On behalf of the accredited organization German Forum Environment & Development, Carbon Market Watch, a project by Nature Code, welcomes the opportunity to provide its views on the role of the Framework for Various Approaches (FVA).

Given the urgency and the severity of the climate crisis, it is absolutely vital that any action taken by Parties does not further weaken reduction commitments but on the contrary strengthens the environmental integrity of mitigation pledges.

Some organisations and Parties, most notably Poland who is hosting COP-19 are advocating establishing a pilot phase under the UNFCCC’s Framework for Various Approaches (FVA). Carbon Market Watch recommends that Parties do not establish such a pilot phase for the following reasons:

• An FVA pilot phase cannot ensure the environmental integrity of market units: To date, only general principles have been established for the FVA. It is premature to establish a pilot before rules and structures that ensure environmental integrity and sound accounting have been established. Without these fundamental rules, the integrity of market units cannot not be ensured.
• Recognition of “Early Action” may taint ADP discussion: Some Parties advocate for the recognition of “early action” for Parties that would participate in a FVA pilot phase.  Given the early stages of the ADP discussions, it is premature to allow for the recognition of any early action under a post 2020 agreement before the negotiations on some of the fundamental principles for the new post-2020 climate regime have been established.
• Pilot schemes can be carried out without a COP decision: Over the last 10 years a wealth of knowledge has been accumulated on how to design and govern carbon market schemes. Establishing an FVA pilot phase under the UNFCCC would therefore add limited value. At the same time it would pose serious risks to the integrity of mitigation targets pre and post 2020.

For these reasons, outlined in more detail in the submission, Carbon Market Watch encourages Parties not to establish a pilot phase for the FVA.