Transparency Issues Unresolved as Glasgow Climate Summit Nears

By Toby McIntosh

Many critical “transparency” issues are unresolved in advance of the COP26 climate crisis summit in Glasgow.

The most controversial issues include:

  • What time frame should be covered in future national reports about emissions and climate change efforts?
  • What information should be included in national reports and how should it be presented?

The outcome on these and other transparency topics is still very much in doubt, according to official documents.

Although the transparency discussions often appear to run under the radar, having accurate reporting is considered important to ensuring that promises made are promises kept. It’s the details that get contentious.

The crucibles for the negotiations are two “subsidiary” bodies of the UN Framework Convention on Climate Change (UNFCCC), the Subsidiary Body for Scientific and Technological Advice (SBSTA) and  the Subsidiary Body for Implementation (SBI).

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Two Chairs Highlight the Remaining Issues

The leaders of both subsidiary bodies are expressing confidence, but documents issued in recent days chart numerous areas of agreement and disagreement. The plethora of acronyms and shorthand terms make the documents daunting to newcomers (including Eyeonglobaltransparency.net).

On Oct. 18, SBTSA chair Tosi Mpanu Mpanu issued a 17-page Informal “Options” Paper outlining many areas of continued disagreement and scheduling an “informal” Heads of Delegation meeting for Oct. 22.  A scenario note issued Oct. 8 by Mpanu Mpanu, who is from the Democratic Republic of the Congo, is 11 pages long with 76 items. On Oct. 6 he updated the pre-conference work plan. Also see provisional agenda.

A scenario note on Oct. 8 put out by Norwegian Marianne Karlsen, who chairs for the SBI, runs 20 pages with 155 numbered paragraphs. The SBI agenda is two pages with 22 items.

Both bodies met virtually for three weeks this summer. “Considerable work remains,” according to a detailed report about the May-June meetings by Earth Negotiations Bulletin. (Documents for the meetings are here.)

Negotiations are continuing at an intensifying pace.  The bodies will meet formally in Glasgow beginning on Oct. 3, with the goal of having their recommendations approved by the scheduled end of the conference on Nov. 12. (See schedule.)

Information on Progress Sketchy

There is limited transparency about the negotiations outside of the chairs’ reports.

The meetings of the subsidiary bodies are “private” under UNFCCC rules, although observers from interest groups are sometimes admitted. The Oct. 22 SBSTA heads of delegation meeting is “parties only.” The COP26 plenary sessions will be public.

The chair’s notes generally do not identify countries by name. In some cases, however, some public position papers have been submitted by countries and country coalitions.

Documents can be found on the websites for the two subsidiary bodies and the associated websites of the chairs. (See links here.) Searches on the main UNFCCC documents page turn up SBSTA and SBI documents.

Making Time Frames Uniform a Persistent, Thorny Issue

One major issue that may or may not get resolved concerns the basic building block document:  Nationally Determined Contributions (NDCs) reports.

These outlines of climate actions and goals were to be submitted every five years. Initially, parties decided for themselves what time period their NDC should cover, which resulted in asymmetric reporting.

“Some adopted a 10-year NDC, with implementation starting in 2021, up to 2030 (i.e., the European Union, China); others pursued a five-year approach (i.e., the United States); still others went for a “5 + 5” approach, with the first five-year target as a “firm” contribution, whereas the 10-year target was “indicative” (i.e., the dynamic contribution cycle) (Government of Brazil 2014),” according to a World Resources Institute summary.

To address this variation, it was agreed in Paris that by 2031 all countries would submit NDCs on the same schedule. But no uniform schedule was defined.

Up for decision again is whether the reports to be submitted by 2025 should cover: five years, 10 years, or some combination.

“Talks on carbon markets, transparency and aligning countries’ climate plans to cover a common time period of 5 or 10 years all reached “stalemate”, a senior climate diplomat told Climate Home News,” according to a June article in Climate Change News.

High-level ministerial consultations took place in Italy on Sept. 7 and Karlsen reported, “I was encouraged to hear ministers searching for a solution that would accommodate all.”

“The question Parties will need to answer in Glasgow,” Karlsen wrote in her scenario note, “is how the agreement on common time frames can be aligned with the five-year cycle of the global stocktake, while catering to each Party’s unique circumstances and ensuring the highest possible ambition.” (SBI scenario note items 61-64)

Arab Nations Back 10 Year Time Frame

In an analysis of the ministerial meeting, one analyst said the choice is boiling down to the 10-year option put forward by Saudi Arabia on behalf of the Arab Group or the five-year option supported by “everyone else who referred to such a process option.” Benito Müller, Managing Director, European Capacity Building Initiative, was describing the meeting (viewable online), in a blog post of Sept. 13.

Müller reported:

“To be clear, Saudi Arabia did not insist that everyone adopt a 10-year time frame, but only that developing countries be given the flexibility to choose between a ten-year and a five year one, with developed countries required to adopt the latter. While one may well wonder why only developing countries are meant to be given this flexibility (could it be because the 5-year Option is recognised as intrinsically better for the planet?), the real question must be whether developing countries are actually interested in having that flexibility; and the answer, judging from the relevant group interventions at the consultation (see below), is most likely negative.”

“Yet,” Müller continued, “there are clearly some who would like to be able to choose [the 10 year option].” He said that Hugh Sealy from Barbados had suggested having countries communicate a 2035 NDC and a 2040 NDC, and repeat them every five years.

Chair Described Eight Options, Five Years Most Favored

Eight options are described in an informal note from June 16 by SBI Chair Karlsen. She did not summarize options in her October scenario note, though she commented, “I trust that a political solution to this issue is within reach….”

A shorter time frame, advocates say, would require countries to more frequently update their NDC targets. “Having all countries use the same time frame means that countries are thinking about the same near-term period, building a sense that action is being taken together,” according to goals set out by a coalition on environmental groups, Allied for Climate Transformation by 2025 (ACT2025).

The most recent NDCs were to have been be submitted in 2020, but the deadline was delayed after COP26 was postponed a year by the Covid-19 pandemic. Many, but not all NDCs, have been submitted in advance of the Glasgow meeting. (See the UNFCCC’s NDC Registry.) “Almost all Parties provided the information necessary for clarity, transparency and understanding of their NDCs….” according to a Sept. 17 UNFCCC synthesis report.

For more background on the time frames issue, see 2020 UPDATE Negotiating cooperation under Article 6 of the Paris Agreement by the European Capacity Building Initiative (with a good bibliography), Highlight a WRI paper and a 2019 WRI article, a 2018 OECD analysis, resources by the Partnership on Transparency in the Paris Agreement, a UNFCCC description of the process and NDC Synthesis report of Sept. 17. Another is planned for Oct. 25. A PowerPoint presentation from September 2020 by Katia Simeonova, former transparency manager at the UNFCCC Secretariat, is acronym-heavy but informative.

The NDC Transparency Check published by the NGO Climate Transparency as part of its 2021 assessment of NDCs assesses the quality of each national NDC “relating to whether a party’s communication is clear, transparent, and understandable.”

Additional Transparency Reporting Details Not Resolved 

There appears to be plenty of work to do if progress is to be made on the rules for uniform national reporting, a concept endorsed under the Enhanced Transparency Framework (ETF) of the Paris Agreement.

The SBSTA said it is engaged in discussions on five transparency-related topics:

  • common reporting tables (CRTs) for national inventory reports;
  • common tabular formats for tracking progress on NDCs;
  • common tabular formats for the electronic reporting of support;
  • outlines of the biennial transparency report (BTR), national inventory document (NID), and technical expert review report (TERR); and
  • a training program for technical experts participating in the technical expert review.

SBSTA Chair Mpanu Mpanu, in his scenario note, indicates that he has heard concerns about “the urgency” of finalizing work on systems and tools for reporting and reviews to facilitate the submission of biennial transparency reports, including the common reporting tables and common tabular formats, by the target date of 2024.

“I have also heard, particularly from developing country Parties, a need for enhanced capacity-building efforts to enable the use of reporting tables and formats, including the use of reporting software tools.” (SBSTA 60) “I understand that these discussions are detailed and the volume of remaining work is significant.” he wrote in the Oct. 11 note, going to describe plans for establishment of a “contact group” to work on the issues. (SBSTA scenario note 61-64)

Annex I Parties, developed countries, are already required to report on national GHG inventories using a set of Common Reporting Formats (CRFs).  Non-Annex I Parties are not required to use a common set of tables.

Mpanu Mpanu appears to have doubts about whether conclusions can be reached on basket of “methodological issues” affecting developed countries. (SBTSA scenario note 57) Subjects include “common metrics to calculate the carbon dioxide equivalence of greenhouse gases” and “emissions from fuel used for international aviation and maritime transport.”

Mpanu Mpanu pledged to consult with Parties “to see whether there are realistic prospects of making progress or reaching substantive conclusions on this item, including its sub-items, at this session.”

The UNFCCC on Oct. 14 issued a 20-page report to SBSTA providing information on activities relating to GHG inventory reviews conducted in the 2020 and 2021 review cycles and plans for the 2022 review cycle. The UNFCCC held an Information Event on Transparency (Part I) on Aug. 24 and Information Event on Transparency (Part II) on Aug. 25. There don’t appear to be recordings of the sessions, but numerous background documents and a few country presentations are provided.

The outcome of the transparency talks are likely to affect the global “stocktake” to by done the UNFCCC, the first  in 2023, to assess the state of implementation and collective ambition.

In preparation, the chairs of the subsidiary bodies on Oct. 20 put out draft guiding questions, 18 of them, for “the Technical Assessment component of the first Global Stocktake.”

Building the Enhanced Transparency Framework

The Subsidiary Body for Implementation (SBI) is expected to conclude “technical work” that will guide the enhanced transparency framework under the Paris Agreement (Article 13)  that will be superseding the existing international assessment and review process.

The ETF process “aims to promote the comparability of efforts among all developed country Parties; build confidence with regard to developed countries meeting their 2020 quantified economy-wide emission limitation and reduction targets; and enable Parties to discuss the review results of individual Parties,” as summarized in the scenario note. (SBI scenario note 48-50)

SBI also will be considering the “terms of reference” for the Consultative Group of Experts (CGE), a body that provides technical advice and support to developing country parties “for the preparation of their national communications and biennial update reports, and the transition to the enhanced transparency framework.” Karlsen was optimistic in her scenario note (SBI scenario note 52-54).

For an introduction to ETF issues, read Navigating the Paris Agreement Rulebook: Enhanced Transparency Framework by the World Resources Institute. More detailed studies:  Towards common GHG inventory reporting tables for Biennial Transparency Reports and Reporting progress towards Nationally Determined Contributions: exploring possible common tabular formats for the structured summary by the OECD. For a detailed report on the May-June 2020 talks, see the Earth Negotiations Bulletin summary,  A recent UNFCC presentation covers the topic of the informal technical expert dialogues.

Head of Delegation Talks Held

In early September, the chairs of both bodies convened heads of delegations (HoDs) to discuss “two key issues relating to the ETF, specifically:

  • the format(s) Parties will use to track progress in achieving and implementing their national determined contributions (NDCs), and
  • the flexibilities that Parties may use to support their climate reporting.”

The consultations, according to a summary issued Oct. 19, “… moved the dialogue forward on this critical element of the Paris Rulebook, but also reflected the urgent need to further advance discussions prior to COP26.”

Requests by developing countries for assistance continued to be a pressing issue, the chairs reporting, “Some HoDs highlighted that without appropriate capacity-building and financial support, developing country Parties cannot implement the ETF.”

Discussions were held on how to best advance the discussions, but even procedural items proved sensitive. When the creation of a “nonpaper” to summarize options was broached, one delegate voiced opposition, “given the sensitivity of this issue and wide divergence of views,” the summary note states.

Hindering progress is a debate about what common formats to use for common reporting tables (CRTs) and structured summaries, according to the chair’s 5-page summary, which indicates resistance to uniformity although that was the mandate given to the bodies.

Ideas developed during the summer meetings for tables that including narrative formats were urged as a starting point, but “[S]ome participants encouraged Parties to explore whether the tables in the informal note accommodate their NDCs and reflect national circumstances.”

The chairs reported, “Most HoDs consistently identified flexibility as a key issue to resolve on transparency.” The note elaborates more on flexibility options, including phased in reporting.

Their summary ends with plea for continued negotiations on the topic known as modalities, procedures and guidelines (MPGs) for the ETF.

Rules for Reporting

 A related topic deals with the rules and timing for other reports, described under Article 6.2 of the Paris Agreement, including submissions to databases and eventually the Biennial Transparency Reports (BTRs).

The SBSTA chair issued a summary note dated Oct. 11 with several dozen topics highlighted in bold to indicate they remain unresolved, principally about the timing of reporting.

The SBSTA held an “informal technical expert dialogue” Sept. 23, summarized in a UNFCC slide presentation. The chair reported that the parties agreed that the informal technical expert dialogue was “not a contentious issue.”

For background, read 2020 UPDATE Negotiating cooperation under Article 6 of the Paris Agreement by the European Capacity Building Initiative.

Official documents on this topic are grouped here on the UNFCCC website.