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IATP submitted the following response on March 6, 2023. 

Executive Summary

Since 2008, the Institute for Agriculture and Trade Policy, an accredited observer organization at the UNFCCC, has participated in each Conference of the Parties (COP) and in some of the inter-ministerials. We have engaged with the UNFCCC both as an individual non-governmental organization and as a member of the Climate Land Ambition Rights Alliance (CLARA) and the Climate Action Network (CAN). Most of our submissions to UNFCCC bodies and side events at COPs and inter-ministerials have concerned the Koronivia “Joint work on implementation of climate action in agriculture and food security” (KJWA) and Article 6 of the Paris Agreement. IATP’s most recent submission, dated 28 February 2023, concerns the Article 6.4 mechanism Supervisory Body’s work program (file attached). In our responses below to some of the GST’s guiding questions, we briefly summarize this work and attach relevant documents.


5. In order achieve the goals defined in Articles 2.1(a) and 4.1 of the Paris Agreement: a) What further action is required? b) What are the barriers and challenges, and how can they be addressed at national, regional and international levels? c) What are the opportunities, good practices, lessons learned and success stories?

Need to end the overreliance of climate action on carbon offsets and carbon removals

An indispensable starting point for “further action” is to recognize that the current state of climate science and climate modeling entail an accelerated and greater scale of actions than what was believed necessary to balance “anthropogenic emissions by sources and removals by sinks of greenhouse gases in the second half of this century.” (Article 4.1) The rapidly depleting carbon budget, given the current emissions and existing and planned fossil fuel infrastructure, indicate that there is no carbon budget for offsetting. The IPCC strongly qualifies the role removals can play to achieve the target goals defined in Article 4.1: to counterbalance hard-to-abate residual emissions. They cannot substitute emissions reductions.

It is common for proponents of emissions offset trading to state, e.g., “at this moment voluntary carbon markets remain the most effective cooperative tool to channel finance into mitigation projects and programs in developing countries. As public finance for climate finance remains shockingly scarce, it may be worth thinking twice before demonizing carbon markets.”[1] (Bold in the original) While it is true that public finance for climate action is terribly inadequate to the scale of need, it does not follow that voluntary carbon markets channel finance for effective climate action to developing countries. Indeed, according to a recent Carbon Market Watch Study, in the opaque world of VCM trading and accounting, it is exceedingly difficult to trace what share of the proceeds from VCM trading remain in developing countries for climate action.[2] For Parties and non-Parties who had counted on the Article 6.2 and 6.4 mechanisms to help achieve the balance between emissions and removals as laid out in Article 4.1 and to provide adequate and predictable source of mitigation funding for developing countries, current climate science is a shock to the system of Paris Agreement era policy assumptions.

An immediate step for further action is to incorporate into negotiating ambition and climate finance scale the Intergovernmental Panel on Climate Change’s (IPCC) clear reporting on the climate crisis and not take action based on the diplomatically massaged versions of climate science in the “Summary for Policymakers.”[3] The IPCC clearly states a continuing challenge: “Current national pledges under the Paris Agreement are insufficient to limit warming to 1.5°C (>50%) with no or limited overshoot and would require an abrupt acceleration of mitigation efforts after 2030 to limit warming to 2°C (>67%).”[4] The opportunity cost of investing in renewable energy vs. Carbon Capture and Storage has long favored renewable energy.[5] The political influence of the fossil fuel industry in advocating Party support for engineering-based removal technologies is a major challenge to achieving the Paris Agreement goals.

In addition, policy assumptions about the feasibility of compensating for long-cycle geological emissions by biogenic removals, with the assistance of financial market innovations, are put into doubt by climate science. According to the IPCC’s Sixth Assessment report on the physical science of climate change, positive emissions are not offset by negative emissions on a one-to-one ratio. Instead, climate scientists describe an asymmetry between the positive emissions of greenhouse gases and the negative emissions of carbon sinks and offsets.[6] According to a Nature Climate Change article on climate modeling findings, “Results indicate that a CO2 emission into the atmosphere is more effective at raising atmospheric CO2 than an equivalent CO2 removal is at lowering it, with the asymmetry increasing with the magnitude of the emission/removal. (IATP emphasis) The findings of this study imply that offsetting positive CO2 emissions with negative emissions of the same magnitude could result in a different climate outcome than avoiding the CO2 emissions.”[7]

Need for obligatory and transparent corporate climate disclosure under public scrutiny

A major challenge to realizing Article 2.1 goals is that non-State actors are not obligated to report their Scope 1, 2 and 3 emissions, as defined by the Greenhouse Gas Protocol. Voluntary efforts to report such emissions under the Climate Related Disclosures Task Force have been inadequate, inconsistent and incomplete. Investors have been unable to judge the scale of corporate climate financial risks to their operations, supply chains, sourcing chains and the communities in which corporate production and distribution facilities are located. The proposed rule by the U.S. Securities and Exchange Commission to require such disclosures in financial reporting has been fiercely resisted, including with threats to invalidate the rule through court challenges. IATP submitted a letter in support of the rule[8] and summarized agribusiness resistance to the rule.[9]

IATP’s climate action work relies in part on adapting climate science and climate modeling to estimate emissions from agriculture activities and propose ways to practice agriculture that would be compatible with the 1.5⁰C target in Article 2.1. One limitation of the framework for reporting Nationally Determined Contributions to Mitigation (NDC) is that nationally limited reporting does not capture non-Party emissions that may have their major emitter origin in subsidiaries located in the jurisdictions of several Parties. One sector that is not adequately represented within NDCs, but is a major source of GHGs, is the global meat and dairy sector.

Since 2018, IATP has published or co-published four “Emissions Impossible” reports, using the U.N. Food and Agriculture’s Global Livestock Emissions Assessment Methodology (GLEAM) to estimate emissions from multinational meat and dairy processing corporations.[11] Our November 2022 report focused on methane emission estimates. The results show that the industrial meat and dairy industry is highly concentrated, and large corporations have done little to contribute to mitigating the climate crisis. This report found that the greenhouse gas emissions of 15 of the largest livestock companies rival the total emissions of Germany. Those companies are also 11.1% of the world’s livestock methane emissions. These estimates are meant to provide benchmarks, not precise emissions calculations. Methodologies and applications of methodologies to estimate emissions can be improved, of course, but the first step in preventing and reducing emissions is to have accurate estimates of the scale of risk to be managed. Additionally, IATP has co-published a 2022 report on the cost of synthetic chemical fertilizers to developing countries and the corporate beneficiaries of those fertilizer sales.[12]

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