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VCS Weighs in on Paris Agreement Article 6

With COP23 around the corner, our friends at IETA are providing a way for their member organizations to submit ideas on how to operationalize Article 6 of the Paris Agreement. While the UNFCCC has invited governments to submit their views on the implementation of Article 6, other stakeholders, including NGOs, project developers and the business community at large, have been excluded from this process. Given the importance of having a wide variety of perspectives to draw from and thus create an effective architecture for the successful operationalization of Article 6, IETA has created a publicly accessible portal for its members to submit their ideas.

The IETA portal serves as a space where submissions from key players in the carbon markets discussion are publicly accessible and can be viewed by anyone interested in how we put Article 6 into practice, from the general public to policy makers and government officials. IETA plans to produce a synthesis of the submissions ahead of COP23.

We at VCS have embraced this opportunity and have submitted our recommendations. We have made the case for robust rules to prevent double counting and the adoption of an ‘open architecture’ approach in which GHG crediting programs like the VCS Program can form part of the architecture needed to drive emission reductions at the scale we need. To be effective, Article 6 will need to address two main topics. The first relates to the credibility of international trading, which will require robust and yet practical rules around double counting and claiming. The second relates to the environmental integrity of the individual units that would be eligible for international trading. While there is not much experience relating to the former, particularly in the context of the varying commitments as outlined in country NDCs, players in both the regulated/compliance and voluntary carbon markets have developed ample experience in ensuring environmental integrity of individual units.

Indeed, we argue that Article 6.4 will be most successful if it leverages the broad expertise currently available across organizations that manage GHG crediting programs. Such a broad base of expertise means that the UNFCCC should establish high-level criteria that GHG programs will need to meet to generate units eligible for trading under the Article 6.4, rather than designing and managing a singular GHG crediting program. Such an ‘open architecture’ approach is already being proposed under the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), and has great potential to serve Article 6.4 as well.

We dive into these topics in depth in our submission, including outlining the benefits of such an ‘open architecture’ approach, as well as our recommendations on governance, project type and scale of activities. Read our full submission here on our site or on the IETA portal.