Double claiming in climate action reporting

𝗞𝗲𝗻𝘆𝗮 𝗮𝗻𝗱 𝗦𝘄𝗶𝘁𝘇𝗲𝗿𝗹𝗮𝗻𝗱 𝗟𝗲𝗮𝗱 𝘁𝗵𝗲 𝗪𝗮𝘆 𝗶𝗻 𝗢𝗽𝗲𝗿𝗮𝘁𝗶𝗼𝗻𝗮𝗹𝗶𝘇𝗶𝗻𝗴 𝗔𝗿𝘁𝗶𝗰𝗹𝗲 𝟲.𝟮 𝗼𝗳 𝘁𝗵𝗲 𝗣𝗮𝗿𝗶𝘀 𝗔𝗴𝗿𝗲𝗲𝗺𝗲𝗻𝘁 The agreement establishes a framework for transferring 𝗜𝗻𝘁𝗲𝗿𝗻𝗮𝘁𝗶𝗼𝗻𝗮𝗹𝗹𝘆 𝗧𝗿𝗮𝗻𝘀𝗳𝗲𝗿𝗿𝗲𝗱 𝗠𝗶𝘁𝗶𝗴𝗮𝘁𝗶𝗼𝗻 𝗢𝘂𝘁𝗰𝗼𝗺𝗲𝘀 (𝗜𝗧𝗠𝗢𝘀), 𝗰𝗿𝘂𝗰𝗶𝗮𝗹 𝗳𝗼𝗿 𝗮𝗰𝗵𝗶𝗲𝘃𝗶𝗻𝗴 𝘁𝗵𝗲 𝗡𝗮𝘁𝗶𝗼𝗻𝗮𝗹𝗹𝘆 𝗗𝗲𝘁𝗲𝗿𝗺𝗶𝗻𝗲𝗱 𝗖𝗼𝗻𝘁𝗿𝗶𝗯𝘂𝘁𝗶𝗼𝗻𝘀 (𝗡𝗗𝗖𝘀) outlined under the Paris Agreement. 𝗞𝗲𝘆 𝗣𝗼𝗶𝗻𝘁𝘀 𝗼𝗻 𝘁𝗵𝗲 𝗜𝗺𝗽𝗹𝗲𝗺𝗲𝗻𝘁𝗶𝗻𝗴 𝗔𝗴𝗿𝗲𝗲𝗺𝗲𝗻𝘁 𝘁𝗼 𝘁𝗵𝗲 𝗣𝗮𝗿𝗶𝘀 𝗔𝗴𝗿𝗲𝗲𝗺𝗲𝗻𝘁 𝗯𝗲𝘁𝘄𝗲𝗲𝗻 𝗦𝘄𝗶𝘁𝘇𝗲𝗿𝗹𝗮𝗻𝗱 𝗮𝗻𝗱 𝗞𝗲𝗻𝘆𝗮: 𝟭. 𝗣𝗮𝗿𝘁𝗶𝗲𝘀 𝗜𝗻𝘃𝗼𝗹𝘃𝗲𝗱: The Swiss Confederation (Federal Department of the Environment, Transport, Energy and Communications) and the Republic of Kenya (Ministry of Environment, Climate Change and Forestry). 𝟮. 𝗢𝗯𝗷𝗲𝗰𝘁𝗶𝘃𝗲: Establish a framework for transferring Mitigation Outcomes internationally to support Nationally Determined Contributions (NDCs) and broader mitigation efforts under the Paris Agreement. 𝟯. 𝗘𝗻𝘃𝗶𝗿𝗼𝗻𝗺𝗲𝗻𝘁𝗮𝗹 𝗜𝗻𝘁𝗲𝗴𝗿𝗶𝘁𝘆: Mitigation Outcomes must be new, real, verified, additional, permanent, and aligned with each Party’s low-emission development strategy and the goal of net-zero emissions by 2050. 𝟰. 𝗠𝗶𝘁𝗶𝗴𝗮𝘁𝗶𝗼𝗻 𝗔𝗰𝘁𝗶𝘃𝗶𝘁𝗶𝗲𝘀: Projects must avoid increasing global emissions, exclude nuclear energy and carbon-intensive lock-ins, and promote sustainable, climate-friendly development while respecting human rights. 𝟱. 𝗔𝘂𝘁𝗵𝗼𝗿𝗶𝘇𝗮𝘁𝗶𝗼𝗻 𝗮𝗻𝗱 𝗧𝗿𝗮𝗻𝘀𝗽𝗮𝗿𝗲𝗻𝗰𝘆: Both Parties will implement authorization processes for transfers based on Mitigation Activity Design Documents (MADDs), publish authorizations publicly, and maintain transparency to prevent double counting. 𝟲. 𝗠𝗼𝗻𝗶𝘁𝗼𝗿𝗶𝗻𝗴, 𝗩𝗲𝗿𝗶𝗳𝗶𝗰𝗮𝘁𝗶𝗼𝗻, 𝗮𝗻𝗱 𝗥𝗲𝗽𝗼𝗿𝘁𝗶𝗻𝗴: Approved third-party verifiers assess mitigation activities; reports are subject to review and approval within specified timelines to ensure accuracy and compliance. 𝟳. 𝗥𝗲𝗴𝗶𝘀𝘁𝗿𝘆 𝗦𝘆𝘀𝘁𝗲𝗺: Both Parties maintain registries with unique identifiers for all recognized Internationally Transferred Mitigation Outcomes (ITMOs), enabling transparent tracking. 𝟴. 𝗖𝗼𝗿𝗿𝗲𝘀𝗽𝗼𝗻𝗱𝗶𝗻𝗴 𝗔𝗱𝗷𝘂𝘀𝘁𝗺𝗲𝗻𝘁𝘀: Each Party applies accounting adjustments to prevent double counting of emission reductions. 𝟵. 𝗦𝘂𝘀𝘁𝗮𝗶𝗻𝗮𝗯𝗹𝗲 𝗗𝗲𝘃𝗲𝗹𝗼𝗽𝗺𝗲𝗻𝘁 𝗖𝗼𝗺𝗺𝗶𝘁𝗺𝗲𝗻𝘁: Mitigation activities must align with sustainable development policies, prevent social conflicts, and uphold environmental and human rights standards. Source - Federal Office for the Environment FOEN #𝗖𝗹𝗶𝗺𝗮𝘁𝗲𝗔𝗰𝘁𝗶𝗼𝗻 #𝗣𝗮𝗿𝗶𝘀𝗔𝗴𝗿𝗲𝗲𝗺𝗲𝗻𝘁 #𝗦𝘂𝘀𝘁𝗮𝗶𝗻𝗮𝗯𝗶𝗹𝗶𝘁𝘆 #𝗞𝗲𝗻𝘆𝗮𝗦𝘄𝗶𝘁𝘇𝗲𝗿𝗹𝗮𝗻𝗱𝗣𝗮𝗿𝘁𝗻𝗲𝗿𝘀𝗵𝗶𝗽 #𝗚𝗹𝗼𝗯𝗮𝗹𝗖𝗹𝗶𝗺𝗮𝘁𝗲𝗦𝗼𝗹𝘂𝘁𝗶𝗼𝗻𝘀

The Paris Agreement's Article 6.2 offers a collaborative pathway for countries to achieve their Nationally Determined Contributions (NDCs) through the use of Internationally Transferred Mitigation Outcomes (ITMOs). However, the accounting, reporting, and review processes associated with Article 6.2 can be complex.   The 'Article 6.2 Reference Manual' provides guidance on the initial reports, annual information, and regular information that participating Parties must submit. The manual also details the review process, ensuring transparency and environmental integrity. Key takeaways: Corresponding Adjustments: The manual emphasizes the importance of corresponding adjustments to prevent double counting of emission reductions. It provides detailed guidance on applying these adjustments for single-year and multi-year NDCs. Reporting Requirements: The manual outlines the specific information required in the initial report, annual information, and regular information, ensuring consistency and comparability across participating Parties. Review Process: The manual details the Article 6 Technical Expert Review (TER) process, including its guiding principles, scope, and procedures, ensuring robust accounting and transparency. #ParisAgreement #Article6 #ClimateAction #Sustainability #ITMOs #NDCs #Transparency #EnvironmentalIntegrity

Couple weeks back we discussed vividly here regarding the Dutch incentive system for low carbon marine fuels. Now NEa (Dutch emissions authority) has come out with some intermediate instructions, here's an extract: To briefly outline the biofuel zero-rating claim workflow, shipping companies generally need to follow these steps: Meet the necessary monitoring and reporting requirements as set out in Regulation 2015/757 (MRV) and Regulation 2018/2001 (RED-II). Demonstrate that the biofuel complies with these regulations, typically through a Proof of Sustainability (PoS). Make the PoS available to the verifier and, if requested, to the NEa. Include the zero-rated biofuel information in the emissions report. Submit the verified emissions report. For bunkering in the Netherlands in 2024, due to the temporary national solution: Your fuel supplier needs to register relevant information in the national registry (REV), including the ship's name and IMO number, the Bunker Delivery Note (BDN), the date of delivery, and the energy content. Ask your fuel supplier to provide you with information from the REV regarding the fuel delivery. Draft your emissions report and specify the amount of zero-rated biofuels. Submit the information received from the fuel supplier (extracts from the REV, BDN) and your drafted emissions report to your verifier. Submit your approved emissions report to Thetis-MRV. This temporary solution is for cases where the shipping company cannot obtain a PoS because the fuel supplier has already submitted it to the NEa to obtain renewable energy units (HBEs). Last time (link in the comments) we discussed also about if this is double counting or not. We got answers that it is double registration but it still kept me a bit puzzled. Have been trying to study this with some LLM's and here is the result Yes, utilizing the Dutch HBE system could lead to double counting if EU ETS savings are claimed for the same low-carbon fuel . Potential conflict arises if the same use of low-carbon fuel is reported as an emission reduction under the EU ETS and, at the same time, the fuel supplier or user receives HBE certificates in the Netherlands, which are used to meet national renewable energy obligations. It can lead to double counting, where the emission reduction appears both in the EU ETS and the HBE system, creating an artificial impression of two separate emission reductions. EU legislation, particularly the RED II Directive, the EU ETS Directive, and the ESR Regulation, aims to prevent double counting. According to the European Commission’s interpretation, the same action should not result in both compliance with a national obligation and a reduction in EU ETS allowances, unless there is a mechanism in place that prevents double reporting. Any regulation specialists here who could elaborate if the above is correct or not?