Paris-Oslo process Comments on the draft REDD+ Partnership Agreement 12 th May 2010 These comments are made on behalf of the following NGOs associated with the Ecosystems Climate Alliance The Ecosystems Climate Alliance (ECA) is an alliance of environment and social NGOs founded in December 2008 committed to keeping natural terrestrial ecosystems intact and their carbon out of the atmosphere, in an equitable and transparent way that respects the rights of indigenous peoples and local communities.
Introduction The Ecosystems Climate Alliance appreciates this opportunity to comment on the draft REDD+ Partnership Agreement, but we also believe that the interim REDD+ Partnership should be a partnership not only of developed and developing states, but also of civil society and indigenous peoples. People living in and near the forests will be most affected by the activities, but have not been treated in an inclusive manner in the process leading up to the preparation of the draft Partnership Agreement. The full and effective participation of all stakeholders in the further work of the partnership should be ensured by all countries taking part in the process. It is important to be very clear about the limited mandate of the REDD+ Partnership and its relationship to the UNFCCC process negotiating REDD+. We want partners to avoid opening up a parallel negotiating track within the Partnership that could confuse or undermine UNFCCC negotiations A Partnership focused on information sharing and transparent coordination of extant and future REDD+ financing commitments could be very useful. That is, the Partnership will have a coordinating rather than an implementing role. During this interim period implementation is to remain with the implementation bodies. We also raise our strong concerns over several aspects of the approach and conduct of REDD+ implementing bodies to date, and stress that we must keep working to quickly improve the practices of these bodies. Detailed comments which follow adopt the format of the proposed REDD+ Partnership Agreement. 1. Background The Partnership should be restricted to sharing information and lessons learned, increasing transparency around existing funding flows and interim REDD+ activities, and encouraging effectiveness in preparing for REDD+ and in the delivery of results.. We want partners to avoid opening up a parallel negotiating track within the Partnership that could confuse or undermine UNFCCC negotiations. The statement that the Partnership will not prejudge but support and contribute to the UNFCCC process seems to be attempting to make this point but is not entirely clear on the matter. We suggest that the Partnership should have a sunset clause outlining when the current agreement will expire. As currently proposed the Partnership would be replaced or subsumed by a future UNFCCC mechanism including REDD+, the time frame remaining open-ended. An expiry at the end of the interim funding period in December 2012 is proposed. Relationship to the High Level Advisory Group on Climate Finance (AGF)
Care should be taken to ensure that language used does not commit the Partners to adhere to the recommendations of the High Level Advisory Group on Climate Finance. Whilst the Partnership should recognise the efforts of the AGF, we are concerned by the use of language in this section of the Partnership Agreement that appears to commit the Partners to follow the AGF whatever its ultimate recommendations. Since the AGF has been established by the UN Secretary General, and is not accountable to the UNFCCC, its recommendations may not necessarily be compatible with the UNFCCC process. 2. Objective The objective should clearly embrace the undertaking of readiness activities before scaling up of REDD+ actions and finance. 3. Partner Contributions i) Effective Stakeholder Participation More clarity and certainty are needed regarding the nature and degree of stakeholder participation in the Partnership. The full and effective participation of relevant stakeholders, including indigenous peoples, local communities and civil society, is an essential component of the readiness processes being guided by the FCPF and UN- REDD Programme, as well as the FIP, and is a safeguard in the AWG-LCA draft decision text. It is applicable to and required of all countries participating in the processes. A qualification on stakeholder participation is made by inclusion of the phrase taking into account national circumstances. This introduces unnecessary ambiguity and is not appropriate in this context, and we suggest deleting it. The employment of this qualification at the end of the sentence that describes the intentions of developing country partners could alternatively be read to make everything that precedes it subject to national circumstances. This is equally unacceptable, and if this is the correct interpretation the qualification should also be deleted. ii) Benefit Sharing It is recommended that the Partnership explicitly promote benefit sharing. Benefit sharing is not yet mentioned in the draft document. Benefit sharing is fundamental to a just and effective REDD+. 4. Principles of the Partnership Prioritising REDD+ Interim Actions
The focus of the Partnership agreement is to coordinate information regarding, and lessons learned from, the application of interim REDD+ funding amongst the forested developing countries. However, no attempt is made to prioritise the types of REDD actions and capacity building to which that should most effectively be applied. The justification for the development of REDD was the recognition that avoiding emissions from deforestation and forest degradation represented a very significant opportunity for cost-effective greenhouse gas mitigation. The expansion to REDD+ in Bali has brought in a range of activities and with this a requirement to ensure that those activities which are most effective in mitigating climate change and providing multiple benefits (livelihoods and biodiversity) receive priority. Capacity-building and REDD readiness must also be given priority if rapid progress is to be made towards the implementation of a fully fledged REDD regime. These constitute another major priority. Thus, a principle that specifically provides for the prioritisation of interim REDD+ actions for their effectiveness in capacity building for REDD+ and in delivery of results should be included in the agreement. Safeguards The safeguards principle needs to be stronger. It does not reflect the language of the most recent UNFCCC negotiating text that the safeguards will be promoted and supported, instead merely requiring the Partners to make efforts to promote the safeguards (support is not mentioned). The omission of mandated support for the safeguards is significant and problematic. (ECA will continue to lobby for a further strengthening of safeguards language in the UNFCCC text, such that the safeguards are respected.) Safeguards are fundamental to ensuring REDD leads to permanent reductions in deforestation and degradation and does not lead to negative social and environmental impacts. The safeguards protect the rights of forest dependent communities, protect biodiversity and prevent leakage. Information sharing, with the aim to strengthen, and ensure safeguards as part of the REDD+ process should be part of the underlying principles and operational text. The Partnership serves as an interim platform to scale up REDD+ actions and finance. It is crucial that the application of the safeguards to REDD be tested at the earliest possible stage. Whilst reference is made to lesson sharing, the Partnership should clarify that it will focus on sharing knowledge and experiences of the Partners efforts to implement the safeguards. Interim financing should be used to support measures taken by developing countries to ensure consistency with the safeguards, and this should be a topic of discussion at the next Partnership meeting. Need to address drivers of deforestation and degradation
Both donor countries and developing countries in this Partnership should adopt policies and measures which identify and make plans to address the diverse social and economic drivers of deforestation and degradation. In addition, all countries should ensure that their markets and policies are not inadvertently or deliberately encouraging activities, such as illegal logging, that undermine other nations efforts to promote strong rule of law and forest governance, reduce state revenues or contribute to international displacement of deforestation. Such actions will contribute to lowering interim readiness costs, ensuring permanence and reducing leakage. In support of an effective REDD+ mechanism, we recommend the inclusion of a Principle to point to action on this matter, and for Operational Measures to then be devised to address this matter. Based upon discussion above, we propose the following specific modifications to the current Principles text: Be focused on support for developing countries' REDD+ efforts including a commitment by all countries to address regional and international drivers of deforestation and forest degradation Prioritise interim REDD+ actions for their effectiveness in preparing for REDD+ and in delivery of results, in particular, protecting natural forests and their soils Build capacity amongst local civil society and indigenous peoples groups to ensure their participation and engagement in REDD Be inclusive to all committed countries as well as representatives of relevant stakeholders, including intergovernmental agencies, civil society, and indigenous peoples and local communities. Ensure transparency and accountability around REDD+ financing, actions and results, including implementation of safeguards Focus on coordinated delivery of scaled up REDD+ financing to seek to close gaps, avoid overlaps and maximize effective delivery of actions and support. Consider continuity with medium and long term finance needs and actions by promoting linkages with other relevant processes Exchange lessons learned and transfer knowledge through discussion and presentation of our REDD+ initiatives. Ensure the economic, social and environmental benefits, sustainability and integrity of our REDD+ efforts. Promote and support the safeguards provided by the AWG-LCA s draft decision text on REDD+, adjusted by any COP decision on this matter. 5. Organisation of the Partnership Database Creation All Partners should contribute their relevant information to the database. There should be full transparency in the design and administration of the proposed database and explicit commitment that the information in this database will be shared
transparently, made freely available to the public (preferably online), and updated regularly. This should also include a sharing of lessons learned and best practices. Involvement of civil society and indigenous peoples groups The Partnership agreement undertakes to promote inclusiveness through the participation of a representative group of stakeholders, but provides no guarantees of the level and nature of participation of civil society and indigenous peoples groups, beyond an undertaking to seek timely and significant feedback on REDD+ financing, actions and results from these groups. Instead the agreement relegates the determination of stakeholder participation to the next partnership meeting. The Partnership agreement should specify safeguards on the level of civil society and indigenous peoples participation. Those safeguards should guarantee both participation in the Partnership, and set minimum standards of participation in developing countries. Appendix II: Operational Measures - Given that modalities for stakeholder participation will be considered at the next Partnership meeting (after Oslo), such modalities should: Build on the representation achieved at the Oslo Climate and Forest Conference, and Use the relevant work of the AWG-LCA, the UN-REDD Programme and other existing arrangements as minimum standards for participation - Establish principles for prioritising and sequencing funding that facilitate efficient and coordinated progress towards REDD+ readiness, followed by demonstration projects that can achieve effective emissions reductions. In so doing: Guidance should be developed that prioritises (i) REDD activities that result in protecting intact natural forests and maintaining their existing carbon stocks, above and below ground; then (ii) REDD activities that result in avoiding ongoing emissions by restoring drained peat forest soils; followed by (iii) REDD activities that lead to enhancing removals by restoring degraded forests to functioning ecosystems; and lastly (iv) sustainable management of forests already subject to degrading activities to the extent that it reduces pressure on intact forests and reduces deforestation and forest degradation. - Address drivers of deforestation and forest degradation: Seek to create an enabling environment for REDD+ implementation by undertaking policies and measures in each of their own countries (including developed nations) to reduce the domestic and international drivers of deforestation and forest degradation and to relieve the pressure on natural forests - Facilitate discussion, starting at the next partnership meeting, on the effectiveness of relevant multilateral, bilateral and other initiatives, and measures to ensure the consistency across all REDD+ activities with safeguards provided by the AWG-LCA draft decision and relevant REDD+ initiatives.