Fundamental Risk to Markets Integrity by Inclusion of Non-Greenhouse Gas Metrics

Several of the world biggest emitters have expressed the targets of their National Determined Contributions (NDCs) in non-greenhouse gas units. The current draft CMA decision in relation to Article 6.2 allows for the inclusion of non-greenhouse gas (GHG) metrics as an option for the internationally transferred mitigation outcomes (ITMOs). While there are some provisions that call for further work on providing guidance on such metrics in the current draft text, there are fundamental concerns with regard to the integrity and effectiveness of such approaches.