Spreadsheet: 1955db23-81ae-496e-998f-0b6334c2cfa9
Sheet: Sheet1

Principle/Criterion (in version 3, September 2011) | Text (in version 3, September 2011) | Comment provider | # | Comment | Drafting team response
General |  | [NAME], World Health Organization | 1 | Suggest including health co-benefits of climate change mitigation - which are quantifiable and well defined by the WHO's work: see  HEALTH IN THE GREEN ECONOMY initiative: http://www.who.int/hia/green_economy/en/index.html For more information you are welcome to contact us. | Thank you - we will consider including this in the next version of BeRT rather than adding to the Criteria.
 |  | [NAME]Project Co-ordinator Timberwatch Coalition | 2 | This process will do nothing to improve the situation on the ground, because as in the ineffective way FSC certification principles and criteria are applied to forests (and to plantations), there will be little resemblance between 'nice theory' and 'harsh reality' when it comes to making the system work. What is also implicit is that while there may be intensified efforts to demonstrate that social and environmental principles are being applied in REDD+ project areas, communities and their land in all other forest and grassland areas will be at increased risk of ruthless exploitation. The core problem of unsustainable growth in demand for consumer products derived from forests or from plantations needs urgent attention, yet as with the rapidly increasing global population, there is very little political will to find solutions to this single greatest cause of deforestation.   REDD+ will be little more than a rubberstamp for allowing increased corporate control over and access to community-owned natural resources. As for "substantial benefits beyond carbon" the only likely benefits of REDD+ will be the money earned by consultants and commodity traders! | The intention is for the SEPC and their application to help limit adverse impacts of REDD+ readiness activities under the UN-REDD Programme, and enhance benefits for a range of stakeholders.  The SEPC attempt to address the problem of displaced pressures through criterion 20 and Principle 7 and its associated criteria. There is little that the UN-REDD Programme can do to address the wider problems of unsustainable consumption.
 |  | GIZ | 3 | The Social and Environmental Principles and Criteria give a framework for what safeguards must be addressed and what elements these safeguards contain. It builds up on important work that has been done by FAO, under UNFCCC and other UN conventions. However, the SEPC does not provide indicators to steer the implementation and monitor the impact. It serves as a framework, not as an operational guidance and might therefore not fulfill it's proposed purpose. If the announced Risk Identification & Mitigation Tool can complement the framework in this issue remains to be seen. | We are indeed proposing that SEPC forms a guiding framework on social and environmental risks and benefits. On application and relationships with other initiatives, please see the companion document submitted to Policy Board in March 2012. We hope that the RIMT (now BeRT) is welcomed by GIZ.
 |  |  | 4 | A distinction must be made between the impact levels. Some of the criteria apply to field activities only (i.e. criteria 18 and 19), others influence the national REDD+ design. Generally, the expectation towards the impacts of UN-REDD Programmes on the overall national REDD+ Programmes or Strategies seems overrated, which will make it difficult to see the criteria fulfilled. Integrating criteria that allow country ownership and flexbility towards national circumstances would be important. | The SEPC are being proposed as a guiding framework for the UN-REDD Programme to address two specific needs: 1) Addressing social and environmental issues in UN-REDD National Programmes and other UN-REDD funded activities. 2) Supporting countries in developing their national approaches to REDD+ safeguards in line with the UNFCCC.  Its influence extends primarily to the UN-REDD programme, but we would hope to support countries in developing safeguards that apply across their REDD+ activities.  (As an aside, we do feel that Criteria 18 and 19 should influence the choice of activities promoted by the national Programme.)
 |  |  | 5 | [On the principles:] The various principles and criteria should be harmonized stronger with National Forest Programme principles (http://www.fao.org/docrep/009/a0970e/a0970e03.htm). The application of those should enhance the efficiency and effectiveness of national planning and implementation of forestry activities and contribute significantly to the achievement of sustainable forestry development. | REDD+ activities should be included in the  nfp process, and the SEPC should be complementary, but not necessarily identical to nfp principles.  The SEPC mostly do deal with same issues covered by nfps. [NAME] links closely to [NAME], but also includes elements of Principle 6 (multiple functions).  The other clusters link closely to principles 1 and 2.  (Nfp is a process-oriented planning framework for the forest sector.  Its principles include "cluster 1: sovereignty & country leadership; cluster 2: consistency with and integration beyond the forest sector; cluster 3: Participation and partnership". )
 |  |  | 6 | UN-REDD Programme should consider whether a new "Risk Identification and Mitigation Tool" is needed or if either the SESA or REDD SES frameworks provide enough monitoring capacity to officially adopt them | A process to apply the BeRT (originally RIMT) does need to be developed. SESA frameworks focus on process rather than content, so may be complementary to BeRT. REDD+ SES frameworks are valuable but lack detail on the environmental risks and benefits. Complementarities are being explored in individual countries, but there is scope for more.
 |  | WWF | 7 | At UNFCCC COP 17 in Durban it was agreed that it is entirely in the hands of countries (according to national circumstances and national sovereignty) to address and to provide information on socio-environmental safeguards. Thus, solid guidance on socio-environmental aspects is key that REDD+ can deliver at scale to benefit the climate, people and nature. WWF believes that for the long-term credibility of REDD+ it is  pivotal that REDD+ is following strong socio-environmental principles. This was also expressed by many statements of current and potential REDD+ donors in Durban who made it clear that strong socio-environmental performance is not a "burden" but more a "pre-condition" for sustainable investment in REDD+. WWF believes that the draft P&C improved significantly and the 3rd version is generally a fairly strong set of P&C, however, some more specificity would improve certain criteria. Of particular importance is how these P&C will be operationalized and translated into performance. In this regard the UN-REDD P&C can benefit from other instruments such as the REDD+ SES and the FSC. | Thank you for your comment that the SEPC have improved in their revision!  On application, please see the companion document submitted to Policy Board in March 2012.
 |  | [NAME], FCPF | 8 | We find this third version of the P&C to be more comprehensive than before, as well as generally clearly articulated. | Thank you.
 |  |  | 9 | Our main concern now is seeing how these P&C might come to be operationalized through application of the Risk Identification and Mitigation Tool (RIMT). | Respondent notified when BeRT released for review.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 10 | As project-level activities start to be developed, such as for example CDM clean cook stove projects, VCS REDD projects, Gold Standard efficient and clean water filtration projects, project areas will start to overlap, raising questions about double counting of emission reductions. How is ownership regulated if a cook stove PoA and a REDD programme are implemented in the same community? | This issue is beyond the scope of the SEPC, which are not at present trying to address project scale accounting of emissions reductions. See also comment 3 on purpose.
 |  |  | 11 | How do the country-level SES criteria relate to a possible subsequent application on the project level? We understand that several of the criteria, and of the questions related to the criteria found in the work tool, can be important for the further improvement of existing standards and methodologies such as the CCBS. In this regard it is important to highlight that currently the SES do not conform to a set of auditable, specific requirements, and can therefore not be validated in a process similar to current DOE audits. Therefore, if the SES are to be applied at project or regional level, it might be necessary to develop specific criteria, to avoid a situation similar to that which emerged for large-scale CDM Hydroelectric projects. There, validation against the World Commission on Dams (WCD) report guidance required obtaining certain buyer-country LoAs. Yet the WCD did not provide the specific criteria needed, leaving validation to a large extent at the discretion of the auditors. Likewise, the Montreal Process criteria and indicators for sustainable forest management have been criticised for failing to provide objective performance standards. | See comment 3.
 |  |  | 12 | Permanence is of key importance for REDD programs to achieve permanent emission reductions. At the operational level, besides sound project and activities design, it might be required to allow for a project buffer or insurance solution such as is provided for at the project level under the VCS. Currently such solutions are not part of the UN REDD SES. | The SEPC do not currently address the operational level or project scale.  Reversals are addressed in criterion 16. We will consider linking more closely to VCS resources on this issue from subsequent versions of BeRT.
 |  |  | 13 | By the same token, it might be insufficient to call for fair and equitable benefit-sharing arrangements while leaving the definition of benefits and sharing open to interpretation. If conflict over resource allocation is to be avoided, benefit-sharing arrangements must be developed early in the life of REDD+ projects, well in advance of payments. Specific criteria and indicators for benefit-sharing could be articulated, and best practices for benefit-sharing should be identified and disseminated through peer-to-peer learning networks, taking into account the perspectives of all stakeholders. | The glossary has given more of a definition of benefits in REDD+. Approaches to designing BDS mechanisms for REDD+ will be included in further guidance - the BeRT already provides some insights which will be developed in further revisions of the BeRT.
 |  |  | 14 | Principle 15 of the Rio Declaration - which stipulates that, where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation - should be applied to the REDD+ approach. Similar logic should extend to social impacts. Regulation tends to overlook cumulative, synergistic, and indirect effects; the limitations of knowledge must be acknowledged and addressed through more interdisciplinary, evidence-based and participatory appraisals that can provide early warning of unintended consequences. Such appraisals should be independent of the prevailing economic and political interests.1                                                                                                                                                                  1 Harremoës et al, 2001 Late Lessons from Early Warnings: the precautionary principle 1896-2000 Environmental Issue Report No 22, European Environment Agency, Copenhagen | This point has been noted. The requirements for accountability and transparency in the SEPC highlight the need for independence. We feel that the SEPC applies a precautionary approach to the social impacts of REDD+.
 |  |  | 15 | The following Principles inform IFCA’s mission to catalyse significant and sustainable demand for forest carbon assets that meet credible, independent performance standards. It is these Principles that have also informed the consultation responses outlined above.  [NAME] and restore forests, in order to contribute to mitigation of climate change, enhance biodiversity and ecosystem services, balanced with the need to ensure food security and provide economic opportunities for women, Indigenous peoples and local stakeholders. [NAME] for transparent, equitable, accessible, efficient and secure market mechanisms to provide a well-functioning global forest carbon market.  • Ensure real, measurable, verifiable and additional carbon assets are generated; promote their insurability and securability; and support “fair value” transactions for all counterparties and stakeholders, to achieve investor preference. • Engage all carbon market stakeholders - non-government organizations, standards bodies, certification and audit bodies, indigenous and forest communities, landowners, governments and multilateral bodies - to drive greater efficiencies in, and eliminate barriers to, forest carbon activity. • Develop a robust financial framework for private and civil-society project development to maximize capital investment in sustainable forest carbon activity. • Support forest carbon project developers with information and intelligence needed for optimal, ethical decision making and striving to improve business proficiency in the sector. | Noted
 |  |  | 16 | Cannot find a section on accounting principles between national REDD programs that produced tons of CO2, versus other, non-REDD activities such as improved cookstove projects. Double counting and carbon ownership might become an issue. | See comment 3.
 |  | [NAME], RECOFTC | 17 | Thank you for giving us the opportunity to review and comment on the draft UN-REDD Social and Environmental Principles and Criteria. We found the principles and criteria to be well written and comprehensive in scope. | Thank you
 |  | EarthChild Institute | 18 | Today’s children have an important role to play in the planet’s future. Educating them on the environment and sustainable practices is one of the best investments we can make to ensure a healthy planet for coming generations. | Noted
 |  | Government of Sudan | 19 | The SEPC tool is very  usful to be used as safeguards, but it should  consider  the developing countries different circumistances, needs and interests, depending on the diffrerent interst of stakeholders and actors, there is high need to nationlise the [NAME] accordingly. | National interpretation will certainly be necessary, especially in using the BeRT, but the SEPC should serve as an overarching guiding framework - including for the development of national safeguards.
 |  | Instituto de Pesquisa Ambiental da Amazônia (IPAM) | 20 | On the document of the SEPC itself we are proud to see the definitions about important words and expressions presented in the document, as well as a clear indication on the use of SEPC into the National Joint Programmes. The only thing that we still miss in the document is the establishment or any references to the provision of mechanisms to address grievances and monitor compliance with standards, as well as due diligence, which we think are  essential elements for stakeholders to be assured that they are able to voice their complaints and have those address in case they do not agree by something said by the Government. | The SEPC is being proposed as a guiding framework, which guides and informs UN-REDD actors in addressing social and environmental considerations in REDD+. Criterion 2 addressess responsive feedback and grievance mechanisms.
 |  |  | 21 | Besides, the only other remark we will would like to raise is about the necessity to promote a broad consultation of the SEPC using other sources than internet, since many Indigenous Peoples and Local Community leaders do not validate a process of commenting a certain document when it is done exclusively through internet, since many leaders have problems to access internet and use computer tools in general. In this sense we still feel the need for UN-REDD to promote workshops in which people can interact and discuss in deep SEPC in order to validate it. | On 8-9 February, the UN-REDD Programme held a workshop in Geneva to build on results of this most recent consultation on the SEPC.  The participants included CSO and [NAME] representatives. Some individual in-country consultations involving IPs have also have contributed to this review.
 |  | Conservation International | 22 | Conservation International is pleased to provide these comments on UN-REDD’s draft Social and Environmental Principles and Criteria (SEPC) and Benefit and Risks Tool (BeRT). REDD+ will not be able to succeed in meeting its goal to slow, halt and reverse forest cover loss and emissions if it is not also able to achieve social and environmental goals. In December 2010 the UNFCCC agreed to REDD+ safeguards, and in December 2011 the UNFCCC provided guidelines for the development of safeguard information systems. All REDD+ efforts, therefore, must respect this high-level guidance from the UNFCCC. More work needs to be done, however, as countries operationalize UNFCCC guidance to ensure that the REDD+ safeguards are addressed and respected throughout REDD+ implementation. Such work should build off of existing tools to the extent that such tools are sufficient to promote our ability to achieve climate, social, environmental and governance goals. Synergies should also be achieved wherever possible in order to streamline processes, while also promoting best practices rather than reducing guidance and standards to the lowest common denominator. | On application and relationships with other initiatives, please see the companion document submitted to Policy Board in March 2012.
 |  |  | 23 | In regards to the SEPC, please refer to the comments Conservation International (CI) provided in August of 2011. Many of these comments are still pertinent. In particular, CI still feels that these principles and criteria do not provide the level of guidance necessary to support countries as they implement REDD+ safeguards. While the BeRT, if sufficiently revised (please see comments below), may contribute to the achievement of the SEPC’s first objective, aiding countries in formulating national REDD+ programmes and initiatives that seek UN-REDD support, it is not clear how the other two objectives will be achieved. Additional guidance will be needed if these objectives are to be achieved. That guidance should clarify what the UN-REDD requirements are and, ideally, provide support to countries as they implement the safeguards and develop their safeguard information systems. Fortunately, some work has already been done in this area. CI would like to recommend the REDD+ Social and Environmental Standards (REDD+ SES) as a tool that already exists, that was developed through a participatory and inclusive process, and was specifically designed as a framework for multi-stakeholder assessment of REDD+ program design, implementation and outcomes.  CI suggests that UN-REDD consider adopting the REDD+ SES as a tool for ongoing monitoring rather than developing new guidelines for this purpose. Since the SEPC does not currently contain the guidance necessary to achieve all of its goals, we recommend that UN-REDD articulate the process it will use to provide the operational guidelines, policy and procedures that are necessary for countries to implement the principles and criteria contained in the SEPC. | See comment 22 on application and relationships with other initiatives
 |  | Center for International Environmental Law (CIEL) | 24 | Overall, we find the SEPC generally cover key subjects related to assessing social and environmental impacts for REDD-related activities.  At the same time, it is unclear how UN-REDD intends to apply the SEPC and BeRT to the various UN agencies and country programmes undertaking activities supported by UN-REDD. Specifically, it is unclear whether these serve as guidance or if instead they are part of due diligence requirements.  In other words, if the SEPC is violated or if the BeRT indicates significant adverse impacts, will there be any repercussions, including possible funding implications?   While we can offer some feedback on the current draft without knowing this information, the most useful feedback would need to know the purpose of the document in order to ensure that the criteria and principles are tailored to fit their intended purpose.   With these points in mind, we would like to offer the following suggestions: | On application and relationships with other initiatives, please see the companion document submitted to Policy Board in March 2012.
 |  |  | 25 | Clarify the process to ensure rights are respected.  The questions asked in the BeRT would theoretically hold the criteria to a high level of human rights protections.  At the same time, the SEPC primarily references guidelines, as opposed to the obligations themselves.  The SEPC/BERT should clarify the underlying rights obligations--see, e.g., CIEL's list of select international obligations at http://www.ciel.org/Publications/REDD/REDD_intl_obligations_Nov11.pdf  (available at CIEL’s REDD webpage, which could be listed as a reference: http://www.ciel.org/Climate_Change/Forests.html ).  The SEPC/BERT should also clarify expectations of UN agencies and countries in ensuring international obligations are respected. | Some of the obligations are listed in the introduction to the SEPC. Detailed obligations can be referenced in  further guidance on specific  criteria.
 |  | Rainforest Foundation Norway | 26 | The RFN welcomes the content of the SEPC. Obviously a lot of work has gone into making a very good and comprehensive tool. Our  only consern is that it has become very elaborate and will require large amounts of work and resources to provide the requested information. If consultants are used it will also be costly. We also wonder in what way and to what degree local knowledge will be respected and local experts will be given an opportunity to contribute in information gathering. | Thank you. In the first instance, the BeRT has been developed to apply the SEPC in the formulation of National Programmes and initiatives seeking UN-REDD Programme support. It is intended for use by national teams to identify and assess potential risks and opportunities from such programmes and to document this assessment process for internal use, and can help them to identify ways of adjusting programme design to minimize risks and build on opportunities.  In future, the BeRT will be tailored to support application of the SEPC in other contexts, including programme implementation, monitoring and evaluation.  We will be testing the application of the BeRT and improving the design accordingly.
 |  |  | 27 | The list of international instruments should include the International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and Political Rights | We have now added 'inter alia' to the table text to indicate that the list of agreements is not intended to be exhaustive.
 |  | The Royal Botanic Gardens, Kew | 28 | [Introductory text on [NAME], its mission, work with international partners and activities in forest science can be found in submitted feedback form.] [NAME] is not formally part of the REDD+ process, nor the UN-REDD programme. [NAME] welcomes the invitation to comment on the implementation of the environmental principles and criteria of the UN-REDD programme, in particular in relation to the conservation and management of biodiversity and related ecosystem services. [NAME] congratulates the UN-REDD programme on these comprehensive and robust Social and Environmental Principles and Criteria (SEPC). [NAME] finds that the SEPC are high level, and as such and could present problems for implementation at ground level. In particular, ensuring that all principles and criteria are met in one project may be difficult. If Programme funding is not dependant on the full implementation of the SEPCs, the SEPCs could be presented as best practice guidance, with further guidance developed to assist ground level implementation. Such additional guidance could also account for national biodiversity management and conservation priorities. It may be helpful to see the UN-REDD Risks and Mitigation strategy, which may address this concern. | Thank you. See comment 7 on application
 |  | Global Witness | 29 | We appreciate the responsiveness UN-REDD has shown to input from Policy Board members and other stakeholders and the hard work put into revising the SEPC. They are substantially improved from previous versions as a result of these efforts, and we support the intention of elaborating a functional set of REDD+ safeguards. We look forward to working with you to further refine the SEPC based on the latest round of comments. We are disappointed, however, to see that the tool to operationalize the SEPC, now referred to as the BeRT, is only intended to serve as guidance in the formulation of national REDD+ programmes. This applies to only one of the three stated objectives of the SEPC. At the 7th Policy Board meeting, we asked for clarification about how the SEPC would be operationalized with regards to the three objectives described in the latest draft of the SEPC. We were assured that the BeRT would make this clear. We now find that the BeRT applies only to the first objective of the SEPC, so the question of how the SEPC will be operationalized to accomplish its other two objectives remains unanswered. We are also concerned that a significant amount of time and effort have gone into a tool that, while potentially useful, apparently will not apply to the existing national programmes in 14 partner countries. | Thank you. See comment 7 on application. The point on application for existing UN-REDD countries is well taken. Whilst the BeRT in its current form may still be useful in reviewing existing national programme documents and strategies in order to identify risks and mitigation actions, future versions will be tailored to support application of the SEPC in other contexts, including programme implementation, monitoring and evaluation.
 |  | WRI | 30 | 1. We welcome this opportunity to comment on the latest draft of the UN-REDD Social and Environmental Principles and Criteria (SEPC) and Benefits and Risks Tool (BeRT). The current draft SEPC document is an improvement over previous drafts. Specifically, the principles and criteria included in the SEPC are more thorough in this version, and cover vital topics like involuntary displacement and land tenure in somewhat more detail. Similarly, the BeRT highlightings the many substantive areas that may present social or environmental risks, including important issues related to transparent and participatory governance. However, questions remain regarding the intended use of these two documents, the methods through which they are meant to be implemented, and the relationship between them. 2. We have chosen to focus our comments less on the individual principles, criteria and questions that make up the substantive portion of these two documents, and more on our remaining concerns around how these documents are to be used. We do so in part because of the relatively thorough nature of the two tools in terms of coverage of substantial issues, and in part because we find it is difficult to comment thoroughly on the more detailed elements of the two documents, and especially the BeRT without entirely understanding their intended use. | See comment 22 on application and relationships with other initiatives.
 |  | Forest Peoples Programme | 31 | the general content of the SEPC has substantially improved and FPP welcomes the efforts of UNREDD to take into account the concerns expressed in the past. | Thank you!
 |  |  | 32 | We have focussed our analysis and attention on the sections that are relevant to indigenous peoples and indigenous peoples’ rights.  In general terms both the BeRT and the SEPC drafts show significant improvements in terms of content and we commend UNREDD for having taken into due account our and other CSO’s recommendations to provide both drafts together to facilitate a cross-analysis and a more consistent contribution. We also commend UNREDD for having accepted to convene a final seminar-consultation with relevant stakeholders and rightsholders, prior to the finalization of the documents.  Nevertheless, in our thorough analysis of both documents we found some discrepancy between improved text and apparent lack of clear guidance on how these will be made operational. In particular, the SEPC, as it stand now seems to be apt to fulfill only one of the three stated goals, notably to assist in the preparation of the National REDD Plan. In order to fulfill the other two goals, namely to assess National Programme Delivery and review National Programmes prior to submission to the Policy Board of the UNREDD, appropriate procedures will have to be put in place. | The SEPC potentially addresses all 3 stated goals; BeRT version 1 is confined to programme development. Please see comment 29  on countries with existing programmes
 |  |  | 33 | As regards both the BeRT and the SEPC, we note the lack of clarity on  how these will be operationalised in particular in the formulation of the Readiness Preparation Plan (RPP) in the cases when UNREDD and FCPF operate in the same country and use the harmonized template. As a matter of fact, the most recent version of the RPP Template does not contain any indication on how these will be taken into account in the Readiness Phase.  Thanking you for your attention we wish a positive discussion and outcome at the Geneva workshop and send you our best regards | See comment 22 on application: the companion document addresses the relationship with FCPF processes.
 |  | Republic of the Congo | 34 | les  Principes et critères de l’UN-REDD doivent servir  de mesures de sauvegardes environnementales et sociales  REDD  et les structures de mise en œuvre doivent être les différentes coordinations REDD+ des pays dans lesquels les processus sont  déjà lancés avec un niveau d’exécution très avancé. - Il faut peut être décliné les indicateurs environnementaux et sociaux, [NAME] objectivement vérifiables à partir des vérificateurs-pays pour chaque critère/indicateur ; Google Translate translation:  - Principles and Criteria of the UN-REDD should be used as measures of environmental and social safeguards and structures of REDD implementation must be different coordinations REDD + countries in which the processes are already underway with a great level of implementation advanced. - It must be declined the environmental and social indicators, which will be based on objectively verifiable audit country for each criterion / indicator; | See comment 29 on countries with existing programmes
 |  |  | 35 | Dans le cas des pays pilotes REDD, [NAME] avoir les PCIV qui [NAME] (cas de la RDC qui a testé ses PC) Google Translate translation: - In the case of REDD pilot countries, it would have to be tested the CPIP (DRC case that tested his PC) | National testing of SEPC and BeRT is most welcome and UN-REDD seeks to support countries in undertaking this.
 |  |  | 36 | Quels sont les mécanismes de suivi prévus ? [NAME]  met en difficulté  pour affirmer ou donner un avis pertinent  pour les spécificités liées au milieu tropical ou en voie de développement  comme cela  est le cas  du Congo où les statistiques nationales ne sont pas régulièrement disponible ; Google Translate translation: - What are the monitoring mechanisms? This causes problems to assert or give notice relevant to the specific characteristics in tropical and developing as is the case of Congo, where national statistics are not regularly available; | See comment 23 on the application of SEPC. The SEPC itself is not a standard that requires monitoring, but may be used to support develop of national safeguards that would be reported on.  BeRT v1 provides some indication of key information needs, but is not comprehensive on monitoring.
 |  |  | 37 | SUGGESTIONS : -décliner chaque critère en plusieurs  sous critères ou indicateurs en veillant a ce que chaque pays décline des vérificateurs pour chaque indicateur et ce en fonction des  [NAME] pays ; -D’où la nécessité de prévoir  des tests  dans chaque pays à  l’image de ce qui s’est fait à Kinshasa (tester les sauvegardes  dans la logique des principes et critères) -Ces critères présentent tellement de détails qu’ils offrent la possibilité de les décliner en sous critères ou indicateurs  -Il est toutefois possible, en suivant les orientations [NAME] dans les systèmes MRV, un volet sur le suivi de la prise en compte des PCIV sur le volet social et environnemental. Google Translate translation: - Decline each criterion into several criteria or indicators, ensuring that each country accepts the auditors for each indicator and this based on the realities of each country; - Hence the need for testing in each country in the image of what has been done in Kinshasa (test backups in the logic of the principles and criteria) - These criteria are so many details that they offer the possibility of decline in under criteria or indicators - It is possible, under the guidance of [NAME] provide in MRV systems, a section on monitoring the inclusion of CPIP on the social and environmental. | See comment 19
 |  | [NAME], ClientEarth | 38 | ClientEarth is very supportive of the UN REDD programme and its work on developing these Social and Environmental Principles and Criteria. We appreciate the opportunity to contribute to this public comment period.   We believe these tools and guidance provide an excellent step towards enhancing the multiple benefits of, and reduce the risks of REDD+.  However, we strongly recommend the following comments/suggestions are taken into consideration in order to ensure that these tools and guidance can be effectively implemented in participating countries. | Thank you
 |  | Government of Norway | 39 | Norway has on several occasions commented on the Social and Environmental Principles and Criteria (SEPC) on a general level. The premises for these comments have not been changed substantially since previous rounds: although the status and function of the framework have become clearer in the later versions, this still needs to be further clarified. Norway would again also like to underline the importance of good coordination and integration with other relevant similar safeguard frameworks and processes at national level(s), e.g. with the FCPF (SESA/ESMF), the CCBA, etc. | See comment 22 on application and relationships with other initiatives
 |  | Indian Law Resource Center | 40 | The Indian Law Resource Center (Center) welcomes the opportunity given by the UNREDD Programme (UN-REDD) to comment on the development of policy related to the Reduction of Emissions from Deforestation and Forest Degradation (REDD) in developing countries. This paper, including the attached annex of line edits, entails the Center’s comments on the “Social and Environmental Principles and Criteria, version 3” (Principles and Criteria) and “Benefit and Risks Tool” (BeRT).1 2. Generally speaking, the Center is particularly interested in discussing the implications of REDD projects taking place in indigenous lands. Grassroots indigenous organizations from Mexico, Central and South America have made inquiries to us regarding REDD, because they are concerned that REDD programs and projects will affect their lands, natural resources and governing institutions. As a matter of both legal obligations and sound policy, UN-REDD policies must ensure respect for and protection of indigenous peoples’ human rights.  1 UN-REDD Programme Draft Social and Environmental Principles and Criteria and Benefits and Risks Tool. Available at http://www.unredd.org/Multiple_Benefits/SEPC_BeRT/tabid/991/Default.aspx | Please see the draft UN-REDD Programme Guidelines for seeking Free, Prior and Informed Consent for further information.
 |  |  | 41 | Comments by the Center on the previous consultation draft of the Principles and Criteria2 called for a principle and set of criteria specifically addressing the collective rights of indigenous peoples, including the following: • Indigenous peoples’ rights of self-determination and self government • Indigenous peoples’ rights to permanent sovereignty over their natural resources • Indigenous peoples full ownership rights to their lands, territories and resources • The rights of indigenous peoples to exist in voluntary isolation • The cultural rights of indigenous peoples, including to access their sacred sites in private Because these comments were not sufficiently incorporated in the present draft, we have provided here a more detailed description of the indigenous rights protections which must be included in UN-REDD policies, including the Principles and Criteria.  2 Indian Law Resource Center's Comments and Recommendations on the UN-REDD Programme "Social and Environmental Principles and Criteria, Draft for Consultations", August 2011. Available at http://www.indianlaw.org/sites/default/files/2011-08%20ILRC%20Comments%20on%20UN-REDD%20PC-1.pdf. | The UN Declaration on the Rights of Indigenous Peoples (UNDRIP) is highlighted in the introduction and [NAME] are specifically mentioned in Criterion 4, 7 and 9. Please see the draft UN-REDD Programme Guidelines for seeking Free, Prior and Informed Consent for further information.
 |  |  | 42 | For the Center’s position on other UN-REDD policies, see the Center’s comments on the “Draft Guidelines on Stakeholder Engagement in REDD Readiness, with a Focus on the Participation of Indigenous Peoples and Other Forest-Dependent Communities”3 (Stakeholders Engagement Guidelines) and the “Guidelines on Free, Prior and Informed Consent” (FPIC Guidelines).4  3 Indian Law Resource Center's Comments and Recommendations on the Forest Carbon Partnership Facility and UN-REDD Programme "Draft Guidelines on Stakeholder Engagement in REDD+ Readiness, with a Focus on the Participation of Indigenous Peoples and Other Forest-Dependent Communities", June 2011. Available at http://indianlaw.org/sites/default/files/2011-06%20FCPF%20UNREDD%20Guidelines%20Comments%20FINAL-1.pdf. 4 Indian Law Resource Center Comments on UN-REDD Programme Guidelines on Free, Prior and Informed Consent (FPIC), January 2012. Available at http://www.indianlaw.org/sites/default/files/2012-01-15%20ILRC%20FPIC%20Guidelines%20Comments%20ENG.pdf. | Noted
 |  |  | 43 | The Center is encouraged by the UN-REDD’s acknowledgment of the UN Statement of Common Understanding on Human Rights-Based Approaches to Development Cooperation and Programming (Common Understanding) and the obligation to adopt a human rights-based approach within its policies. Under the Common Understanding, the UN-REDD Programme is obligated to comply with international human rights agreements, including the UN Declaration on the Rights of Indigenous Peoples (UN Declaration).5 6. These human rights standards must serve as the benchmarks for any REDD programs and policies. This is both a matter of UN-REDD’s legal human rights responsibility as an agency of an intergovernmental organization; as well as a practical matter, as the only effective means of ensuring that the rights of indigenous peoples and other local communities are not violated due to REDD policies or projects. 7. Unfortunately, while the Principles and Criteria are intended to be “consistent with” and to “help countries meet their commitment to” internationally recognized human rights standards, they fail to do so. The Principles and Criteria will only be effective at deterring human rights violations in REDD projects if they are binding, concretely linked to specific human rights standards rather than more general impact statements, and provide for effective remedies. This is especially the case regarding the rights of indigenous peoples to their lands, territories and resources. 8. To remedy this serious shortcoming, the Principles and Criteria must: 1) operationalize a human rights-based approach; 2) track the substance of actual human rights standards; 3) address the unique collective rights of indigenous peoples; and 4) require compliance with human rights standards. 9. The Center believes that the above indicated issues are critical not only for the survival of indigenous peoples, but also for the effectiveness of UN-REDD supported projects when taking place in indigenous territories. We hope the concerns outlined in this paper are fully addressed at the upcoming UN-REDD Policy Board meeting, which is scheduled to take place on March 25– 26, 2012, and prior to any adoption of final policy documents.  5 The Human Rights Based Approach to Development Cooperation: Towards a Common Understanding Among UN Agencies. Available at http://www.undg.org/archive_docs/6959- The_Human_Rights_Based_Approach_to_Development_Cooperation_Towards_a_Common_Understanding_amon g_UN.pdf. | See comment 23 on application. In addition, we feel that the principles and criteria follow a human-rights based approach. This is highlighted by a number of criteria (e.g. criterion 7 and criterion 9). There have been revisions to some citeria to strengthen the rights-based approach, including to the lanuguage of criterion 7 and to reference effective remedies. Inclusion of references to other UN-REDD guidance, for example on FPIC, ensures coverage of many issues linked to the rights of indigenous peoples such as recognising collective rights. There is a process of clarification of the application of the SEPC underway which is being proposed to the Policy Board that describes the nature of the instrument and whether it is binding. Stakeholder rights, including human rights, statuary , customary and collective rights, are made reference to in Principle 2 and the UN  Declaration on the Rights of Indigenous Peoples (UNDRIP) is specifically mentioned in the introduction to the SEPC. The importance of responsive feedback and grievance mechanisms are further underlined in criterion 2. The UN-REDD Stakeholder Engagement team is looking into incorporating a means to assesss  and address human rights impacts, as per the recommendation from the FPIC Workshop, 10-11 February, Geneva.
Introduction and Context | Box on international agreements | GIZ | 44 | doesn't list the relevant UNFCCC decisions; e.g. [NAME]. Also doesn't mention UNFF and the PF/IFF Proposals for Action | We have now added 'inter alia' to the table text to indicate that the list of agreements is not intended to be exhaustive.
 |  |  | 45 | National Forest Programmes are mentioned in Principle No. 4, but no reference to the underlying nfp principles is made. It would be useful to refer to the nfp as policy process and its relevance to REDD+ and safeguards | see comment 5
 |  | EarthChild Institute | 46 | By 2025, children who are 18 years or younger today will represent more than half of the world’s workforce. A critical strategic opportunity exists to ‘insure’ the resiliency, effectiveness, and overall return on investment on 20-30 year REDD projects by investing in innovative school-based integrated educational approaches which empower young people to build better futures through life-sustaining values, practical skills and knowledge. These essential capacities will enable forest communities to convert CO2 into things they and the world at large will thrive on – healthy ecosystems, healthy people, and healthy economic opportunities. Such education and economic empowerment of the children of today and of tomorrow will mitigate leakage and ensure sustainability in REDD project areas, thereby strengthening investor confidence. Allocation of a percentage of REDD funds flowing to such integrated school programs will reduce risk and yield social, economic and environmental benefit for all parties concerned.   During the 3nd World Summit on Sustainable Development (WSSD) in 2002, education was recognized as having a major role to play in future sustainability. The UNFCCC Article 6(a)(i) states that parties shall: promote and cooperate in education, training and public awareness related to climate change and encourage the widest participation in this process.” Furthermore, the Convention on the Rights of the Child (CRC) is a primary source for justification of this platform for action. The CRC explicitly recognises the importance of the natural environment for the growth and well-being of children (Preamble), and requires the State Parties to take account of the dangers and risks of environmental pollution (Article 24) and to educate children to respect nature (Article 29). The CRC implicitly confirms that a safe environment is a necessary condition for children to realise certain rights. Thus, children’s environmental education is a principle that must be supported and promoted.   If approximately five percent of the world’s 2.2 billion children were to plant five trees per month, investing on infrastructure for the care of children would allow a return on the investment of more than 11 percent. According to our model, the Net Present Value of such an investment would equal 553 million USD over 25 years. Today’s children have an important role to play in the planet’s future.Educating them on the environment and sustainable practices is one of the best investments we can make to ensure a healthy planet for coming generations. | The role and importance of children in REDD+ is made in a number of the criteria, as 'youth' are included in the definition of vulnerable and marginalised groups. We feel that specific mechanisms or strategies (e.g. education) should be covered in accompanying guidance.
 |  | Indian Law Resource Center | 47 | [Referring to text:] "The Principles and Criteria reflect the UN‐REDD Programme's responsibility to apply a human‐rights‐based approach to its programming, uphold UN conventions, treaties and declarations, and apply the UN agencies' policies and procedures". We appreciate UN‐REDD's commitment to a human‐rights‐based approach, however the Principles and Criteria fall short of actually achieving that goal due to the reasons identified in overall comments attached. | There have been revisions to some citeria to strengthen the rights-based approach. See comment 44 for further information
 |  |  | 48 | [Refering to text:] "The Social and Environmenal Principles and Criteria draw on, are consistent with, and seek to help countries meet their commitment to the following itnernational agreements and, when applicable, the decisions taken in their COPs/MOPs:… International Labour Organization Convention 169 (ILO 169), United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP), Convention on the Elimination of All Forms of Racial Discrimination (UNCERD)..." We encourage UN‐REDD to additionally look to regional human rights systems as a source of human rights obligations, especially with regards to the Inter‐American and African human rights systems' relevant jurisprudence on the rights of indigenous peoples, see overall comments attached. | Agreed, but we feel that this should be covered in further guidance for specific criteria.
 |  |  | 49 | [Referring to text:] "The Principles and Criteria, which are consistent with UNFCCC agreements on safeguards for REDD+..." The Principles and Criteria are not consistent with UNFCCC agreements on REDD+ Safeguards. Those Safeguards include " b) That actions complement or are consistent with the objectives of national forest programmes and relevant international conventions and agreements" and "c) Respect for the knowledge and rights of indigenous peoples and members of local communities, by taking into account relevant international obligations, national circumstances and laws, and noting that the United Nations General Assembly has adopted the United Nations Declaration on the Rights of Indigenous Peoples.” The Cancun agreements additionally "emphasiz[e] that Parties should, in all climate change‐related actions, fully respect human rights.” See general comments above. | As mentioned in the introduction, the SEPC are coherent with and draw from the broad guidance provided by the [NAME] agreement and are consistent with other international agreements, such as the UN Declaration on the Rights of Indigenous Peoples. See comment 44 for further information on human rights and [NAME] rights.
 |  | [NAME], ClientEarth | 50 | Multilateral agreements relevant to SEPC The document includes an insert with the international agreements the SEPC draws or is consistent with (see [NAME] below). Although we recognize these are relevant international commitments that the SEPC should take into account, there are also several others that must be taken into account. Not only because they are relevant to inform the content of the Principles and Criteria, but also because safeguards “A” under the Cancun Agreements requires that REDD+ actions are consistent with international agreements, and this includes actions undertaken/supported by the UN-REDD Programme. We therefore suggest the UN-REDD Programme carries out a detailed identification of relevant obligations under international/multilateral agreements and ensures the SEPC is consistent with these.  These would include, amongst others:  • Non-Legally Binding Instrument on All Types of Forests (2007) • International Tropical Timber Agreement (ITTA) (1994) • Convention on International Trade in Endangered Species of Wild Fauna and [NAME] (CITES) (1973) • Convention Concerning the Protection of the World Cultural and Natural Heritage (1972) • Convention on Wetlands of International Importance, Ramsar (1971)  • Universal Declaration of Human Rights (UDHR) (1948) • Convention on the Protection and Promotion of the Diversity of Cultural Expressions (2005) • Convention on the Rights of the Child ( 1989) • Declaration on the Right to Development (1986) • International Covenant on Civil and Political Rights (ICCPR) (1966) • International Covenant on Economic, Social and Cultural Rights (ICESCR) (1966) • Optional Protocol to the International Covenant on Economic, Social and Cultural Rights (2008) • Optional Protocol to the Convention on the Elimination of All Forms of Discrimination against Women (OP-CEDAW) (1999) | See comment 27
Purpose |  | GIZ | 51 | As stated in "General comments", the SEPC are not providing indicators, therefore the purpose cannot be review and assessment of safeguard performance. It is rather a starting tool to make the next step towards implementation guidelines. | This was certainly the vision - thank you for recognising it! See comment 7 on application.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 52 | Possibly discuss relevance of this country-level tool for subsequent application on project level. Important to avoid a situation like the WCD criteria, that were made in generic form, and then no one cared about developing criteria that can be validated by auditors. | See comment 20.
 |  | EarthChild Institute | 53 | Participatory environmental education for sustainable development in REDD+ forest regions is a cost effective strategy for mitigation of leakage and can ensure long term project sustainability in REDD project areas, thereby strengthening investor confidence. Allocation of a percentage of REDD funds flowing to such integrated school programs will reduce risk and yield social, economic and environmental benefit for all parties concerned. | This is beyond the scope of the SEPC, which do not set out to dictate the contents of a national programme.
 |  | Indian Law Resource Center | 54 | [Referring to text:] "The Principles and Criteria will provide the UN‐REDD Programme with a framework to ensure that its activities promote social and environmental benefits and reduce risks from REDD+." The purpose of the Principles and Criteria should not be merely to ensure that its activities "promote social and environmental benefits and reduce risks", but to ensure that its activities respect and promote human rights, consistent with international human rights standards. | We feel that the content of the principles and criteria, which make reference to the need respect human rights and make reference to international human rights standards, covers this issue. There have been revisions to some citeria to strengthen the rights-based approach. See comment 44
 |  | Rainforest Foundation Norway | 55 | It is not totally clear exactly how the document will be used, and how the information included in the SEPC and the BeRT will be evaluated and used, and according to what criteria the countries will be evaluated. For instance- What is expected of a country for it to be accepted for readiness? Are some categories given more weight than others? | See comment 7 on application.
 |  | Global Witness | 56 | As noted above, the BeRT will only be used to help achieve the first objective of the SEPC: assisting countries in formulating national REDD+ programmes. It remains unclear how the other two objectives will be operationalized. Key questions that remain include who is responsible for ensuring compliance with the SEPC, against what standards, at what point(s) during the design, implementation and review of UN-REDD-supported activities, and what happens if compliance is not achieved. Specifically with regards to the second objective of the SEPC, the consistency of national programmes with the SEPC should be considered when proposals are reviewed for UN-REDD funding rather than "prior to submission". This would help to ensure that national programmes meet the requirements of the principles and criteria before approval. On the third objective of the SEPC - assessment of national programme delivery - the SEPC should clarify what is meant by "delivery" and be accompanied by performance criteria and compliance indicators in order to allow a meaningful assessment. The role of the UN agencies and the Policy Board in conducting such an assessment should also be clarified. It is also unclear whether "delivery" refers to a one-time assessment of the program or an ongoing assessment of programme activities, how this would be linked to accountability mechanisms, and whether compliance with SEPC will affect funding eligibility or other decisions. [further comment on BeRT placed in BeRT spreadsheet] | See comment 7 on application.
 |  | Forest Peoples Programme | 57 | The draft SEPC document states that the three goals of the SEPC are respectively to assist in the formulation of the National REDD Programmes, to assess National Programme delivery, and to review National programmes prior to submission to the Policy Board of the UNREDD. Therefore, if one of the goals of the SEPC is to assess National programme delivery, and also review National programmes prior to submission to the Policy Board of the UNREDD, then there needs to be some sort of protocol/procedure to ensure a process of bechmarking and assessing compliance of the REDD programme to the SEPC due to be funded with the SEPC.  This is not clear in the document. [In narrative comments there is additional text: "Nor is it clear whether and how the SEPC will apply to inform already funded National Programmes"].  The other important element is the “assessment of National programme delivery”. This would mean that the SEPC should also be accompanided with performance criteria and compliance indicators  to assess how these are being respected in National programme delivery. | See comment 29 on application and countries with existing programmes
 |  | WRI | 58 | 3. SEPC guidance indicates that it will be used by the UN-REDD Programme: as a) “an aid in formulating national REDD+ programmes and initiatives that seek UN-REDD funding; b) in the review of national programmes prior to submission for UN-REDD funding; and c) to assess national programme delivery.” 4. Further, the SEPC guidelines do mention that the BeRT will be used to operationalize the SEPC by various users, including “UN-REDD Programme staff, national counterparts and other stakeholders.” And that “[f]urther guidance is also being developed by the UN-REDD Programme on the reviewing and reporting procedures with regards to the use and application of both the Principles and Criteria and the Risk Identification and Mitigation Tool.” 5. While we recognize that not all information can be contained in one document, the lack of detail around the process which will be used to achieve the above objectives makes it difficult to image how the SEPC will be used. How b) and c) above will be achieved as a result the use of the SEPC and BeRT—and especially c) given the current state of UNREDD fund disbursements—seems especially important given the objective of having the principles and criteria defined. Clarification, for example, regarding the use of the principles and criteria and the BeRT tool by UNREDD staff with regards to assessing national programme delivery would be most useful. Would all the principles and criteria need to be considered for all activities? Would countries need to demonstrate that they are achieving improvements in relation to all aspects of all the criteria as part of their programs? As currently written it is not clear what the process would be. | See comment 7 on application. On the specific question, we do anticipate that the SEPC should be used together as a set, so that all are relevant to all programmes (relevance to individual activities supported by Programmes may vary)
 |  | [NAME], ClientEarth | 59 | According to the documents the SEPC will be used: 1. As an aid in formulating national REDD+  Programmes and initiatives that seek UN-REDD funding 2. To review national programmes prior to submission for UN-REDD funding; and 3. To assess national programme delivery However, there is lack of clarity in the documents as to how the SEPC will be used by the UN-REDD Programme in particular for number 2 and 3 outlined above.  With regards to the review of national programmes prior to the submission for UN-REDD funding, is important to clarify several questions in the documents. These include:   • Related to the outcome: What would be consequences of not meeting these Principles and Criteria in national programmes? What would be the funding implications? (e.g. would the national programme not be submitted to UN-REDD funding?)  [NAME] to the process for review: Clarifying how will the review of a national programme be carried out? What tool/mechanism would be employed to review that a national programme is meeting the SEPC?  Who can provide information on meeting these Principles and Criteria (e.g. can relevant stakeholders, such as forest dependent communities submit information or is only the government)?  With regards to the assessment of national programme delivery, it is also important to clarify several questions in the document. These include: • Related to the process for review: Clarifying how the assessment of national programme delivery will be carried out.  What process/ tool/mechanism would be employed to assess national programme delivery? Is also important to clarify/consider who can submit information about the national programme delivery. Can relevant stakeholders submit information, or is only the government/national authority entitled? • Related to the outcome: What are the consequences of not delivering/meeting these Principles and Criteria? What would be the access to justice opportunities if rights are violated as a consequence of not meeting these principles and criteria? What effective remedies will be provided? | see comment 58
Structure and Application |  | GIZ | 60 | No  reference to the FCPF SESA framework  is made. That leaves FCPF/REDD countries with the difficulties how to achieve consistency between competing frameworks of two UN organizations. Principles and criteria are provided, but corresponding indicators (cf. CCB/CARE REDD SES framework)  are missing.  This might have remained unmentioned due to the fact that FCPF contributed the paper. In our opinion, it should be made obvious. | See comment 22 on application and relationships with other initiatives
 |  | WWF | 61 | Clear complaint mechanism should be in place for forest dependent people enabling them to communicate adverse impacts | Criterion 2 addressess responsive feedback and grievance mechanisms
 |  | EarthChild Institute | 62 | We propose UN REDD include budgetary consideration for funding innovative school-based integrated educational approaches that empower young people to build better futures through life-sustaining values, practical skills and knowledge. These essential capacities will enable forest communities to convert carbon investment funds into things they and the world at large will thrive on—healthy ecosystems, healthy people, and healthy economic opportunities. Such education and economic empowerment of the children of today and tomorrow will mitigate leakage and ensure sustainability in REDD+ project areas, thereby strengthening investor confidence. Allocation of a percentage of REDD+ funds flowing to such integrated school programs will reduce risk and yield social, economic, and environmental benefits for all parties.  There is broad consensus among forest specialists that sustainable and just REDD+ policies and incentives must fulfill criteria for effectiveness, efficiency, and fairness. To be effective and fair, REDD+ policies at all levels must honor the principle of free, prior, and informed consent and respect human rights, including the rights of indigenous peoples, women, and children. The CRC clearly affirms that a child’s rights to life, survival, and development should be protected and that actions should be taken in the best interest of the child. Participatory empowering education in REDD+ combined with funding for clean energy, water, sanitation, and locally grown food at school facilities, will make great strides toward fulfillment of these rights and criteria.   Support to schools should include: school based vegetable gardens, access to safe water, sanitation and hygiene facilities combined with life-skills based participatory environmental education with focus on forest and ecosystem preservation and reforestation. Installation of renewable energy for electrification of the school and computers with which students and teachers can communicate with students and teachers in other parts of their countries and the world can enhance shared learning and global citizenship. | As noted in the responses under specific criteria, the definition of vulnerable and marginalised groups includes women and youth.The application of FPIC and who it applies to is covered by the UN-REDD FPIC guidelines, and where FPIC does not apply, the rights of stakeholders will be clearly outlined. We feel that specific mechanisms for budgetting should be considered in detailed and context specific planning but guided by the principles and criteria.
 |  | Indian Law Resource Center | 63 | The Principles and Criteria will only be effective at deterring human rights violations in REDD projects if they are binding, concretely linked to specific human rights standards rather than more general impact statements, and enforced through an effective complaint mechanism. This is especially the case regarding the rights of indigenous peoples to their lands, territories and resources. The content of these rights is complex and is not sufficiently protected merely by referencing "forest tenure rights". | The criteria (e.g. number 7) mention more than just forest tenure rights. A complaints mechanism is referenced in criterion 2 and 6. There is a process of clarification of the application of the SEPC underway which is being proposed to the Policy Board.
 |  |  | 64 | [Referring to text:] "The Principles are overarching, fundamental, active statements about the achievement of a desired outcome… The Criteria are the conditions that need to be met by UN‐REDD Programme funded activities to contribute to the achievement of the Principle." The Principles and Criteria should be binding minimum requirements for UNREDD projects. | See comment 22 on application
 |  | Rainforest Foundation Norway | 65 | It is not entirely clear how the SEPC will relate to the RPP | See comment 22 on application and relationships with other initiatives
 |  | Global Witness | 67 | The issues noted above need to be clarified and the SEPC and BeRT incorporated where relevant into the R-PP template. In countries participating in both the FCPF and UN-REDD Programme, the relationship between the SESA and other requirements outlined in the R-PP and the SEPC need to be clear to ensure efficency and effectiveness during implementation and monitoring. It is important where multiple standards co-exist that countries adopt the highest one. | See comment 22 on application and relationships with other initiatives
 |  | Forest Peoples Programme | 68 | There is an outstanding issue related to the integration of the SEPC within  the RPP in particular. The most recent draft RPP template does not provide any indication on how the SEPC will be made operational in the activities envisaged in the RPP. Nor does it clarify when and whether the SEPC apply in cases where FCPF (WB or other delivery partners) and UNREDD operate together in the same country.  For the sake of consistency and to ensure the proper application and use of the SEPC, these points need to be clarified and the RPP template revised accordingly. For the sake of consistency and to ensure the proper application and use of the SEPC, these points need to be clarified and the RPP template revised accordingly. | See comment 22 on application and relationships with other initiatives
 |  | WRI | 69 | 7. Furthermore, guidance in the SEPC document indicates that ”the Principles and [NAME]…are intended to guide the technical and financial readiness support offered by the UN-REDD Programme and to inform the assessment of programme delivery.” However, it is unclear whether this is intended to convey that the SEPC will form minimum standards that must be met if the activity is to receive UN-REDD support or if there are any other potential consequences that may occur if such adherence is not achieved. | see comment 7 on application
 |  |  | 70 | 8. If the SEPC will indeed be used to assess eligibility, this will prove challenging for the SEPC does not indicate clear minimum requirements. Several criteria ask the implementing body to, for instance, “minimize” adverse impacts, but it is unclear what level of adverse impact is acceptable, either in the SEPC, or in the BeRT. Finally, some criteria contain standards that are hard to quantify. Criterion 6, for instance, requires actors to “ensure the rule of law and access to justice.” While both rule of law and access to justice are ultimately vital for successful REDD+ programs, it is difficult to understand how an activity could demonstrate compliance with such a high and broad standard, particularly for REDD+ readiness activities. | see comment 7 on application
 |  |  | 71 | 9. Finally, we note that most UN-REDD funding has already been approved for disbursement to partner countries. This therefore begs the question of what role the SEPC will play going forward and/or may help in selecting what additional guidance is most urgently needed to assist the UN-REDD programme staff in the near term. | see comment 7 on application
Process |  | WWF | 72 | We are pleased that the comments process for Version 3 of the P&C has been managed in a more open and transparent way, allowing a broader range of stakeholders to participate in the review. The publication of the comments matrix on Version 2 further contributes to this transparency. We look forward to engaging and commenting on the RMIT - this will be an ambitious tool, as many of the responses to the comments in the comments matrix suggest that many challenging issues will be addressed in the RMIT. | Noted, thank you
 |  | Indian Law Resource Center | 73 | [Refering to text:] "Approval of the Principles and Criteria will be sought from the Policy Board at its first meeting in 2012." The Principles and Criteria should not be adopted until the concerns addressed herein are resolved. | Noted, see comment 7 on the companion document
 |  | Global Witness | 74 | Relevant stakeholders should be involved in the application of the BeRT at all stages in its use, not only at the validation stage at which point it is too late for their engagement with the SEPC to have meaningful impact on national programme design. National programmes should include the BeRT outcomes as an annex along with an explanation of how the risks identified are addressed in the proposal. The submission form for national programmes should include an assessment of the quality of the BeRT process. The quality of stakeholder engagement during the use of the BeRT should be specifially reported on and considered as part of the process of considering national programmes for funding. | These are useful inputs and will be considered as the design of and guidance on the BeRT moves forward.
Principle 1 | Apply norms of democratic governance, including those reflected in national commitments and Multilateral Agreements | [NAME], Ministry of Forests and Soil Conservation, Nepal | 75 | Establishment of national level multi-stakeholder policy guidance and decision making mechanism on REDD+  should be incorporated under this principle | We feel that criteria 2, 3 and particularly 4 address this issue
 |  | GIZ | 76 | The term "democratic governance" is a rather unusual one and might be misunderstood within the UN context. In the context of Natural Resource Management, the term "good governance" is more often used and better understood. | See response from previous consultation: 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.
 |  | Global Witness | 77 | There is a need to ensure integrity, transparency, and accountability  of the institutions involved in REDD+ design, implementation and enforcement. (See suggestions for criterion 2). | We feel that these issues are covered under the detailed criteria
 |  | [NAME], ClientEarth | 78 | Would be appropriate to further clarify and identify which are the multilateral agreements that must be respected. | Some references are included in the opening text to the SEPC, but further guidance will be given where relevant for each criterion
Criterion 1 | Ensure the integrity and transparency of fiduciary and fund management systems | [NAME], RECOFTC | 79 | Ensure the integrity, transparency and consultative development of fiduciary and fund management systems | We feel that a number of other criteria (such as criteria 2, 3 and 4) emphasise the need for consultative development of systems around REDD.
 |  | Indian Law Resource Center | 80 | Transparency should be explained in terms of what it means for impacted communities, i.e. in linguistically and culturally appropriate format. These mechanisms should not only be available, but their existence should be actively made known to impacted communities. | This is part of the access to information criterion and accessibility of information is defined in the glossary. The UN-REDD Guidelines on FPIC which are referenced under critierion 9 also give further guidance on this issue.
 |  |  | 81 | [BeRT] Should address fiduciary responsibility and transparency in terms of obligations toward communities and local rights‐holders participating in projects. | Noted
 |  | [NAME] and [NAME], REDD+ SES Initiative Secretariat | 82 | Suggest adding ‘of the REDD+ program’? 'why not financial management?' | Have added reference to REDD+ activities in the criterion.
 |  | Global Witness | 83 | Accountability is an essential element of fiduciary and fund management systems and should be added as a criteria. | Accountability has been included in the wording of the criterion
 |  | [NAME], ClientEarth | 84 | Besides integrity and transparency, is important the criterion also requires accountability of fiduciary and fund management systems. | Accountability has been included in the wording of the criterion
Criterion 2 | Ensure accountability and legitimacy of all bodies representing stakeholders, including through establishing responsive national feedback, complaints and grievance mechanisms, amongst others | Government of Sudan | 85 | Integration of indiguous and national systems and  legal pluralism. | Customary law is covered in principle 2 and a number of criteria, such as in the criteria under Principle 2, which makes specific reference to statuary, customary and collective rights, so we feel that it does not need to be mentioned here.
 |  | Indian Law Resource Center | 86 | Rights‐holder analysis should not be confused with stakeholder analysis. Identification of relevant stakeholders must follow from an analysis of land and resource rights under national and international law. | This is an issue that is covered by the UN-REDD stakeholder engagement guidelines. We also feel that process (i.e. best practice in stakeholder analysis/identification) should be outlined in further guidance linked to the criterion.
 |  | [NAME] and [NAME], REDD+ SES Initiative Secretariat | 87 | Criterion 2 – Ensure accountability and legitimacy of all bodies representing REDD+ program stakeholders, including through establishing responsive national (why only national?) feedback, complaints and grievance mechanisms, amongst others.  Why use both terms ‘complaint’ and ‘grievance’?  This just says that any bodies that happen to represent stakeholders should be accountable and legitimate but does not require representation of stakeholders and clarify what level of influence they should have? Is government included as a stakeholder - ie does this cover all bodies or only those with non-govt representation?  Do all stakeholders have to be represented?  Should they choose their own representatives?  These issues are not clear in the criterion and are covered in BeRT. | The criterion has been simplified to remove the word 'compaints' and 'national' has been removed. Stakeholders has been clarified to include 'relevant stakeholders' as defined in the glossary. UN-REDD stakeholder engagement guidelines and the FPIC guidelines offer more information on this issues, and more details on these bodies can be discussed in further guidance
 |  | Rainforest Foundation Norway | 88 | This sould be demanded by all bodies involved in REDD at all stages of the process. | Noted
 |  | Global Witness | 89 | This criterion should ensure that the same elements in criteria 1 (integrity, transparency, and accountability) apply to all bodies involved in REDD+ design, implementation, and enforcement including those bodies representing various stakeholders. Suggested text: "Ensure integrity, transparency, and accountability of all bodies involved in REDD+ design, implementation, and enforcement, including inter alia through establishing responsive national feedback, complaints and grievance mechanisms." | It is our view that these issues are covered across the criteria
 |  | Forest Peoples Programme | 90 | This can be risky for indigenous peoples, since it might open the door to ilegitimate intrusion of governmental authorities into traditional decision-making and governance structure of indigenous peoples | The UN-REDD Programme recognizes the importance of customary rights and traditional livelihoods. This is covered in the revised criteria, such as those under Principle 2. In addition, the UN-REDD stakeholder engagement guidelines and the FPIC guidelines offer more guidance on these issues
 |  | [NAME], ClientEarth | 91 | The Principles and Criteria fail to address accountability, transparency and integrity of the institutions involved in REDD+ design, implementation and enforcement. Instead they focus on the bodies representing stakeholders and their legitimacy. This is a notable bias and flaw. This criterion should apply to all bodies engaged in REDD+ design, implementation and enforcement, not just those representing stakeholders.  Suggest clarifying which complaints/grievance mechanisms would be established. This might include judicial and administrative proceedings. | The criterion is supposed to emphasise those bodies representing stakeholders. The changes to criterion 1 and other criteria cover other aspects of REDD+ activities.
Criterion 3 | Ensure transparency and accessibility of all information related to REDD+, including active dissemination among relevant stakeholders | WWF | 92 | The conditions for information accesibility are appropriate, however information has to also be provided in due time. Communities, particularly those who are marginalized in national societies, need time to react to REDD+ information and probably convene assemblies or traditional decision-making organs. It is important to include this feature in Criterion 3. Clarity on the definition of 'accesssibility' could enhace this criteria: education materials and consultations should be designed with respect to cultural norms and accessible and understood by all relevant stakeholders, including women's groups | This has been included in the glossary definition of accessibility
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 93 | take into account accessibility issues in candidate sites for forest carbon mitigation, and ensure that information is provided in the appropriate language and media for the local conditions | This is included in the glossary definition of accessibility
 |  | EarthChild Institute | 94 | It has been demonstrated that children are effective at teaching their parents and influencing the behaviour change of their parents. For example, the City of Los Angeles had an amazing ninety percent compliance when they started their recycling program, as compared to other large cities who have only been able to engage less than half of the residents’ compliance. Before implementation, and educational program was conducted in public schools by a local non-profit organization called TreePeople. This program reached 250,000 elementary school children. These children in turn educated their parents, thereby ensuring the success of family action when the municipal recycling program began. | This point has been noted. The role of children (youth) in REDD+ is emphasised in a number of criteria under the definition of vulnerable and marginalised groups.
 |  | Government of Sudan | 95 | Ensure equal and easy accessiblity to information reated to REDD+, with consideration to illtreate and remote  people in the rural areas. | We feel that this is covered by the glossary definition of accessibility of information, which has been adapted.
 |  | Rainforest Foundation Norway | 96 | Grievance mechanisms should be (human) rights  compatible and timely, and where desicions cannot be reversed, should be able to provide reparation to victims. They should be independent and there should be an appeal option. | This further elaboration of the form of grievance mechanisms will be included in any relevant accompanying guidance.
 |  | Global Witness | 97 | Criterion should specify that the provision of information should be done in a timely and culturally appropriate manner in order to allow for meaningful participation in decision-making processes. | We feel that this is covered by the glossary definition of accessibility of information, which has been adapted. The UN-REDD Guidelines on FPIC offer further information on this and can be referred to in any further guidance related to the criterion.
 |  | Forest Peoples Programme | 98 | Specify that accessibility of information has to be timely and culturally appropriate | We feel that this is covered by the glossary definition of accessibility of information, which has been adapted. The UN-REDD Guidelines on FPIC offer further information on this and can be referred to in any further guidance related to the criterion.
 |  | [NAME], ClientEarth | 99 | Suggest clarifying that all information related to REDD+ includes providing information regarding decision making processes/opportunities to participate.  Also suggest including the condition to provide timely dissemination of information, as stakeholders will require sufficient time to understand the provided information before being able to participate in decision making processes. | We feel that this is covered by the glossary definition of accessibility of information, which has been adapted.
Criterion 4 | Ensure the full and effective participation of relevant stakeholders, in particular, indigenous peoples and other forest dependent communities, with special attention to the most vulnerable and marginalized groups | [NAME], RECOFTC | 100 | particular, indigenous peoples, women and forest dependent communities, with special attention to the most vulnerable and marginalized groups | The criterion has been changed to include reference to vulnerable and marginalised groups. The glossary definition includes women.
 |  | GIZ | 101 | instead of "forest dependent communities": "local communities" (as in Cancun Text on FPIC). | This has been changed in the criterion.
 |  | WWF | 102 | Ensure in all phases of the programme the full and effective participation of relevant stakeholders, in particular, indigenous peoples and other forest dependent communities, with special attention to the most vulnerable and marginalized groups. In the definition of 'relevant stakeholders' it is important to include natural resources' use rights granted to communities. It is important here to acknolwedge that women play an active role in forest resource use and management and should not only be considered in this context as 'vulnerable.' Gender-sentitive architecture, including consultation requirements and procedural guidance should be required of all relevant decision-making bodies. | The phrase "in design, planning and implementation of REDD+ activities" has been included in the criterion. The definition of vulnerable and marginalised groups makes reference to gender issues.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 103 | in particular, ensure that gender issues are appropriately addressed in outreach and consultation. Criteria for effective participation should be defined; we propose that the threshold be fully interactive participation as described by [NAME]  in Participatory Learning for Sustainable Agriculture, World Development Vol 23 No 8, pp 1247-1263, 1995. | The definition of vulnerable and marginalised groups makes reference to women. The UN-REDD stakeholder engagement guidelines and other guidance outline procedures for effective participation. The UN-REDD report 'The Business Case for Mainstreaming Gender in REDD+' further discusses the importance of gender-responsive stakeholder engagement and can be referred to in any further guidance related to this criterion.
 |  | EarthChild Institute | 104 | A majority of the world’s 370 million indigenous peoples are children or adolescents.  Indigenous children in forest communities are particularly vulnerable to the impacts of deforestation, yet they are the world’s best hope for maintaining the traditions of their peoples and protecting the forest ecosystems thus ensuring the well-being of all children worldwide Life-skills based education in children will help to mitigate leakage in REDD+, increase resilience of most vulnerable children and their families to climate change and fortify the long-range planning needed to sustain a green economy  Further, we note that indigenous communities experience increasing prevalence of domestic and community based violence in association with deforestation and the associated intrusion on their land. There needs to be an understanding and promotion of local peoples’ knowledge, needs, capacities and practice, local livelihoods and rights, all of which can occur by using systemic approach to planning and engagement of various stakeholders. | The definition of vulnerable and marginalised groups makes reference to youth.
 |  | Government of Sudan | 105 | This is applicable in Sudan community forests | Noted
 |  | Conservation International | 106 | [NAME] and 9. While CI recognizes that indigenous peoples have special rights under international law, we also feel that in regards to REDD+ FPIC should apply to both indigenous peoples AND local communities. As currently worded, the criteria refer to indigenous peoples and other forest-dependent communities. However, REDD+ may also impact indigenous peoples and communities that are not forest-dependent, for example pastoral or agricultural communities. | This has been changed in the new text. UN-REDD's guidance on FPIC (currently under revision) also deals with the issue of which actors it applies to.
 |  | [NAME] and [NAME], REDD+ SES Initiative Secretariat | 107 | Suggest adding all, since ‘full’ as defined in glossary means thoughout the process. | Full and effective participation' is defined in the glossary to mean 'Meaningful influence of all stakeholder groups
 |  | Center for International Environmental Law (CIEL) | 108 | Clarify the definition of “stakeholder.”  Currently the criteria allow for a complaint and grievance mechanism and allows for stakeholder involvement.  While it is important to ensure that all relevant stakeholders are included in the process, neither the Principles and Criteria nor the BeRT define who will be included as “relevant stakeholders.”  Ideally this term would include not just groups directly impacted by the project, but also encompass non-governmental organizations in the area. Including groups that may not be directly impacted by the project allows for a wider range of voices to ensure that all potential problems are spotted and handled before harm occurs. | The definition of "relevant stakeholders" appears in the glossary.
 |  | [NAME], ClientEarth | 109 | With regards to full and effective participation: While the criterion is linked to the glossary of terms to further define what full and effective participation means, the concept provided in the glossary of terms falls short on specifying what conditions need to be met to ensure the full and effective participation of relevant stakeholders. Ideally the term ‘stakeholder’ would include not just groups directly impacted by the project, but also encompass non-governmental organizations in the area. Including groups that may not be directly impacted by the project allows for a wider range of voices to ensure that all potential problems are spotted and handled before harm occurs. We suggest that the criterion or the associated definition included in the glossary of terms, furthers defines what conditions need to be met to ensure the full and effective participation. The definition of this term must draw on relevant international legal commitments, which at least require the following: • Relevant stakeholders, in particular indigenous peoples and other forest dependent communities, have a right to access information at the local, regional and national level in the possession of public authorities or the private sector that is relevant to environmental decision-making processes. • Information on how to participate in decision-making processes is proactively provided to relevant stakeholders • Relevant stakeholders, in particular indigenous peoples and other forest dependent communities, have a right to participate in decision-making processes in a transparent and culturally appropriate manner, at the local, regional and national levels. • Relevant stakeholders, in particular indigenous peoples and other forest dependent communities, have a right to access effective judicial and administrative proceedings, including redress and remedy, to challenge the substantive and procedural legality of any decision, act or omission relating to participation in environmental decision making. | These issues are included in guidance referenced in the glossary. Civil society is listed as a relevant stakeholder in the glossary. The other issues are addressed under various other criteria, such as criterion 2,3 and 11. They will also be reinforced in any further guidance (e.g. adaptation of the BeRT) produced.
 |  | Republic of the Congo | 110 | A titre d’exemple pour la justification des indicateurs nous prendrons le principe I et le critère 4 tous les détails qui sont dans ce critère peuvent être déclinés en indicateurs sur le cas spécifique des peuples autochtones, le cas spécifique des femmes comme être vulnérable ; Google Translate translation: - As an example for the justification of the indicators we will take the principle and the criterion I 4 all the details that are in this criterion can be broken down into indicators on the specific case of indigenous peoples, the specific case of women as being vulnerable; | Noted.
Criterion 5 | Promote coordination, efficiency and effectiveness, including cooperation across sectors and in the enforcement of laws | GIZ | 111 | ...across sectors and countries, which would then include the necessity to address regional and global threats (e.g. corruption). It seems unusual for UN-REDD Programme activities to be involved in law enforcement. How would such promotion be carried out, purely in dialogue? | The wording of the criterion has been changed to reflect these comments. The footnote includes a reference to cooperation between countries.
 |  | EarthChild Institute | 112 | Inclusion of Education and Youth ministries with appropriate allocation of REDD funds will reduce risk and yield social, economic and environmental benefit for all parties concerned.  REDD+ initiatives are well-positioned to incorporate whole systems thinking - which includes the engagement of schools, innovative financing mechanisms, and the planting of trees that last – as the most intelligent means to mitigate leakage and benefit multiple stakeholders in communities. | The criterion has been altered and the footnote emphasises the need for cooperation with sectors outside the forest sector.
 |  | Government of Sudan | 113 | In the part of enforcement of law, it could be better to add enforcment of plural and combitable  laws (Indigouse and natinal laws) | Customary law is covered in principle 2 and a number of criteria
 |  | Global Witness | 114 | Suggested text: "Promote coordination, efficiency and effectiveness among all agencies and implementing bodies relevant to REDD+, including law enforcement agencies." | The criterion text has been changed to reflect this comment. The glossary definition of agencies relevant to REDD+ includes law enforcement agencies.
 |  | [NAME], ClientEarth | 115 | The criterion does not specify that enforcement of the law is a condition of democratic governance, but merely requires that coordination, efficiency and effectiveness must take place in the enforcement of laws.  We suggest the criterion is reworded/clarifies that the enforcement of laws is a condition of democratic governance and that its coordination, efficiency and effectiveness should be promoted. | We have changed the wording to emphasise that this criterion is focused on coordination, efficiency and effective for all agencies and implementing bodies. The importance of the rule of law is included in criterion 6.
Criterion 6 | Ensure the rule of law and access to justice | GIZ | 116 | It is not within the influence of a UN-REDD Country Programme to ensure the rule of law and access to justice in a country, not even with regard to programme activities. Better: "Seek for the partner country to take appropriate measures to..." | This has been changed to "promote and support" in the new criterion text
 |  | WWF | 117 | Ensure the rule of law and access to justice " and to a effective complain mechanism" In the 'access to justice' definition, it is important to add States must guarantee a non-discriminatory access to justice. This may imply endorsing the necessary reforms and measures to combat the lack of access to justice for indigenous peoples and other marginalized groups -as forest dependent and rural communities. In this criteria it would be great to mention" and to a effective complain mechanism" | This issue is covered in the footnote and in other criteria, such as criterion 2. The footnote also stresses the attention needed towards vulnrable groups.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 118 | in particular, ensure adequate training for law enforcement and judiciary in environment and natural resource laws and regulations and in other rule-making relevant to forest carbon management | This will be covered in further guidance on the criterion. The glossary definition of access to justice, covers some of the key elements that may need to be supported, likely through training and investment in legal systems.
 |  | Government of Sudan | 119 | Integration of indiguous and national systems. | Customary law and its relationship to statutory systems is covered in principle 2 and a number of criteria.
 |  | Indian Law Resource Center | 120 | Indigenous peoples and local communities should have access to impartial technical and legal support necessary to ensure access to justice. | We feel that this is covered by the glossary definition of access to justice and the references made in the glossary.
 |  | Global Witness | 121 | The principles should also ensure the right to an effective redress. | This has been included.
 |  | [NAME], ClientEarth | 122 | While affirming the need to ensure the rule of law and access to justice, the criterion should try to specify that this needs to take place at the national, regional, state/provincial or local/municipal level to further ensure it can be accessible to all relevant stakeholders.  Access to justice should include remedies and redress. | We feel that these scalar issues apply to many of the criteria and can be clarified in further guidance. Access to redress has been included.
 |  | Center for International Environmental Law (CIEL) | 123 | Affirm the right to an effective remedy. While affirming the right of access to justice, neither the Principles and Criteria nor the BeRT provide any reference to effective remedies. Without protecting effective remedies, a country could allow groups to bring claims in their court system, but then deny a remedy that can effectively fix their problem. The right to effective remedies is reflected in several international treaties and should be protected in the Principles and Criteria. | This has been included
Additional suggested criteria under Principle 1 |  | [NAME], RECOFTC | 124 | 1. Under Principle 1, RECOFTC feels that there is an opportunity to underline UN-REDD support for the improvement and reform of forest governance. Although Principle 1 refers to democratic governance in the REDD+ process, the criterion do not make the link between REDD+ and wider forest governance.  We would therefore suggest an additional criterion to be added to Principle 1 to ‘promote the improvement of national forest governance systems in order to support the REDD+ readiness process’ | We feel that the criteria as they stand help to promote and support forest governance related to REDD+
 |  |  | 125 | RECOFTC also feels that in either Principle 1,2 or 3, the criterion should refer specifically to responding to local needs. There is room for greater emphasis on the opportunities arising from bottom up processes. For instance, perhaps there could be a criteria which refers to ‘Promoting community-led REDD+ planning’? | We feel that the criteria on full and effective participation in the 'design, planning and implementation of REDD+ activities' covers this issue.
Principle 2 | Respect and protect stakeholder rights, including human rights, statutory and customary rights, and collective rights | WWF | 126 | Using the language of "rights-holders and stakeholders" throughout the P&C would better highlight this principle and basis in rights. | We have given definitions of relevant stakeholders, and referred in a number of criteria to the rights of these and of indiegenous peoples, local communities and other vulnerable and marginalised groups. We feel that this is sufficient to cover this point.
 |  | EarthChild Institute | 127 | The Convention on the Rights of the Child (CRC) is a primary source for justification of this platform for action. The CRC explicitly recognises the importance of the natural environment for the growth and well-being of children (Preamble), and requires the State Parties to take account of the dangers and risks of environmental pollution (Article 24) and to educate children to respect nature (Article 29). The CRC implicitly confirms that a safe environment is a necessary condition for children to realise certain rights. Thus, children’s environmental education is a principle that must be supported and promoted. | The CRC is relevant in the REDD+ context. Further reference to relevant international obligations will be made in accompanying guidance for each criterion.
 |  | Indian Law Resource Center | 128 | Respect and protect the rights of all individuals and communities, including the collective rights of indigenous peoples, as those rights are established by international law and domestic law, whichever is more protective. | We feel that the text in the criterion covers this issue, but have reinforced the attention to international obligations, as well as references to collective right, as the UN supports such obligations.
 |  | Center for International Environmental Law (CIEL) | 129 | Several of the questions asked in the analysis may indicate a significant risk that could adversely impact rights. Without providing a mechanism to help countries address risks, how will the BeRT ensure countries follow a rights-based approach consistent with both UN-REDD programming obligations and safeguard A of the Cancun Agreements?   To ensure that risks are not only identified but also addressed, the SEPC and BeRT also need to clarify how they interact with each other and what actions will be required in the event that risks are identified.   For example, it would be helpful to clarify the process to ensure rights are respected, including how rights themselves are identified.  The questions asked in the BeRT would theoretically hold the criteria to a high level of human rights protections.  At thes same time, the SEPC primarily references guidelines, as opposed to the obligations themselves.  The SEPC/BERT should clarify the underlying rights obligations (see, e.g., CIEL's list of select international obligations at http://www.ciel.org/Publications/REDD/REDD_intl_obligations_Nov11.pdf ).  The SEPC/BERT should also clarify expectations of UN agencies and countries in ensuring international obligations are respected.  Finally, the SEPC/BERT should not only affirm the right of access to justice but also the right to an effective remedy.  Without protecting effective remedies, a country could allow groups to bring claims in their court system, but then deny a remedy that can effectively fix their problem. The right to effective remedies is reflected in several international treaties and should be protected in the Principles and Criteria. | A reference to international obligations has been made in the principle. The questions of application will be covered in the different types of guidance produced for applying the SEPC. Criterion 6 has also been changed to include effective remedies
 |  | Rainforest Foundation Norway | 130 | add in accordance to international obligations | This has been added
 |  | The Royal Botanic Gardens, Kew | 131 | Suggest that the language used in this Principle and related Criteria is flexible in order to better align with domestic legislation  and international committments in relation to  rights | Language has been added on international obligations which the UN promotes. The reference to domestic legislation is not made in the principle because it may vary with and conflict with other processes
 |  | Global Witness | 132 | Respect for and protection of these rights should adhere to international laws and obligations. | This has been added
 |  | Forest Peoples Programme | 133 | add: in accordance to international obligations and instruments | This has been added
 |  | [NAME], ClientEarth | 134 | It’s clear that this Principle must draw on international instruments related to human rights and indigenous people’s rights. As it appears the UN-REDD Programme has only taken into consideration the international instruments identified in [NAME] I of this document, we suggest UN-REDD programme tries to draw on all relevant international instruments and ensures that all internationally recognized rights held by stakeholders and indigenous peoples are also recognized by the SEPC. Important rights that we think should also be recognized through a criterion or at least linked to existent criterion are: • Social, economic, political and cultural rights with respect to their identity, customs, traditions and institutions. • Provide effective mechanisms for the prevention of, and redress for, any action that violates or undermines the rights or freedoms of relevant stakeholders, especially those concerning their rights to ownership and possession of lands and territories. | This has been added. Relevant obligations will be referred to in any guidance for specific principles.
Criterion 7 | Respect and promote the recognition and exercise of equitable land tenure and carbon rights by indigenous peoples and other local communities | [NAME], [NAME] | 135 | I think the text would benefit from the inclusion of a definition and further clarification on  "carbon rights" , this should perhaps include how they may be allocated. | The new wording of the criterion makes a reference to resources, including carbon. A standard definition of carbon rights does not exist, but can be elaborated in any further guidance for the criterion.
 |  | WWF | 136 | Add, "with particular reference to customary rights." Indigenous peoples' traditional guardianship of the environment and the need to identify relevant rights holders should also be highlighted. Women's roles should also be disaggrated from the category of "local communities," as different members of these communities may have informal rights to use different parts of the forest. For example, women  use forests more for food, fuel, medicines and other NTFP whereas men are more involved in timber production. This gender differentiation has major implications for ownership and usufruct right to forest and by-products that affect the selection of species for forest management decisions. Furthermore, if women are excluded from owning property or holding rights to land, they may be less inclined to defer present livelihood benefits. | Attention to customary rights is included in the text and footnote of the principle 2. The definition of vulnerable and marginalised groups includes women.
 |  | [NAME], FCPF | 137 | For example, the addition of Criterion #7 on "equitable land tenure and carbon rights" for indigenous peoples and other forest-dependent communities is welcome, although the terms "land tenure" and "carbon rights" have come to denote a rather distinct (if inter-linked) set of concerns, so this Criterion might benefit from being split into two. | The new wording of the criterion makes a reference to resources, including carbon. A standard definition of carbon rights does not exist, but can be elaborated in any further guidance for the criterion.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 138 | recognize that the sale of carbon credits conveys a form of property right that must be managed consistent with laws and regulations, and that may be in conflict with other rights unless and until harmonized and clarified | We feel that this will need to be dealt with in further guidance related to the criterion.
 |  | Indian Law Resource Center | 139 | With regard to indigenous peoples, the standard here should not just be equitable land tenure, but indigenous peoples' rights to land, territories and resources, consistent with the UN Declaration. Because these rights are complex, this should not be a criterion, but a separate principle with more specific criterion that elaborate the content of indigenous peoples' permanent sovereignty over their natural resources, including the collective rights to own, use, and manage the lands, territories and natural resources that they possess by reason of traditional ownership or other traditional occupation or use, as well as those which they have otherwise acquired. | The respect and protection of stakeholder rights, and specifically those of Indigenous Peoples, is addressed in several criteria under Principle 2.  The SEPC further makes reference to the UNDRIP in the introductary text, and also the UN-REDD Guidelines on FPIC in a footnote under Principle 2. The UN-REDD Guidelines on FPIC provides more details on the specific rights of Indigenous Peoples.
 |  |  | 140 | Ensure that no REDD projects go forward without protections in domestic law for the PSNR (Permanent Sovereignty over Natural Resources )of indigenous peoples, including recognition, demarcation and protection of collective and traditional ownership of land and resources. | The SEPC addresses stakeholder rights under Principle 2. The UN-REDD Guidelines on FPIC specifically addresses issues related to the recognition, demarcation and protection of land and resources.
 |  | [NAME] and [NAME], REDD+ SES Initiative Secretariat | 141 | 18. Criterion 7 – Respect and promote the recognition and exercise of equitable land tenure and carbon rights by indigenous peoples and other local communities.  What does equitable refer to?  Is it the land tenure and carbon rights, ie how much of them, that is equitable, or the ‘the allocation of’ carbon rights and land tenure? | The reference to equitable has been removed - the emphasis of the criterion is now on respecting and promoting rights.
 |  | Center for International Environmental Law (CIEL) | 142 | [Clarify the relationship between land tenure and carbon rights.] Rights related to lands, territories and resources are far more established than rights related to carbon.  Indeed, many have questioned whether in the context of REDD the right to carbon can be disaggregated from natural resources (i.e. trees) in which that carbon resides.  Put simply, whomever has the right to the tree would also control the carbon.  We understand that some actors have attempted to purchase or otherwise claim carbon rights in the context of REDD, but the legal nature of such decisions remains tenuous if it is separate from the underlying rights to the lands, territories, or resources in which that carbon is found. Currently the SEPC combines carbon and land tenure into one criterion (number 7). In order to better improve this criterion, language should be added to recognize that carbon rights should be respected where they are consistent with internationally and nationally recognized rights to lands, territories, and resources.  We note that the BeRT examines countries’ existing legal obligations to both carbon and tenure rights but does not ask whether these rights are consistent with customary rights.  It is possible that a country has a “legal” framework that nevertheless violates international obligations. As such, customary rights and international obligations should be included in this assessment. | The principle clarifies that attention should be given to international obligations and customary rights. We feel that the new language for the criterion emphasises that the rights of indigenous peoples to resources, including carbon, should be promoted and respected.
 |  | Rainforest Foundation Norway | 143 | we suggest: respect and promote the recognition and exercise of the right to land, territories and resources, through land tenure reform, land demarcation and titling, and defining rights over forest resources (including carbon) | We feel that the specific mechanisms through which these issues are dealt with should be outlined in further guidance for meeting the criterion. This can also elaborate further best practice on how such processes should be carried out.
 |  | Global Witness | 144 | Land tenure and carbon rights should not be treated equally, since the former is much more established than the latter. Suggested text: "respect and promote recognition and exercise of the rights of indigenous peoples and local communities to land, territories and resources, including carbon." | We have changed the text to reflect this suggestion which is clearer than the original formulation.
 |  | Forest Peoples Programme | 145 | this needs to be changed into the following formulation, to encompass a broader approach to rights to land, territories and resources: "respect and promote the recognition and exercise of the rights to land, territories and resources,  through land tenure reform, land demarcation and titling, and defining rights over forest resources (including carbon)” | We feel that the way in which these issues are dealt with should be outlined in further guidance for meeting the criterion. This can also elaborate further best practice on how such process should be carried out.
 |  | [NAME], ClientEarth | 146 | Critically, this criterion must follow international commitments and require the respect and legal recognition of indigenous peoples and other local communities rights to lands and territories which they have traditionally owned, occupied or otherwise used or acquired; this includes lands not exclusively occupied by indigenous peoples, but to which they have traditionally had access for their subsistence and traditional activities.  The current wording of the criterion falls short in defining the conditions to meet the principle, in particular it puts at risks the protection of indigenous peoples “rights to lands and territories”. Situations could arise where a national legal framework does not recognize the customary/traditional rights of indigenous peoples and other local communities; in which case the current wording of the criterion would not provide protection as the national programme might only need to prove compliance with statutory law.  Furthermore, it is important that this criterion separately covers the legal rights to lands, and all natural resources including carbon.. Although some countries are moving towards defining carbon rights within their legal frameworks, many other countries understand it as part of the ecosystem services linked to the land/forest. | Reference to customary systems is made at the principle level. The new wording reflects the request to separately cover legal rights to lands, territories, and resources, including carbon
Criterion 8 | Promote and enhance gender equality, gender equity and women’s empowerment | WWF | 147 | It is important to follow what the Nagoya Protocol on Access to Genetic Resources and the Fair and Equitable Sharing of Benefits arising from their Utilization states regarding the gender dimension. The preamble, Article 12(3) and Article 22 tackle the involvement of women in the development of community protocols and model contract clauses for benefit sharing. Moreover, State Parties should support capacity needs and priorities of women. In addition, paragraph 43(d) of the Akwé: Kon Guidelines stresses that gender should be considered in determining the scope of a social impact assessment. Gender equity criteria might include: gender finance quotas via gender responsive budgeting processess; mandatory gender audits of funds spent; conditional release of subsequent tranches linked to gender perforamce indicators or standards; gender monitoring, in particular around women's role as forest users managers and equitable access to and distribution of benefits. | Definitions of gender equity and gender equality are given in the glossary. Further analysis of the gender dimensions of REDD+ has also been carried out by UN-REDD. Links to this protocol and guidelines will be made in further specific guidance for the criterion.
 |  | EarthChild Institute | 148 | There are over 500 million adolescent girls (aged 10-19) in the developing world.  Female children in particular, are most often responsible for collecting firewood, water and fodder, however, as girls and young women face additional challenges as a result of depleted forests, these challenges have also been known to motivate them to become more responsible than their male counterparts in terms of environmental stewardship The Girls Count report by the Chicago Council on Global Affairs indicates that “adolescent girls and women are the key to fully realizing the productive potential of agriculture. If women farmers were given the same access to productive resources as men, agricultural yields could increase by 20 to 30 percent and reduce the number of undernourished people by 12 to 17 percent.”  Girls’ responsibilities at home and on the farm give them unique knowledge of local crop species and environmental conditions, making them natural players in resource management and risk reduction associated with natural hazards. | Noted. The glossary definition  of vulnerable and marginalized groups has also been adjusted and refers to women as well as youth
 |  | Government of Sudan | 149 | Adding gender mainstreming in all REDD+ activities | The intention of the criterion is to ensure gender mainstreaming in all REDD+ activities.
Criterion 9 | 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) | [NAME], Ministry of Forests and Soil Conservation, Nepal | 150 | Community based resource management groups should be added after indigenous peoples | The scope of application of FPIC is further clarified in UN-REDD guidance on FPIC which has been referenced in the footnote.  The UN-REDD FPIC Guidelines will be clarified to define FPIC as a right for only IPs, based on international law.The guidelines will also clarify the rights of non-indigenous communities in relation to FPIC.
 |  | GIZ | 151 | instead of "forest dependent communities": "local communities". In many countries, legal tenure rights are not settled, local communities should therefore be included in the FPIC process. Also, please add: "to developments/programme activities that affect their resources and territories". FPIC only makes sense at the level of geographically explicit activities, which might affect IPs territories. | The scope of application of FPIC is further clarified in UN-REDD guidance on FPIC which has been referenced in the footnote.  The UN-REDD FPIC Guidelines will be clarified to define FPIC as a right for only IPs, based on international law.The guidelines will also clarify the rights of non-indigenous communities in relation to FPIC.
 |  | WWF | 152 | (Seek) Guarantee 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) Consultation processes should be designed with in put from indigenous peoples and other forest dependent communities. In addition, consultation meetings should ensure full participation of women based on good practices such as holding separate meetings with women's groups. Links between free, prior, informed consent and customary rights to lands, territories and resources are not yet reflected here. | Gender equality and women's empowerment is included in criterion 8, while the importance of women's involvement in REDD+ activities is further discussed in the UN-REDD publication 'Business Case for Mainstreaming Gender in REDD+'. The UN-REDD Guidelines on FPIC, which offer more details on the FPIC process, has been referenced in the footnote.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 153 | Define what level of information is needed to allow for "informed" criterion to be met, or make reference to the definition provided in the UN REDD FPIC guidelines where this is defined. Effective consent requires fully interactive participation as described by [NAME]  in Participatory Learning for Sustainable Agriculture, World Development Vol 23 No 8, pp 1247-1263, 1995. | The scope of application of FPIC is further clarified in UN-REDD guidance on FPIC which has been referenced in the footnote.
 |  | Government of Sudan | 154 | Information accessiblity should consider  illterate people by using radio and other media | This is covered by the criterion on accessibility of information
 |  | Indian Law Resource Center | 155 | It is good that this specifies that decisions must be respected regardless of whether consent is given or withheld. | Noted
 |  | Conservation International | 156 | [NAME] and 9. While CI recognizes that indigenous peoples have special rights under international law, we also feel that in regards to REDD+ FPIC should apply to both indigenous peoples AND local communities. As currently worded, the criteria refer to indigenous peoples and other forest-dependent communities. However, REDD+ may also impact indigenous peoples and communities that are not forest-dependent, for example pastoral or agricultural communities. | The scope of application of FPIC is further clarified in UN-REDD guidance on FPIC which has been referenced in the footnote.  The UN-REDD FPIC Guidelines will be clarified to define FPIC as a right for only IPs, based on international law.The guidelines will also clarify the rights of non-indigenous communities in relation to FPIC.
 |  | [NAME] and [NAME], REDD+ SES Initiative Secretariat | 157 | Criterion 9 – 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).  Why does FPIC only apply to forest dependent communities (in addition to indigenous peoples)?   What if the REDD+ program affects rights of pastoralist or agricultural communities? Need to define ‘forest dependent’.  We propose changing ‘forest dependent’ to ‘local’ communities and removing the term ‘other’ which could imply that FPIC only applies to forest dependent indigenous peoples.  This should be adopted throughout the SEPC and BeRT. | The scope of application of FPIC is further clarified in UN-REDD guidance on FPIC which has been referenced in the footnote.  The UN-REDD FPIC Guidelines will be clarified to define FPIC as a right for only IPs, based on international law.The guidelines will also clarify the rights of non-indigenous communities in relation to FPIC.
 |  | Global Witness | 158 | FPIC should apply not only to indigenous peoples and forest-dependant communities but to all local communities with significant relationships to natural resources. | The scope of application of FPIC is further clarified in UN-REDD guidance on FPIC which has been referenced in the footnote.  The UN-REDD FPIC Guidelines will be clarified to define FPIC as a right for only IPs, based on international law.The guidelines will also clarify the rights of non-indigenous communities in relation to FPIC.
Criterion 10 | Ensure there is no involuntary resettlement as a result of REDD+ | [NAME], Ministry of Forests and Soil Conservation, Nepal | 159 | Any REDD+ program that requires resettlement (voluntary or involuntary) cannot be accepted. Therefore this criterion should be rephrased to reflect that REDD+ program has no resettlement of any type. | We do not agree with this - resettlement my be appropriate if it is voluntary and if consent is sought through due process.
 |  | [NAME], [NAME] | 160 | Perhaps this should also incude adequate compensation for income forgone ("ensurewhere necessary that adequate compensation for behavioural change is given") - this my apply to cases where consent has been given, but that this requires behavioural change by communities/ forest dependent groups/ indigenous communities, and that change results in a net decrease in income/ livelihood/ quality of living etc. To minimise risk of reversals adequate compensation or alternatives would need to be provided. | Accompanying guidance on this criterion should cover the best practice procedures for dealing with voluntary resettlement, drawing from existing international guidance.
 |  | GIZ | 161 | the previous should be a safeguard for this not to happen | Noted, but we wanted to emphasise the issue of resettlement based on comments received and in line with other safegaurds. Given the change in wording of criterion 9 on the coverage of FPIC, it Is important to have a criterion on involuntary resettlement.
 |  | [NAME], FCPF | 162 | One possible drawback is in the wording of Criterion #10, which comes across as a bit too exclusionary.  The notion of "involuntary economic displacement" is so broad that it is unrealistic to think that some national REDD+ strategies won't come to incorporate some element of this.  As mentioned in comment #209 in the response matrix, the challenge would be to define both the conditions under which involuntary resettlement might take place and the ways in which it would be addressed, through the provision of adequate compensation, the replacement of lost assets, and so forth. | Noted. Accompanying guidance on this criterion should cover best practice in determining whether resettlement is voluntary or involuntary, and best practice procedures for dealing with voluntary resettlement, drawing from existing international guidance
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 163 | Define the term better; what about illegal squatting situations that the local communities want to enforce better? Possibly review applicable IADB policy. The Tool lists questions on how to address resettlement but it is not clear how the tool relates to this criterion. | Accompanying guidance on this criterion should cover the best practice procedures for dealing with voluntary resettlement, drawing from existing international guidance.
 |  | Government of Sudan | 164 | Ensure there is no compulsory resettlement as a result of REDD+. | This says the same thing in our view
 |  | Indian Law Resource Center | 165 | ...or related policy initiatives or activities | We think that the focus should remain on REDD+ activities, given the scope of the SEPC
 |  |  | 166 | Any relocation of indigenous peoples or restriction of their access to their lands, territories and resources shall only procede with their free, prior and informed consent, and shall only take place after agreement on just and fair compensation and with the option for return. | Criterion 9 covers the FPIC requirement.
 |  | [NAME] and [NAME], REDD+ SES Initiative Secretariat | 167 | 20. Criterion 10 – Ensure there is no involuntary resettlement as a result of REDD+.  [NAME] resettlement (without consent) is not possible with effective FPIC so why does this need a separate criterion?  If this criterion applies to all rights holders and stakeholders (not just indigenous peoples and forest dependent communities) then FPIC logically applies to all rights holders and stakeholders. | Given the change in wording of criterion 9 on the coverage of FPIC, it Is important to have a criterion on involuntary resettlement.
 |  | Center for International Environmental Law (CIEL) | 168 | [Clarify operational requirements for ensuring no involuntary resettlement.] This criterion to ensure there is no involuntary resettlement as a result of REDD projects is critically important.  However it is unclear what operational steps will be implemented to ensure this is met in practice, and it is also unclear what steps will be taken to remedy situations where forced relocation may occur.  In order to avoid these types of situations, UN-REDD needs to monitor these type of activities, investigate, and remedy any instances of violation. | Accompanying guidance on this criterion should cover the best practice procedures for dealing with voluntary resettlement, drawing from existing international guidance.
 |  | Global Witness | 169 | The BeRT is not consistent with this criterion which does not permit involuntary resettlement. | This is noted and will be taken into account in the revision of the BeRT and/or production of any other guidance
 |  | [NAME], ClientEarth | 170 | In accordance with international obligations, the criterion should further specify that indigenous peoples must not be removed from their land without their free, prior and informed consent. It should also specify what measures would be taken if a violation of this criterion takes place. | This is covered by the criterion on FPIC. Measures taken if the criterion is violated are covered in other criteria on redress mechanisms.
 |  | Republic of the Congo | 171 | le critère 10 sera difficilement applicable dans certaines conditions c’est ainsi qu’il serait souhaitable de faire recours à la PO 04.12 (source du [NAME]) de la banque mondiale  sur la relocalisation volontaire. En effet, plusieurs activités peuvent demander le déplacement de certaines populations mais de manière [NAME] ne peut pas avoir des impacts négatifs  et peut être résolu de commun accord avec les populations dans les zones des activités nécessitant la relocalisation. [NAME] en exergue un cadre de politique de relocalisation des populations (CPRP). Google Translate translation: 10 will be the criterion difficult to apply in certain circumstances is how it would be desirable to make use of PO 12.4 (source of the Policy Framework for the relocation of populations) of the World Bank on the voluntary relocation. Indeed, several activities may require the displacement of populations, but negotiated so it can not have negative impacts and can be resolved by mutual agreement with the people in the areas of activities that require relocation. it will highlight a policy framework for the relocation of populations (CPO). | The criterion does not say that populations cannot be displaced, only that this must happen voluntarily.
Criterion 11 | Respect and protect traditional knowledge and cultural heritage and practices | International Forest Carbon Association Working Group 2 - REDD+ Policy | 172 | Integrate traditional and local ecological, tenurial, and climatological knowledge into forest management and MRV through the use of participatory mapping and similar knowledge management tools | Traditional knowledge and cultural heritage and practices are covered in the criterion. Accompanying guidance and other documents can go into further details.
 |  | EarthChild Institute | 173 | An integral component of indigenous culture is indigenous knowledge. The particular relationship of indigenous knowledge and traditional education and schooling is however less well understood. A number of studies in recent years have revealed the existence of a tension between the two, and a review of the evidence points in both directions. The United Nations’ stance on this, however, is markedly in support of the view that the acquisition and transmission of indigenous knowledge and languages continue to be significantly undermined by traditional education models perpetuated by a number of exogenous actors. Indigenous children best hope for maintaining the traditions of their peoples and protecting the forest ecosystems thus ensuring the well-being of all children worldwide.  There is clear evidence of the dynamic properties of indigenous knowledge systems and, by extension, their potential to develop pro-environmental attitudes and action. In addition there exists a growing body of literature that has explored the impact of declining indigenous knowledge on ecological diversity, and while further research is needed in this area, it is hardly a stretch to assume the loss of indigenous knowledge has inevitable consequences for natural resource use, consumption and management.  Education systems must be both formal and non-formal, leveraging key features of indigenous knowledge to ensure protection of direct and indirect ecosystem services. | Noted.
 |  | Indian Law Resource Center | 174 | With regard to indigenous peoples, this should state "Respect and protect the cultural rights of indigenous peoples, including rights to traditional knowledge, practices and resources, rights to revitalize their spiritual and religious traditions, and rights to access in privacy their religious and cultural sites, as consistent with the UN Declaration." | We feel that this criterion shoud have broader coverage. Reference to the UN Declaration is made in the introduction to the SEPC and further references are made within accompanying guidance and other UN-REDD guidance.
 |  | Rainforest Foundation Norway | 175 | including traditional livelihoods and customary use of forest land and resources | This has been included in the footnote
 |  | Forest Peoples Programme | 176 | clarify that protection and respect apply also to traditional livelihoods and forest management/conservation practices - Moreover, In iine with our comments on the UNREDD draft FPIC guidelines, in addition to draft Criterion 11, FPP wishes to recommend some additional elements to safeguard local livelihoods under Principle 3 by adding a further criterion as follows:  Criterion (bis) -  Respect and protect traditional livelihood practices, including customary use of forest land and resources | This has been included in the footnote
 |  | [NAME], ClientEarth | 177 | In accordance with international obligations, we suggest the criterion further clarifies that benefits from this knowledge are fairly and equitable shared. | This has been included in the footnote
Principle 3 | Promote and enhance forests’ contribution to sustainable livelihoods | Ms. [NAME], JICA | 178 | Promote and enhance forests’ contribution to sustainable livelihoods and poverty alleviation.  (The objective is to highlight the need to address poverty alleviation, and to include it in the list that some people might use as a list to ‘tick off’ against.) | Poverty reduction has been included
 |  | GIZ | 179 | The FAO forest defintion is introduced without a reference to the UNFCCC definition. Has UN-REDD Programme decided to adopt the FAO definition and have any partner countries adopted it subsequently? | No, there has been no such decision. Please see revisions to [NAME], which clarify that the definition of relevance is the nationally adopted definition.
 |  | The Royal Botanic Gardens, Kew | 180 | Although ecosystem services are referred to broadly in later Principles and Criteria, it may be appropriate to make specific reference here to the maintenance and enhancement of ecosystem services contributing to local livelihoods (as part of Criterion 13 or as a separate criterion). | Principle text now shortened. A definition of sustainable livelihoods has been included in the glossary – this includes the notion of natural capital and therefore the links between forests and livelihoods that was in the original text for the principle.
 |  | Global Witness | 181 | If this principle is meant to safegaurd the livelihoods of indigenous peopes and local communities, these groups should be specifically referenced. The term "relevant stakeholders" is defined broadly and would appear to give equal consideration to a range of groups whose rights are typically not considered in need of safeguarding, with the exception of only the "most vulnerable and marginalized" groups. | This is reflected in the criteria
 |  | [NAME], ClientEarth | 182 | We suggest considering a criterion or for current criterions to include a reference to providing access for local communities and indigenous peoples to forest resources and relevant markets in order to support livelihoods and income diversification from forest management. | We feel that this is covered by criterion 13 and in the glossary definition of sustainable livelihoods, which includes consideration of natural capital. Specific strategies (e.g. income diversification from forest resources) will need to be covered in any further context specific guidance.
Criterion 12 | Ensure equitable, non-discriminatory and transparent benefit sharing and distribution among relevant stakeholders with special attention to the most vulnerable and marginalized groups | WWF | 183 | It would be important to state and clarify State Parties should ensure appropriate legislative, administrative or policy measures are in place. It would be important to clarify what is the basis for equitable and non-discriminatory sharing - such as rights, costs, and relative risks. | Equitable benefit sharing is addressed in criterion 12, and stakeholder rights  are addressed under Principle 2.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 184 | the issue of beneficiaries and the distribution of benefits must be resolved through an open and transparent process at the beginning of a forest carbon project. Benefits should be determined using fully interactive participation as described by [NAME]  in Participatory Learning for Sustainable Agriculture, World Development Vol 23 No 8, pp 1247-1263, 1995. | We feel that this is covered in criterion 4 dealing with participatory processes and the required stakeholder engagement guidance of the UN-REDD Programme. The analysis of benefit sharing systems can be covered in further guidance linked to this criterion
 |  | EarthChild Institute | 185 | Children and young people in forest communities are most vulnerable, yet conversely can be most beneficial to long-term sustainability through integration of participatory environmental education for sustainable development in REDD+ forest regions. | Noted, but we feel that the point made is not directly relevant in the context of this criterion. Education is an aspect of criteria on information and participation.Participation of relevant stakeholders is addressed in Criterion 4, and youth is included as part of the 'most vulnerable and marginalized groups' which will be given particular attention.
 |  | Indian Law Resource Center | 186 | Benefit‐sharing must respect the property and cultural rights of indigenous peoples as well as their rights of self‐determination consistent with international law, including the UN Declaration. | The criterion on FPIC and UN-REDD FPIC guidelines also cover this issue.
 |  |  | 187 | The Principles and Criteria and BeRT are silent with regards to contracts. The BeRT should provide guidance on contract fairness. Governments must take effective measures to prevent swindling or duress of communities regarding any REDD projects. No contracts should lead to the taking of indigenous peoples' lands or resources. Any contracts should be of short duration, reviewable, and should not require indemnity by the community. Local communities must have access to legal assistance in contract issues. Contracts with indigenous peoples should include a clause prohibiting human rights violations. | We feel that the specific details of contracts should be dealt with in accompanying guidance for the criterion, rather than in the criterion itself which is broader than just benefit sharing through contracts.
Criterion 13 | 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 | WWF | 188 | Considering the P&C frequently target indigenous peoples and other forest dependent communities, impacts on cultural well-being should be also included. A cultural assessment process should also be incorporated. Such process is included in Akwé: Kon Guidelines. | We consider the definition of social well-being to include th concept of cultural well-being. How social/ cultural assessment is carried out is covered by some of the other criteria (e.g.criterion 4 on participation) but can also be elaborated in further guidance on assessing potential impacts of REDD+
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 189 | recognize the social impacts of the substitution for payments of subsistence activities of forest dwellers; forest communities will tend to be highly self-sufficient, if cash-poor; a sudden transition to a currency-based economy has the potential to be highly disruptive; perhaps more significantly, it will make such communities subject to exploitation in forms against which they may have no cultural defense. Education, legal and regulatory safeguards, and technical support may be required. | The definition of benefits in the glossary recognises that they may not be only financial. The risks of such a transition will need to be highlighted in accompanying guidance.
 |  | EarthChild Institute | 190 | Allocation of a percentage of REDD funds flowing to such integrated school programs will reduce risk and yield social, economic and environmental benefit for all parties concerned. | We feel that consideration of such approaches should be covered in more detailed guidance on this criterion
 |  | Government of Sudan | 191 | High consideration to win-win approach, socio-economic development  and REDD+ should meet the stakeholders needs during 15 years as minimum. | Economic and social well-being is being addressed in the criteria. The detailed timeframe of REDD+ has to be discussed in other guidance.
 |  | Rainforest Foundation Norway | 192 | include notion that traditional livelihoods should not be undermined | This is included in criterion 11 on traditional knowledge
 |  | Global Witness | 193 | Suggest deleting "while minimizing adverse impacts on", which is implied by "protect and enhance". | This has been removed as suggested
 |  | Forest Peoples Programme | 194 | this should include : taking into account indigenous peoples’ visions (or development plans) and concepts (where this applies) | This has bee incorporated into the footnote
Principle 4 | Contribute to low-carbon, climate-resilient sustainable development policy, consistent with national development strategies, national forest programmes and commitments under international conventions and agreements | WWF | 195 | ["]Contribute to low-carbon, climate-resilient sustainable development policy and mitigation plans, consistent with national development strategies, national forest programmes and commitments under international conventions and agreements["] WWF strongly suggests to create also a link to other mitigation plans | We think mitigation plans are covered under Criterion 14, and do not need to be included in the Principle. Climate policy is included under international commitments.
 |  | The Royal Botanic Gardens, Kew | 196 | This is a rather broad principle - it might be better to separate sustainable development from climate change resilience/adaptation.  Given that carbon is intrinsic to REDD+, is it necessary to include low-carbon in the text of this principle? | The objective is to ensure coherence with other aspects of climate policy (see Criterion 14).
Criterion 14 | Ensure consistency with and contribution to national climate policy objectives, including mitigation and adaptation strategies and international commitments | [NAME], RECOFTC | 197 | Ensure consistency with and contribution to national climate policy objectives, including mitigation and adaptation, synergies between these, and strategies and international commitments | Whilst ideally REDD+ programmes would enhance synergies between mitigation and adaptation, we feel that this point is covered by consistency with policy objectives.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 198 | This favors a nested approach, in which discrete local carbon projects can contribute to, and benefit from, a national framework, provided such a framework is developed in a consultative fashion that incorporates local interests and needs. | This is possibly true, but it also applies to programme scale planning and action.
 |  | Government of Sudan | 199 | Community based adaptation and mitigation should be included . | Given that the Principle refers to national scale policies, it seems appropriate that the criterion does too. These objectives will be addressed within the revised BeRT.
Criterion 15 | Address the risk of reversals of REDD+ achievements, including potential future risks to forest carbon stocks and other benefits to ensure the efficiency and effectiveness of REDD+ | [NAME], [NAME] | 200 | Perhaps leakage should also be refered to under "reversals" | "Reversals" specifically refers to the emission of carbon that has been sequestered or judged secure, i.e. "focal carbon", rather than carbon which is not the focus of REDD+ action, which is what leakage generally refers to.  Given that there are other criteria addressing indirect impacts, it might be less confusing to leave leakage there.
 |  | GIZ | 201 | That is one of the  technically most challenging issues. No information is provided on how to do that. A good example is the VCS Non-permanence risk tool. | This should be included in the relevant section of the BeRT.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 202 | How: Insurance? Buffers?  Build adaptation strategies into REDD+ project design. | Recommendations of this sort belong in the BeRT.
 |  | EarthChild Institute | 203 | If approximately five percent of the world’s 2.2 billion children were to plant five trees per month, investing on infrastructure for the care of children would allow a return on the investment of more than 11 percent. According to our model, the Net Present Value of such an investment would equal 553 million USD over 25 years.  Today’s children have an important role to play in the planet’s future. Educating them on the environment and sustainable practices is one of the best investments we can make to ensure a healthy planet for coming generations. | Noted.
 |  | Government of Sudan | 204 | REDD+ reversal impact drivers should include the drivers in short term; medium term and long term | These drivers should be addressed in BeRT.
Criterion 16 | Ensure consistency with and contribution to national poverty reduction strategies and other sustainable development goals (including those outlined under the Millennium Development Goals framework), including alignment with ministries’ and sub-national strategies and plans that may have an impact on, or be affected by the forest sector and/or land use change | International Forest Carbon Association Working Group 2 - REDD+ Policy | 205 | Taking into account comments given in Criterion 13, incorporate strategies for a safe transition from subsistence to a cash-based economy when benefit-sharing is in the form of payments, including mobilization of legal and regulatory safeguards, education, and technical support to forest communities. | The definition of benefits in the glossary recognises that they may not be only financial. The risks of such a transition will need to be highlighted in accompanying guidance.
 |  | EarthChild Institute | 206 | National policies and practices that promote investment in human capital and an active citizenry, can, in the long run, reduce poverty, increase access to primary education, environmental sustainability, improve child health and promote regional peace and stability.  New research proves that human capital formation (a population’s education and health status) plays a significant role in a country’s overall economic development, but that this development is also sustainable when citizens are informed and active participants in their governments.    A single year of primary school can increase the wages people earn later in life by 5-15%. For each additional year of secondary school, an individual's wages increase by 15-25%.  We also know that educated communities are far better able to utilize new and emerging technologies that in turn boost productivity, profits and wages. | Noted.
 |  | Government of Sudan | 207 | Add: national alternative energy plan, sustainable livelihoods and mainstream gender. | Will ensure these are covered in the BeRT.
Criterion 17 | Ensure consistency with and contribution to national biodiversity conservation policies, other environmental and natural resource management policy objectives, national forest programmes, and international commitments | WWF | 208 | Considering the relevance of REDD+ biodiversity safeguards to support achievement of CBD Aichi Targets and other global, regional or national biodiversity obligations, it is important to add national biodiversity strategies and action plans and keep other policies. Proposed language: "…contribution to National Biodiversity Policy and Action Plans (NBSAP) of the CBD and other national biodiversity conservation policies,..." Other biodiversity-relevant international obligations are captured by the wording at the end of the sentence on  "...international commitments." | This is a good point, and text on NBSAPs has been added. This is also covered in the BeRT.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 209 | In particular, reduce the overhead costs of implementing a wide range of agreements and commitments through support for local capacity to monitor, e.g. through parataxonomy programs, and through enhanced use of community-based natural resource management wherever appropriate. | This point will be addressed in the BeRT.
 |  | Indian Law Resource Center | 210 | Those international commitments include respect for the rights of indigenous peoples to permanent sovereignty over their natural resources, including the rights of self‐government and control over natural resources as consistent with the UN Declaration. | Yes, however these issues should be covered by the criteria that explicitly address such rights ([NAME], 7, & 9).
Additional suggested criteria under Principle 4 |  | GIZ | 211 | Under this principle, country leadership should be included as a criterion. | Adjusting national leadership is beyond the scope of the REDD+ programme.
Principle 5 | Protect natural forest from degradation and/or conversion to other land uses, including plantation forest | GIZ | 212 | There are no UNFCCC definitions of Natural forests and degradation. The definitions provided in the glossary should be flagged as FAO definitions, subject to future decisions of the COP. | These definitions have been updated to reflect the current FAO definition of 'naturally regenerated forest', as it also has no current definition for natural forest, and cited appropriately.  We agree that this may have to be revisited if UNFCCC agrees a definition for natural forest.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 213 | add the word "to" before "plantation forest" to clarify the meaning of this sentence. | The Principle wording has been shortened so this comment is no longer relevant; the Criterion 18 now refers to planted forest
 |  | EarthChild Institute | 214 | School based tree nurseries provide a sustainable solution for REDD projects meeting the need to care for saplings for initial 3-5 year period until they can be planted in the forest, while simultaneously functioning as a platform for action based learning, fostering confidence and competence among the children and their families. School-grown saplings sold to the forest project will generate a sustainable source of funds to the school for continuing improvement of learning environments and infrastructure. Further, by using strategic planting methods that correspond to the region, ecosystem-derived benefits can be enhanced. Benefits may include prevention of flooding and erosion and the promotion of biodiversity. | Noted.
 |  | The Royal Botanic Gardens, Kew | 215 | Should leakage be dealt with here?  Perhaps that is what Criterion 20 refers to, but if so should it specify off-site? | Leakage is dealt with in criterion 20, the criteria under Principle 6 and associated glossary entries.
 |  | Government of Pakistan (Sindh testing) | 216 | Protect natural forest from degradation and/or conversion to other land uses, including plantation forest comments: Yes this is a good idea but how to do in real world?  Step one is that we all agree to i) not convert natrual forest to plantation or other land uses like housing or agriculture, ii) convert low  forests of low economic value  like thorn forest or even range lands conversion  to high value irrigated plantations is one way to meet the demands of a rising population. This may be true for REDD not for REDD plus as Pakistan cannot sustain its high population and meet their demand from low value natural forests. Where is the balance then : it could be that we retain (conserve) 15 percent of our land area of each taxonmoic group reagardless of its economic value as provided in CBD's GSPC Global Strategy for Plant Conservation. The remaining area can be used for conversion to plantations. This can be allowed if we take care not to plant exotics . | REDD+ should reduce deforestation emissions as compared to "business as usual". This presumably includes emissions from the conversion of  'low forest of low economic value'. Use of  REDD+ funds  to support plantation development on these natural forests would not be consistent with this Principle.
Criterion 18 | 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 | [NAME], Ministry of Forests and Soil Conservation, Nepal | 217 | Ensure that REDD+ activities  conserves natural forest 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 important to explicitly discourage the conversion of natural forest by REDD+ activities, in line with the Cancun safeguards.
 |  | [NAME], RECOFTC | 218 | 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) in forms that do not adversely affect local livelihoods a REDD+ priority | We agree with this intention, but feel this is captured in Principle 3 and its Criterion 13.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 219 | Take into account energy and food security issues of forest communities and adjacent communities; loss of forest lands for agriculture for example may result in displacement to other non-REDD areas with net losses to biodiversity. | We agree that this is important. The needs of local communities are covered under Principle 3, and  displacement is covered in Principle 7 on non-forest lands.
 |  | Government of Sudan | 220 | It should be consider each country's needs to afforestation as means to livelihood, such as in South Sudan and Congo, the top priority is to meet the people basic needs by cutting the trees. The focus should be how to meet the REDD+ activites and local people's needs, though promoting new sustainable livelihoods, intensive for social development and reducing forest degradation (not to be chnaged to other land use , extraction of fuel for local people is a part of the natural ecosystem , moreover extraction of some of deadwood and grasses enhances natural regeneration and reduces fire risk) | See comment 219.
 |  | [NAME] and [NAME], REDD+ SES Initiative Secretariat | 221 | Criterion 18 – Ensure that REDD+ activities do not cause the conversion of natural forest ‘or other areas important for biodiversity and ecosystem service priorities’ 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.  Why restrict this to conversion of natural forest when it should also apply to other critical ecosystems of importance for maintaining and enhancing biodiversity and ecosystem services. | We propose to continue to address this issue separately and with slightly less weight in Principle 7 on non-forest land. REDD+ cannot prioritise the protection of non-forest ecosystems per se, but REDD+ itself should do little harm to non-forest ecosystems. See also comment 217.
 |  | Center for International Environmental Law (CIEL) | 222 | [Clarify operational requirements for ensuring no natural forest conversion.] Criterion 18 ensures no natural forest conversion to other uses such as plantation forest due to REDD activities, which is important and required as a matter of the UNFCCC REDD safeguards. However, it is unclear how this will be operationalized.  How will UN-REDD ensure that if/when forests are replaced by plantations, the UN-REDD programme did not contribute to this conversion?  Without an effective mechanism to monitor activities and take corrective action where appropriate, it unclear how this criterion can be ensured in practice. | See comment 3 on clarifying purpose and application.
 |  | The Royal Botanic Gardens, Kew | 223 | Perhaps better to split 18 and 19 diffently, with one criterion  specifying that REDD+ programmes should prioritise the reduction of conversion and degradation (e.g....), and the other criterion specifying that Programmes should ensure that REDD+ activities do not cause conversion or degradation of natural forest. | We feel that it is  useful to address degradation and deforestation separately because of qualitative differences between the two in (a) clarity and acceptance of existing definitions and monitoring methodologies, and (b) the causes and actors involved.
 |  | Global Witness | 224 | The BeRT should clearly identify the need to distinguish between natural forests and plantations. | The BeRT does clearly identify this need.
 |  | [NAME], ClientEarth | 225 | We suggest reference to mechanism that would operationalise this criterion, such as through monitoring of activities. | See comment 3 on clarifying purpose and application.
Criterion 19 | 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 | GIZ | 226 | Exclude degradation of natural forest by REDD+ activities and make… | We propose the use of 'avoid or minimise'. The total exclusion of the degradation of carbon stocks is considerably challenging, as it implies no net removals. Interventions to limit deforestation pressure on forests might still result in forest degradation - e.g. the encouragement of the use of forest products by communities. See also comment 246.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 227 | Taking into account the complexity of transitioning communities away from subsistence uses linked to degradation, consistent with comments to Criteria 13 and 16 above.  Address energy and food security requirements of forest communities and of communities adjacent to forest areas. | Where pressure on forest comes from local people, addressing energy and food security needs is an essential part of REDD+. The BeRT will address this.
 |  | Government of Sudan | 228 | Suggestion: instead of using  only infrastructure development, it could be more better using physical developments. | The glossary now defines infrastructure development as including more than just transport (other physical developments). We accept that this word has different uses.
 |  | Global Witness | 229 | This criterion needs to be stronger. As we have previously noted, REDD+ activities should not increase forest degradation, but rather should reduce or prevent it, with prevention particularly imporant in intact forests and with regards to acivities such as industrial timber extraction that cause significant and widespread degradation. This criterion should be revised and the BeRT should incorporate these considerations. | See comment 226.
 |  | [NAME], ClientEarth | 230 | REDD+ activities should not result in degradation of natural forests if they have been well constructed. Thus the criterion should aim at no degradation as a direct result of REDD+ activities while reducing degradation due to other causes | See comment 226.
Criterion 20 | Minimise indirect land-use change impacts of REDD+ activities on forest carbon stocks, biodiversity and other ecosystem services (including impacts of extractive activities) | GIZ | 231 | "indirect land use change" is actually displacement of activities. UNFCCC compliant wording should be used. | UNFCCC text covers 'displacement of emissions', which is a result of displacement of land-use change (indirect land-use change).  'Displacement of activities' risks confusion with REDD+ activities.  We feel that the glossary adequately defines indirect land-use change.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 232 | Take into account the linkages between land cover change, land disturbance, and the spread of invasive alien species, which can have a detrimental effect on forest health and carbon stocks. In particular, take a precautionary approach to the unintentional introduction of alien species, including incorporating early detection and rapid response to biological invasions in MRV protocols. | The risks of invasives will be covered in the BeRT.
Additional suggested criteria under Principle 5 |  | [NAME], ClientEarth | 233 | We suggest inclusion of a criterion related to the need to ensure effective law enforcement to combat and eradicate illegal forest-related practices. | This is addressed in specific terms in the BeRT questions on the effectiveness of existing measures. It is also addressed in general terms in Criterion 5 (now "Promote coordination, efficiency and effectiveness among all agencies and implementing bodies relevant to REDD+"). See also Criterion 17.
Principle 6 | Maintain and enhance multiple functions of forest to deliver benefits including biodiversity conservation and ecosystem services | WWF | 234 | Sustainable livelihoods should be included amongst the benefits. | Sustainable livelihoods are covered in principle 3 and defined in the glossary.
Criterion 21 | 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 | WWF | 235 | Add highlighted text in the following phrase: 'in relation to local and other stakeholders’ values and natural resources' sustainable uses. | We feel that this is implicit within the synergies and tradeoffs.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 236 | Benefits should be determined using fully interactive participation as described by [NAME]  in Participatory Learning for Sustainable Agriculture, World Development Vol 23 No 8, pp 1247-1263, 1995. | Noted. We feel that the exact mechanisms for determining benefits should be further elaborated in accompanying guidance. Participatory approaches are (an important) one of a number of approaches that need to be considered depending on the context.
 |  | EarthChild Institute | 237 | Forest ecosystem services are inextricably linked to water and food, as well as the security and health of children, their parents, and the community at large. A strong association can be found between food insecurity and primary education. More than one third of all children in the world are malnourished and 6 million children a year die of causes related to malnutrition. | Noted.
 |  | Government of Sudan | 238 | Co-benefits | We prefer to spell this out as 'ecosystem services and biodiversity conservation' for increased clarity. Note also that UN-REDD uses the term 'multiple benefits' rather than 'co-benefits'.
 |  | [NAME], ClientEarth | 239 | We suggest considering the importance of promoting conservation and sustainable use of biological diversity through coordination and integration of relevant sectoral or cross-sectoral plans, programs and policies, which not be limited to land-use planning. | Yes; we feel that this is addressed in Principle 4, Criterion 17 and through associated material in the BeRT.
Criterion 22 | Ensure that planted and natural forests are managed to maintain and enhance ecosystem services and biodiversity important in both local and national contexts | [NAME], Ministry of Forests and Soil Conservation, Nepal | 240 | Ensure that forests' resources are managed to maintain and enhance ecosystem services and biodiversity important in both local and national contexts | Through the present language, we were aiming to emphasise that this should include planted forest as well as natural forest.
 |  | WWF | 241 | The enhancement of biodiversity in forest management must also contribute to the global CBD Aichi targets. Suggested language:  …national contexts as well as contributing to achieve global biodiversity conservation targets. | See comment 239.
 |  | Government of Sudan | 242 | Add sustainably - managed | We feel that this is by definition sustainable management.  An explicit connection to the "sustainable management of forest" will be made in the BeRT.
 |  | [NAME], ClientEarth | 243 | Is important to consider how to operalizationalise this criterion. We suggest reference to mapping, categorization and monitoring of forests. | The relevant sections of the BeRT do, or will, address these issues.
Additional suggested criteria under Principle 6 |  | WWF | 244 | Further to our comments on version 2 of the P&C, we feel it is important to provide an additional criterion to address the risks and benefits associated with forest restoration such as : “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.” We note your response to comment 341 in the comments matrix and acknowledge that it is difficult to make this an absolute requirement, however the wording of our suggested criterion allows some flexibility, whilst addressing the very real risks that REDD+ could create perverse incentives such as focusing on species that are associated with high carbon stocks but poor biodiversity outcomes. | Thank you for taking a look at the previous responses - it is helpful to have an ongoing dialogue. We do feel that restoration is covered by Criterion 22 on planted forest. We will include further relevant guidance along these lines in the BeRT.
Principle 7 | Minimise adverse impacts (direct and indirect) on non-forest ecosystem services and biodiversity | [NAME], Ministry of Forests and Soil Conservation, Nepal | 245 | A separate criterion should be added to highlight that REDD+ program leads to the conservation of biodiversity at all level and contributes in  implemeneting National biodiversity strategy and action plans | This has been addressed in Principle 4, Criterion 17 - see  comment 208.
 |  | WWF | 246 | Principle 7 should be guided not only from the goal to minimise adverse impacts, but to avoid adverse impacts first. This is linked to the EIA approach; therefore proposed language in priciple 7 and the followed criterion: "Avoid or minimise…" | This changes the emphasis rather than the meaning. We have accepted this suggestion and will use it more widely.
Criterion 23 | Minimise adverse impacts on carbon stocks, biodiversity and other ecosystem services of non-forest ecosystems resulting directly from REDD+ activities (such as afforestation) | WWF | 247 | Avoid or minimise… | See comment 246.
 |  | International Forest Carbon Association Working Group 2 - REDD+ Policy | 248 | In particular, take a precautionary approach to the intentional introduction of alien species, including appropriate risk assessments to ensure that afforestation activities do not result in collateral forest degradation | See comment 232.
Criterion 24 | Minimise indirect land-use change impacts on carbon stocks, biodiversity and other ecosystem services of non-forest ecosystems (including impacts of extractive activities) | WWF | 249 | Avoid or minimise… | See comment 246.
Criterion 25 | Minimise other adverse indirect impacts on biodiversity and carbon stocks of non-forest ecosystems, such as those resulting from intensification of land use | WWF | 250 | Avoid or minimise…   To achieve language consistency with criterion 23 and 24 "ecosystem services " should be added: "…on biodiversity, ecosystem services and …" | We have merged [NAME] and 25; see also comment 246.
 |  | Government of Sudan | 251 | Applying REDD+ in the land that has been degradated  by mechanized agricultural schemes could recover and rehabilitate, the land quickly. | Noted, and we will ensure it is covered in the BeRT.
 |  | The Royal Botanic Gardens, Kew | 252 | This does not seem to be clearly distinct from the preceding criterion. | See comment 250.
Glossary | Most vulnerable and marginalized groups: Relevant stakeholder groups that are lacking assets for secure, sustainable, livelihoods and/or lack influence over decision-making processes including, for example, women, youth, elders and the disabled. | Ms. [NAME], JICA | 253 | Most vulnerable and marginalized groups: Relevant stakeholder groups that are lacking assets for secure, sustainable, livelihoods and/or lack influence over decision-making processes including, for example, women, youth, elders, the disable, and the poor.’ (The objective is to highlight the need to address poverty alleviation, and to include it in the list that some people might use as a list to ‘tick off’ against.) | This has been added to the glossary.
 | Forest: An area of land spanning more than 0.05 hectares with tree crown cover (or equivalent stocking level) of more than 10 percent with trees with the potential to reach a minimum height of 2-5 meters at maturity in situ. It does not include land that is predominantly under agricultural or urban land use. (FRA 2010). National definitions vary, and may be more restrictive. | Dr. [NAME], University of Leicester and Orangutan Tropical Peatland Project (OuTrop) | 254 | The range is unnecessary here - if the minimum height is 2-5 m, then it is effectively 2 m. I suggest that 2 m is too low, however, and prefer the original FRA definition of 5 m | Thank you for this useful set of comments on forest definition. The glossary has been revised to indicate the primacy of national forest definitions, and to give both UNFCCC and FAO forest definitions which these often draw on.
 |  |  | 255 | 0.05 ha is a patch of land measuring 22.3 x 22.3 m. Ten percent of trees with potential to reach height of 5 (not 2-5!) m could therefore be only one or two trees. Surely one tree cannot make a forest!!!! The minimum area clearly therefore needs to be substantially larger than this. Based on nothing more than personal impressions, I would suggest 1 ha as an absolute minimum whereby the forest can be expected to support anything like its native biota and provide any real ecosystem services (in reality, I suspect this area will be substantially higher in almost all cases) | See comment 254.
 |  |  | 256 | How is "predominantly" defined? > 50 % by area?? In light of the above, this could be 10.15 x 22.3 m….. These measurements strike me as being at least an order of magnitude out - this is barely an allotment, let alone a "forest"….! | See comment 254.
 |  |  | 257 | How is "agriculture" defined? Agriculture may or may not be compatible with maintaining forest carbon stocks and biodiversity. Clear felling of forests is one thing, but collecting and (supplemental) planting of certain crop species within a forest without conversion into an alternative land uses could be compatible with biodiversity conservation (e.g. forest fruits). Some reference to conversion and introduction of non-native species should be made here | See comment 254.
 | Natural ecosystems: Ecosystems composed primarily of indigenous species, not established by human intervention and with limited human impact. | Dr. [NAME], University of Leicester and Orangutan Tropical Peatland Project (OuTrop) | 258 | Definition of "primarily" = ?. Without robust definitions, this sort of term can be very open to abuse | "Natural ecosystems" is used here only in the Glossary entry for land use change. The issue highlighted by the reviewer is that there is potential for a country to define an ecosystem as no longer natural, so that land-use change would not be of concern. However, the land-use change definition is not restricted to natural ecosystems, so we feel that this is not an issue for the SEPC.
 | Natural forest: A forest composed primarily of indigenous trees, not established by planting or/and seeding in the process of afforestation or reforestation. | Dr. [NAME], University of Leicester and Orangutan Tropical Peatland Project (OuTrop) | 259 | Definition of "primarily" = ?. Without robust definitions, this sort of term can be very open to abuse | See comment 212 on the proposed change to the natural forest definition to use the current FAO definition for 'naturally regenerated forest'. Again, part of the issue is that degraded forests could be defined as 'non-natural'. The current definition definitely includes secondary as well as primary forests as long as they are naturally established; however, naturally regenerated forest of non-native species are also included.
 |  | GIZ | 260 | Annex I, Table 2 (key terms): define transparency, accountability, integrity in the specific glossary. | Accountability has been added to the glossary
 |  |  | 261 | A general glossary would be useful (standard issues like UNFCCC, REDD+, etc. Links to explanatory websites where appropriate) | The existing glossary has been specifically designed to cover the language used in the SEPC (or in other glossary entries). We feel that a more general glossary is likely to be surplus to requirements for our audience.
 |  | [NAME], FCPF | 262 | The Glossary of Key Terms has also developed quite nicely, and it now represents a substantial contribution to the elaboration and understanding of safeguards systems overall. | Thank you!
Annex I |  | [NAME], ClientEarth | 263 | The documents state the proposed principles were developed from the Cancun safeguards and respond to them. We suggest [NAME] I (which displays the relationship of the proposed principles with the [NAME] safeguards), better illustrate the relationship/relevance of the Cancun safeguards with the principles. Annex I currently shows how each of the Cancun safeguards are covered by the Principles and Criteria, rather than illustrating how the Principles and Criteria are relevant to ensuring REDD+ activities are carried out in accordance with the Cancun safeguards. | It is not seen as the UN-REDD Programme's role to interpret the [NAME] safeguards, so care has been taken to show this from the perspective of the SEPC rather than vice versa.