Nationally Appropriate Mitigation Actions (NAMAs) for Pakistan

3 November 2010 Nationally Appropriate Mitigation Actions (NAMAs) for Pakistan What is a NAMA A Nationally Appropriate Mitigation Action (NAMA) aims to mitigate the impact of climate change. NAMAs will be undertaken by developing countries, given adequate financial and technological support. The term NAMA emerged from the 2007Bali Action Plan, which recognized the importance of developing country participation in efforts to reduce global emissions. Even though voluntary in nature, it is assumed that all countries will undertake such nationally appropriate actions as part of their contribution to the wider challenge of climate change. Over the past three years, however, the debate around NAMAs has become exceedingly complex, politically driven and economically motivated. Developed countries believe that NAMAs should pave the way for comparable efforts by b o t h d eve l o p e d a n d d eve l o p i n g countries. Author: Farrukh Iqbal Khan Lead Negotiator for Pakistan For their part, developing countries do not feel any such obligation. The UN Framework Convention on Climate Change (UNFCCC) principle is one of common but differentiated responsibility for climate change, recognising that many industrialized nations have been emitting greenhouse gases (GHGs) for two centuries. Developing countries, including Pakistan, believe that there should be comparability in mitigation efforts amongst developed countries, rather than comparability between developed and developing countries. Pakistan was instrumental in negotiating the definition of NAMAs set out in the Bali Action Plan, as Chair of the Group of 77 and China. The Bali Action Plan defines NAMAs as: An integral part of sustainable development. This implies that NAMAs will not only be evaluated for their impact on emissions, but for additional development benefits, such as economic development, capacity building, infrastructure. Supported and enabled by technology, financing and capacity building. This implies that a NAMA is not restricted to national policies and climate action plans, but also includes concrete mitigation projects and programmes, such as energy efficiency, green transport a n d t h e u s e o f re n ewa b l e technology. Measurable, reportable and verifiable (MRV). MRV implies that NAMAs will have to meet a harmonized international standard Policy Brief November 2010

of certification and/or registration, in addition to reporting national GHG inventories. MRV systems could be nationally owned and consistent with international guidelines and/or open to international audit. Alternatively, MRV could be an international system of registration. Three years of negotiations have, unfortunately, been unable define what may, or may not, constitute a NAMA. Views still differ on the institutional structure needed to support NAMAs and on how to measure, report and verify their results. While the debate has remained somewhat vague, there has been a proliferation of types of NAMAs: The state of play Any agreement on NAMAs is tied to a global agreement on mitigation and emissions reduction. The crucial piece of this negotiation is the level of ambition on emissions reduction to be assumed by developed countries. It makes little sense for developing countries like Pakistan to agree on a NAMA framework without an agreement on quantified economy-wide emission reduction targets for the developed world; setting the level of ambition in emission reduction by major polluters; or predictable finance and technological support. Targets remain the most contentious aspect of climate change Unilateral NAMAs: mitigation actions undertaken by talks, exacerbated by the Copenhagen Accord, which is developing countries on their own voluntary and has eliminated the notion of binding obligation Supported NAMAs: mitigation actions in developing on the part of developed countries to reduce emissions. The countries supported by direct climate finance from goals submitted by the developed countries under the developed countries (known as 'directly supported Copenhagen Accord are far below what is required by science, NAMAs') or the need to limit global temperature rise to 1.5 or 2 degrees Credited NAMAs: mitigation actions in developing Celsius above pre-industrial levels. countries that generate credits to be sold on the carbon market (e.g. sectoral crediting). Many developed countries, particularly Japan, are also seeking to scrap the Kyoto protocol, the only international instrument that imposes binding emissions obligations upon them. The European Union (EU) has tied its acceptance of the second commitment period under Kyoto to strong actions by the developing countries via NAMAs. At the same time, it is unwilling to commit to a deeper target on emission reduction in the absence of similar commitment from the US. ee.swstatic.co.uk The Pakistan context In its policy statement, Pakistan has expressed its keenness in contributing to global mitigation efforts and be a part of the solution to climate change. The country at present contributes only 0.8% of total global greenhouse gas (GHG) emissions, but this is projected to double by 2020. The country's economic potential and its resulting energy needs are likely to surge its emission trajectory by 2050. At present, Pakistan's enormous energy needs and the high cost of cleaner sources of energy reinforce its reliance on cheap fossil fuels and its natural resources. The Government of Pakistan also recognizes that moving towards cleaner, renewable energy is both desirable and necessary. However, Pakistan has categorically stated that any international mitigation framework agreed to in Cancun or in the future should not constrain economic growth, given that Pakistan's first and overriding priority remains social development and poverty eradication. Put simply, the countries that must undertake the deepest cuts in emissions are asking others to do the same. Canada and the EU have said that they do not want to increase their targets until the US sets significant reductions. The EU is unlikely to revise its targets, given the changing political environment in the US. The US, however, wants a firm agreement on reductions from major emerging economies, especially China. The overall result is a lowering of targets. The individual targets set by developed countries are likely to total around 13%. Even the highest targets, of 19%, fall short of the 25-40% reduction thought to be necessary by the Intergovernmental Panel on Climate Change to hold the global temperature rise to 2 degrees Celsius. This state of play bears heavily on a NAMA agreement. Developing countries feel that any agreement on NAMAs with a low level of ambition from the developed countries would merely shift the burden of mitigation on to them, with the provision of finance used to coerce developing countries to reduce emissions, and an adverse effection their economic growth and development. This state of play suggests that Cancun is unlikely to result in an outcome on mitigation in general, or NAMAs in particular. What is likely is the crystallization of some elements pertaining to NAMAs and continued negotiations in the future. 2

NAMA issues in Cancun carbon space in the context of sustainable development. Pakistan's NAMA could focus on transformative change, such as a Feed-in-Tariffs programme, that will not only reduce emissions in the future, but help the country leap frog technologically and direct emission reduction actions such as wind farms and energy efficient infrastructure. Pakistan should not rule out the possibility of a unilateral mitigation action, with the costs borne by the Government. While such unilateral actions should be consistent with the UNFCCC, it is important for Pakistan to maintain the distinction NAMAs and unilateral actions. As a first step, Pakistan's unilateral mitigation actions can be policy-based such as laws, regulations, standards, subsidies and the creation of fiscal and trade incentives necessary to undertake NAMAs. Pakistan should also express its willingness to negotiate a framework for the recognition of unilateral actions, including those done retrospectively until 2009. Potential NAMAs for Pakistan are outlined in Box 1. Some of the key issues that COP16 will consider are: Should developing countries agree to a NAMA framework in the absence of an agreement under the Kyoto Protocol How should developing country mitigation actions since 2009 be captured Should there be enhanced reporting for developing countries Should there be a provision of international consultation and analysis for non- supported or unilateral mitigation actions Should there be a Registry to match NAMAs with sources of support, or should this have an advisory role to assist countries in securing support And where should this registry be place: under mitigation or the financial mechanism Pakistan's policy approach for Cancun Pakistan has expressed its firm commitment to undertake NAMAs as agreed under the Bali Plan of Action. In its policy statements, Pakistan has clearly stated that the term NAMA is applicable only to actions by developing country Parties that are supported by technology, financing and capacity-building. It has underlined that such actions will be voluntary in nature and will be a part of sustainable development. Pakistan has agreed that developing countries might undertake mitigation actions beyond those supported by developed countries. However, such unilateral action should be a sovereign choice made on the basis of national circumstances and capacities. These would, in its view, constitute unilateral actions that are distinct from NAMAs. Measurement, reporting and verification (MRV) In its policy statement, Pakistan has supported the establishment of an MRV mechanism comprising National Communication, a registry and an international verification audit mechanism. During the 16th Conference of Parties (COP), Pakistan's approach to MRV could comprise the following: The MRV mechanism for developing countries should be distinct from the MRV of emission reduction commitments by developed countries. The MRV for developed countries will aim at compliance and comparability, while the one for developing country NAMAs will aim at transparency in actions and abatement of GHG. There should also be a distinction between the MRV of Given Pakistan's low emission status and its economic challenges, Pakistan has stated that it is not in favour of an agreement to impose an overall emission reduction target be it voluntary in nature - for developing countries. Pakistan does not support a scenario whereby it must undertake actions on a par with those of major emerging economies, such as Brazil, China, India or South Africa. In authors view, there are six key elements for a Pakistan NAMA. NAMAs should aim to reduce emissions by the developing countries. Ideally, they should be a part of broader strategy, such as a Low Carbon Development Strategy. Pakistan should ensure that the NAMA framework remains flexible, with provisions for standalone actions that could reduce emissions. The development and implementation of NAMAs should depend on developed countries delivering on their UNFCCC commitments in terms of financial resources and technology transfers. Economic and social development and poverty eradication remain the priorities, and NAMAs must support these. NAMAs should be consistent with the UNFCCC. An agreement on a NAMA should only take place once the international community has determined the principles of burden sharing and equitable access to footprints.pbworks.com 3

supported mitigation actions and the MRV for unsupported mitigation actions by developing countries. If some developing countries seek recognition for their unsupported or unilateral mitigation actions at the international level, Pakistan should consider and domestic verification process distinct from MRV of supported actions. Only supported NAMAs should be subject to international MRV requirements. The National Communication should form the measurement and reporting (M&R)part of the MRV process, with verification conducted through an international audit. Guidelines and operational details for M&R could be redesigned while the guidelines and operational details for the verification process could be developed by 17th COP. A verification mechanism could comprise an Expert Panel established as a part of a Registry mechanism. This would have separate sections for supported and unsupported actions, and a verification panel to conduct technical assessment prior to registering the NAMAs. The Registry should come under the financial mechanism of the UNFCCC to ensure that the provision of finance and technology becomes automatic once a NAMA has been registered. Full guidelines and Terms of Reference could be elaborated between COP 16 and COP 18. Pakistan should express its willingness to discuss the process of recognizing unsupported actions, including the notion of international consultation and analysis. Overall policy approach for Cancun While there is an urgent need to cut global emissions rapidly, Pakistan's emissions are not likely to grow at a higher rate until after 2020. It is important, therefore, that the long-term perspective is not neglected. Pakistan should maintain its position to support NAMAs as an instrument that delivers strategic, long-term, transformational measures that are unlikely to be achieved through other mechanisms such as the carbon market. As such Pakistan's policy towards NAMAs could be guided by the following key concepts. Maintain the definition of NAMAs as contained in the Bali Plan of Action: NAMAs are actions that are supported. Draw distinction between domestically funded or the so called unilateral actions and NAMAs. In this regard, Pakistan should not support formalization of Appendix-II of the Copenhagen Accord which does not distinguish between the two. Maintain that emission reduction resulting from NAMAs should not count as part of the mitigation obligations of the developed countries or to offset their quantified emission reduction commitments. It should count as part of developing countries own efforts to hold temperature increases to a maximum of 2 C. This position is critical, given the extremely low level of emission reduction commitments on the part of developed countries. Any option of offset is likely to pass the burden of mitigation to the developing countries alone. 4

Express willingness to discuss the notion of international consultation and analysis, provided such a process does not impinge upon national sovereignty. Ensure that the proposed registry to record NAMAs should not be a matchmaking facility alone. It should rather be an advisory body to ensure provision of necessary finance and technology. Pakistan should maintain its position that Registry should be placed under the financial mechanism. The development of NAMAs requires a close cooperation and coordination between various ministries and institutions at a national, regional and municipal level. To warrant a full and sustainable implementation of measures, a strong ownership of all related institutions needs to ensured. In this regard, Pakistan should consider the option to establish a Agree to a Institutional framework for NAMAs dedicated national body to coordinate communication and comprising National Communication and a registry to processes related to NAMAs and their submission to the MRV supported NAMAs. However, Pakistan should UNFCCC. ensure that such a framework remains distinct from the MRV of quantified emission reduction by the developed country parties. Call for periodicity in reporting cycles of National Communication based on the levels of economic development and emissions in the developing countries. 5