Development Law Organisation (IDLO) | 371 | Principle X - IDLO would recommend considering the addition of a further Principle on “respect existing legal, traditional and customary land tenure rights”. Criteria of promoting the clarification of those rights without compromising customary ownership or possession should be added (see III.C.72) Alternatively, this could be incorporated as criteria under Principle 1 and 2. | Please see additional criterion on land tenure and carbon rights under Principle 2 | 371
Glossary |  | Ecuador | 372 | The definition of ‘Full and effective (stakeholder) participation’ is the same as for ‘Relevant stakeholder’, which does not seem appropriate. The definition ‘full and effective participation’ should be more precise and could draw from the one used by the REDD+ SES: ‘Full and effective participation means meaningful influence of all relevant stakeholder groups who want to be involved throughout the process, and includes consultations and free, prior and informed consent’. | Agreed, and glossary entry revised | 372
 |  | Japan | 373 | Some languages in glossary are not used in proposed principles and criteria.  So the following languages should be modified or deleted; “displacement of land use change”, “fiduciary and fund management risks”, “indirect land use change”, and “natural ecosystems”, | Thank you, addressed in glossary and in hyperlinks from text. | 373
 |  |  | 374 | “Conversion” is so confusing.  This definition does not specify the meaning, so it should be deleted or explained in more detail. | Changed glossary entry to address 'conversion of natural forest' | 374
 |  | Expert reviewer | 375 | [Define law enforcement and oversight bodies in Criterion 1 in glossary] For the glossary: The Dept. of Justice/Public Ministry/Prosecutor’s office (however defined in each country), particularly any environmental crime unit or money laundering unit; the army to the extent that it is involved in deforestation/forest protection activities; government ombudsman, entities charged with defending citizens’ rights, Controller (court of auditors) charged with oversight on government spending/activities; etc. It could also include Customs, police, etc. depending on the dynamic in country [track changes] | Thank you, we will take this into account to update the glossary | 375
 |  | Expert reviewer | 376 | I suggest that a definition of ‘participation’ be added (one that emphasizes a solid, proactive involvement of local people in decision-making about their lives and environments) in the glossary. | "Full and effective participation" definition included in Glossary | 376
 |  | Expert reviewer | 377 | Transfer and translate key references into the context section | Included Annex 3: Sources Consulted | 377
 |  | Facilitated consultation - Nigeria | 378 | [Comment regarding definition of "indigenous peoples"] It is important to note that “indigenous people” is not a relevant term in Nigeria (and other places), and it would be helpful if the glossary entry reflected this | Noted. We use terms such as "other forest dependent communities in the P&C as well as in our Operational Guidance | 378
 |  |  | 379 | [Comment regarding definition of "most vulnerable and marginalized groups" ] Expand to explicitly include women, youth and the disabled | Now included in glossary entry | 379
 |  | Indian Law Resource Center | 380 | [Comment regarding draft UN-REDD Programme Guidelines for Seeking the Free, Prior, and Informed Consent of Indigenous Peoples and other Forest Dependent Communities referenced in glossary under "Free, Prior, and Informed Consent (FPIC)] We note that this document is incomplete because of its reference to the draft UN-REDD Guidelines for Seeking the Free, Prior and Informed Consent of Indigenous Peoples and other Forest Dependent Communities (Guidelines), which is not yet available.  As the process of FPIC is critical to many aspects of the principles and criteria, UN-REDD should provide for a series of public consultations for the Guidelines and all the policy documents that refer to the Guidelines once they have been made available to the public. | The draft FPIC guidelines are being prepared for public comment at the latest in November 2011 | 380
 |  |  | 381 | [Comment regarding "full and effective (stakeholder) participation" definition] 2. On full and effective (stakeholder) participation, we recommend that UN-REDD adds language promoting projects implemented by indigenous peoples themselves, such as: “With respect to those projects occurring on the land, territories of indigenous peoples or affecting their natural resources, countries should promote the implementation by the affected indigenous community itself wherever possible.”  Empowering indigenous communities to control and manage REDD+ projects not only meaningfully promotes the principles of benefit-sharing and self-government rights, but it may also prove extremely effective in meeting the overall goals of REDD+.     See, e.g. The Katoomba Group, Baker & McKenzie Legal Analysis – Surui REDD Project (2009), http://www.katoombagroup.org/events/baker_mckenzie.pdf. | For further discussion and consideration | 381
 |  | Expert reviewer | 382 | [Comment regarding "democratic governance" definition] The working definition of good governance developed through a consultative process led by FAO, WB, Chatham House and UN-REDD (see p.10 in http://www.fao.org/climatechange/27526-0cc61ecc084048c7a9425f64942df70a8.pdf  and p. 4-5 in http://www.unredd.net/index.php?option=com_docman&task=doc_download&gid=5336&Itemid=53 ) would offer more clarity and accessibility than this definition. You may want to consider using it. | The entry for "Democratic governance" has been revised in the glossary. The P&C are consistent with the operational description of REDD+ governance using 3 pillars and 6 principles developed in the draft Guidance. | 382
 |  |  | 383 | [Comment regarding the four principles of democratic governance, in "democratic governance" definition] This list is confusing because of its omission of key governance principles. Why not refer to ALL the principles of good/democratic governance? The “core principles of DG  [are] participation, transparency, effectiveness and efficiency, responsiveness, accountability, consensus, equity and inclusiveness, and the rule of law” (A Guide to UNDP Democratic Governance Practice, p.65). | Agreed. The entry in the glossary has been revised. Note that there is no exhaustive list of principles of democratic governance. | 383
 |  |  | 384 | [Comment regarding "forest" definition] The definition of forests should be the one in FRA 2010, but what is presented here is incomplete and wrong. The correct definition is: “Land spanning more than 0.5 hectares with trees higher than 5 meters and a canopy cover of more than 10 percent, or trees able to reach these thresholds in situ. It does not include land that is predominantly under agricultural or urban land use.” | Updated glossary entry | 384
 |  |  | 385 | [Comment regarding "indirect land use change" definition] I suggest deleting. This is identical with the definition of “displacement”. | Retain ILUC as glossary entry as used in new version of Criterion 16, but amend to indicate 'as displacement' | 385
 |  |  | 386 | [Comment regarding "land use change" definition] Is “management” really part of the definition. [Suggests inserting "and":] ...may thus have an impact on climate, locally and/or globally" | We feel management is an appropriate part of the definition. We have removed reference to climate as not necessary to land use change definition. | 386
 |  |  | 387 | [Comment regarding "secure" in "most vulnerable and marginalized groups" definition] Is this different from “sustainable livelihoods”? | Agreed that sustainable implies "secure", which we kept for emphasis: | 387
 |  |  | 388 | [Comment regarding "native" in "natural forest" definition] Same as “indigenous”, which is the terms used earlier. | Changed to 'indigenous' throughout | 388
 |  |  | 389 | [Comment regarding "relevant stakeholders" definition] How about NGOs or CBOs? What is the difference between “informal forest user” and forest dependent communities. Also, REDD+ activities may affect stakeholders that have no interest in forests, e.g. mining companies. Are they covered in the definition. Civil society should be mentioned too. | Agreed. NGOs and CBOs are now encompassed in the general term "civil society" . The definition also includes "and those that will be affected either negatively or positively by REDD+ activities". | 389
 |  | Conservation International (CI) | 390 | Definition of Degradation should read:  Human-induced reduction in forest carbon stocks in natural forests “remaining forests,” generally accompanied by reduction in the capacity of a forest to provide goods and services. | There are various definitions for degradation - see "Definitional issues related to reducing emissions from deforestation in developing countries". Have incorporated points about 'human-induced' and ''remaining forests', but dispute that only natural forests can be degraded in terms of their services | 390
 |  | CBD LAC Regional Consultation on REDD+ and biodiversity safeguards (Working Group 1) | 391 | The participants recognized the need to get a definition for forest for REDD-plus. | Our understanding is that national forest definitions are likely to be employed | 391
Annex 1 |  | Facilitated consultation - Viet Nam | 392 | Participants felt that the two columns were presented in the wrong order. The right column should be on the left side, and the left column on the right. The principles are basically a responds to the safeguards in the Cancun Agreements. The current table makes one believe that the Principles were developed first and then relevant section were included in the Agreements. | Added text to caption "The proposed Principles were developed from the Cancun safeguards, and typically each responds to more than one safeguard. The Principles may not comprehensively cover the issues raised by the safeguards". Presenting in the order originally used makes it easier to see which part bit of the [NAME] text the principles respond to. | 392
 |  | Expert reviewer | 393 | This annex is misleading as it suggests that principles cover the full array of issues included in each safeguards. It seems important to state that this is not the case, probably as a sub-title. | Please refer to response to comment  392 | 393