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Carbon Market Watch recommendations for COP23

Dear Respected Colleague,

Carbon Market Watch is pleased to share our SBSTA, SBI, and APA recommendations as well as an overview of our upcoming events and recent publications (below).

Phase out Clean Development Mechanism (CDM)
To reach the objectives of the Paris Agreement, it is essential to learn from past experience avoid the mistakes made with Kyoto mechanisms. Importantly, Parties need to plan for an orderly phaseout of the CDM at the end of the second Kyoto Commitment period. The vast majority of CDM credits lack environmental integrity and most of them are double counted under international commitments including the Cancun Pledges and NDCs. If used towards NDCs and other commitments, these credits would lead to an increase of overall emissions and seriously undermine post 2020 ambition taking us further away from the Paris climate objectives. The comparatively small number of vulnerable projects will, however, need international climate finance for a continued climate benefit. For the sake of the environmental integrity of the Paris Agreement, the vast oversupply of Kyoto hot air, including CDM credits should not undermine ambition after 2020.

Establish strong rules for Article 6 to avoid opening Pandora’s box
Article 6 must enhance – not undermine – ambition. That means strong international rules and oversight to prevent a free-for-all race to the bottom in global markets as well as making cooperative approaches and the SDM equally robust. Carbon markets need a new approach to additionality and to avoiding perverse incentives for present and future climate policy. Further, the social and environmental impacts of mitigation measures cannot again be allowed to be an afterthought and rather must be built into the core of the way any market works. Article 6 must further operate in a world of evolving Clarity, Transparency and Understanding of NDCs – creating a dynamic challenge changing the goalposts and baseline every five years at least.

Don’t let aviation undermine the Paris Agreement
In writing the Paris rulebook, it is essential to address the role of aviation and shipping, two sectors projected to take up to 40% of the carbon budget by 2050. This includes assessing both sectors’ ambition towards Paris goals in the Facilitative Dialogue and Global Stocktake and compatibility with the Paris Agreement on the Transparency Framework and accounting rules. The Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) is clearly not along term solution for aviation emissions in a world where all sectors must quickly reduce their own emissions. Without transparent, compatible rules, the CORSIA could end up increasing the overall emissions in the Paris Agreement by an equivalent of those from 817 coal fired power plants in a year.

For the COP 23, Carbon Market Watch makes the following recommendations:

SBI agenda item 7: Review of the CDM Modalities and Procedures

  • Prepare to phase out the CDM at the end of the second commitment period
  • Cease project registration as of COP24
  • Establish a CDM grievance mechanism
  • Strengthen civil society participation
  • Establish a CMP CMA process to guide the transition process


SBSTA agenda items 11a and 11b: Article 6, Guidance on cooperative approaches and rules, modalities, and procedures of the SDM

  • Establish prerequisites to allow only countries with an economy-wide quantified target to participate in markets
  • Ensure a common accounting system for all international transfers
  • Limit eligible activity sectors to within the scope of NDCs
  • Require countries engaging markets to certify that mitigation actions have not violated human rights or caused environmental harm
  • Create an even playing field between cooperative approaches and the SDM to ensure net mitigation of overall greenhouse gas emissions and a share of proceeds for adaptation
  • Design the SDM as a tool for results based finance, not for zero sum offsetting
  • Ensure environmental integrity, contribute to transformational change, and avoid perverse incentives that undermine ambition for both 6.2 and 6.4
  • Define, monitor, report and verify real, measurable and long-term sustainable development and mitigation benefits


APA agenda items 3, 5 and 6 (as they relate to shipping and aviation targets outside the scope of NDCs)

  • Integrate progress on shipping and aviation into preparation and review of mitigation action of states
  • Establish formalized cooperation between ICAO and the UNFCCC on avoiding double counting
  • Provide information on offsets going to CORSIA participants in reports and updates under the Transparency Framework
  • Introduce information on ICAO and IMO activities into the global stocktake


For more information, please see our latest publications:

Please join us at our side events:

Strengthening the Paris Agreement Transparency Framework through social accountability tools  Thursday 9 November 2017, 13:30-14:30 

Venue:  Climate Planet Space – More information here

Ships, Planes and Paris: Clearly navigating to 1.5°C Tuesday 14 November 2017 10:00-11:45
Venue: South African Pavilion – More information here

Please feel free to contact us in Bonn for any questions.

With best regards,
Carbon Market Watch Team


Aki Kachi, International Policy Director
+49 157 86 80 08 55
[email protected]
Twitter: @akikachi

Kelsey Perlman, Policy Officer for Aviation and Land Use
+32 487 13 02 80
[email protected]
Twitter: @kelsey_perlman

Pierre-Jean Brasier, Network Coordinator
+33 685 88 76 23
[email protected]
Twitter: @pjhugo

Kaisa Amaral, Press Officer
+32 485 07 68 90
[email protected]
Twitter: @KaisaAmaral


Recommendations on CDM review

Recommendations on Article 6

Recommendations on international transport

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