ECO has found many problems in the Article 6 texts, and wants to flag four in particular: (1) the risk of absence of any consequences from the 6.2 review, (2) the open door to mark all information as confidential, (3) troubling CDM carryover loopholes, and (4) the unhelpful ‘other A6.4ERs’ terminology.
First, the Article 6 review must have some teeth. It should review the cooperative approaches (not just the consistency of information), and should not be guided by vague principles like non-intrusive, non-punitive, no ‘political judgments’, etc. The review must have consequences. Recurring and/or unaddressed inconsistencies cannot simply be ignored. No Internationally Transferred Mitigation Options (ITMO) transfers should be allowed until the review is completed and inconsistencies are satisfactorily addressed.
ECO was somewhat reassured to see that Parties want to mandate further work to define how confidential information should be reviewed. This is an opportunity to limit the current ‘free for all’ approach that allows Parties to designate any information as confidential. ECO welcomes the proposal that Parties should justify why they deem information to be confidential, but is concerned that some language remains too loose. The section on confidentiality throws the door wide-open for countries to designate any information as confidential and, given the uncertainty about what will be discussed in the future work programme, this is a risk that ECO advises against taking.
ECO is particularly troubled by text that would first carryover CDM projects allowing them to continue using their CDM methodologies potentially beyond 2025 and, on top of that, allow issuance of credits for those activities even before a new baseline methodology is approved by the Supervisory Body. Parties agreed in Glasgow that CDM activities must be reviewed for environmental integrity before A6.4ERs could be issued, but this text is a recipe for non-additional units and allowing backsliding. While ECO knows Parties should be patient to get the new methodologies right, if more hot air credits are issued, this could be one area where corrective actions will be needed.
Finally, after so many discussions about the ‘non-authorised’ A6.4ERs and the good start in Glasgow, when useful names were proposed, ECO was disappointed to see the proposition for ‘other’ A6.4ERs’ in the Article 6.4 text. This language does not clearly convey the idea that emission reductions embedded in these carbon credits are already being counted by the host country. The proposed text also does not restrict the use of these units at all and opens the door for companies to count emission reductions that have already been counted by the host country to reach an NDC. Call it what you will, but when it comes down to it, this is plain and simple double counting, and unless clarified, it will undermine the host country’s increase in ambition. ECO proposes alternative names, like ‘contribution A6.4ERs’ or ‘Paris Agreement Support Units’, and to limit the use of these ERs to results-based climate finance and domestic carbon pricing, without the open-ended loopholes.