13 December, 2019

Fundamental risk to markets integrity by inclusion of non-greenhouse gas metrics


Climate Analytics

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.

Challenges for tracking progress against NDCs

The text allows the transfer of non-GHG metrics that are not the same as the metric used to measure the NDC. This could present challenges for tracking progress. Under the Enhanced Transparency Framework, Parties are to track progress using NDC indicators; if a Party sells a unit that is in the same unit as these indicators it will be difficult to see how the transaction affected that Party's NDC.