Shifting incentives, making risk and value visible

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As we near the end of Week 1 of the COP28, there is consensus that ambition needs to rise quickly. Accelerated timelines & mobilization of expanded funds for transformational climate action are key.

Our first COP28 dispatch focused on what is happening and why it makes sense to look ahead to real-world climate transformation. There is key language in draft text that holds promise to meet the Paris Agreement Article 6.8 call for “integrated, holistic, and balanced” approaches that work across conventions.

We are starting to see recognition that national sovereignty is not diminished by robust, multidimensional climate cooperation, but enhanced, and that trade relations, foreign investment, and everyday security and prosperity can be improved by improving climate cooperation.

Densely built Dubai is a reminder of the scale and complexity of the low-carbon transformation. It also provides a clear visual reference for those asking what the financial opportunity looks like for transformative enterprise.

On Day 4, December 3, there was some progress in clarifying how the New Collective Quantified Goal on Climate Finance (NCQG)—effectively the upgrade of the 2009 pledge of $100 billion per year by 2020—should be designed and finalized. Two core concepts emerged as potential points of consensus: a short-term actionable goal that allows for rapid and measurable mobilization, and a long-term goal for 2050. 

For the short term goal, there is emerging support for a 5-year goal that would be periodically reviewed for the adequacy of the target number and progress towards it. This cyclical review concept has emerged as a potential “ratchet mechanism” to push ambition higher, if climate disruption worsens or it becomes clear that ambition is too low or implementation too slow. There has been discussion about the “race to the top” concept, with hard questions about whether countries have ever seriously started the constructive cooperative competition envisioned by the Paris Agreement. 

Significant controversy emerged in discussions around Article 6.2 of the Paris Agreement, which focuses on international transfer of mitigation outcomes (ITMO), or emissions trading

  • There is a serious carbon accounting question, which ultimately relates to the Global Stocktake, assessment of progress, and the upgrading of NDCs.
  • If “cooperative approaches” through ITMOs need not involve at least 2 nations agreeing to trade accounted emissions reductions, then the type of emissions offsetting taking place could lead to a gaming of the carbon accounting system.
  • If Nation A considers industries’ emissions cuts through offsets in its national carbon accounting, but Nation B, where the offsetting activity takes place, possibly as forest conservation, does not agree to relinquish those emissions reduction to Nation A, then there would be “double counting” and lack of clarity about the remaining global heating pollution “budget”.
  • A key tension is that private sector experimentation could lead to faster emissions reductions in some countries, but the double-counting problem could undermine the political and commercial viability of the systems that welcome that experimentation.

The COP President called for Just Transition, citing the need for developing nations to not have to forego development while implementing climate plans. This was welcomed by many but raised concerns from some advocates and vulnerable stakeholders that the decoupling of development from pollution might slow down or be reversed, endangering Paris Agreement implementation and putting lives and livelihoods at risk as climate impacts worsen. There are also ongoing concerns that Just Transition might be reframed as simply a question of national sovereignty, rather than a question of just treatment of vulnerable, marginal, and affected communities.

Full phase-out of fossil fuels is on the table. Draft text for the consensus outcome from COP28 contains language calling for “an orderly and just phase-out” or “accelerating efforts towards phasing out unabated fossil fuels”. More than 100 countries support full phase-out. Parties arguing that oil is essential to their economies are being asked by Parties and by advocates to recognize that a climate-resilient clean economy will deliver a healthier, more diversified, more sustainable form of prosperity. 

Net-zero pathway analysis by the IEA on energy and by FAO on food systems shows that countries can achieve a healthier, more sustainable form of economy-wide development through climate action. Given the urgent need for rapid climate transformation, and the steadily rising costs associated with inaction and worsening climate impacts, it should be possible to reach consensus that continues the decoupling of pollution from development while protecting vulnerable and affected communities from being left behind.

Day 5, December 4, was Finance Day. 

The UAE launched Financing the Future of Food (F3)—an effort to develop innovative bond structures to de-risk and expand flows of private sector capital into food systems transformation and climate-smart agriculture in the Global South.

The Good Food Finance Network held a Leaders Dialogue and Working Meeting, hosted by the FAIRR Initiative at the Hub Culture Climate Pavilion. The session gathered input from Good Food Finance leaders and practitioners, invited input from stakeholders on reaching small-scale actors and activating traditional knowledge, and focused on: 

Non-market approaches were discussed in a contact group—specifically the question of whether carbon pricing policies that do not involve emissions trading are non-market approaches. There has always been a difference of views on this: Some Parties that did not want carbon pricing in the Paris Agreement accepted the non-market language in hopes it would reduce the likelihood of carbon pricing policies having international effects, but cooperative efforts to correct the market failure to price pollution have always been considered potential areas of cooperation not involving ITMOs. 

Negotiations around the sharing of information to structure, connect, and expand multilateral non-market approaches to accelerated climate action.

For two reasons, this should not affect the outcome at COP28 in a significant way: 

  1. The question of what qualifies as a non-market approach is not a carbon accounting question, and there is no oversight body that limits what countries can voluntarily do to enhance their shared path to climate resilience.
  2. The vetting or admission of non-market approaches is more about what kind of information will be shared through a digital platform than it is about what kind of policies countries might or might not adopt.

On Day 6, December 5, there was further debate about whether carbon pricing policies should be listed as non-market approaches in the agreed outcome text from this round of negotiations. Debate also extended to certain types of climate service payments. 

The Global Goal on Adaptation (GGA) process will advance, after concerns were raised that without a mandate for the Co-Facilitators to draft decision text, progress since COP27 would be lost. Some still argue that the GGA is adequately described in Article 7.1 of the Paris Agreement. The wider consensus seems to be that Article 7.1 simply offers criteria for an eventual motivational goal. 

CCI and others advocate for a high-ambition GGA that effectively amounts to a call for eliminating climate damage to people and nature. This ‘zero harm’ standard would require active crisis response to prevent major climate impacts from destabilizing lives and communities. It could also serve as an overarching frame for ambition, sequencing of action, and performance tracking—providing solid information about the state of progress toward securing a livable future.

Left to right: Shanoo Saran, Food Systems for the Future; Felicien Bamporineza, Rwanda Green Fund; Godefroy Grosjean, CGIAR; Jaqueline Musiitwa, USAID; Joe Robertson, CCI / EAT, moderating.

Data has been a major subject of the opening days of the COP28—both in the formal negotiations and in informal side events and other meetings. 

  • On Tuesday, December 5, we heard a panel of private-sector financial leaders and policy-makers give insights to a gathering hosted by FAIRR about emerging performance metrics that link Earth systems data, health and resilience data, and material risks related to climate and nature, to financial data.
  • Later in the day, I was privileged to moderate a panel in the Rwanda Pavilion on blended finance for climate, nature, food, and development. A consistent thread through the discussion was the need for actionable insights on non-financial value, and how such data can create a new investable climate-smart economy.
  • The new Climate Trace tool that launched during this first week provides independent tracking of global heating emissions. The expanded database is now tracking climate pollution from more than 352 million assets (a 4,400x increase).

Finally, we close this dispatch from Dubai with a word on human rights. The same language on human rights found in the Preamble to the Paris Agreement has been frequently repeated or referenced in consensus outcomes since 2015. It is important language that makes an unprecedented commitment to human rights. In Dubai, there are now calls for operationalizing the call for Parties to: 

“respect, promote and consider their respective obligations on human rights, the right to a clean, healthy and sustainable environment, the right to health, the rights of Indigenous Peoples, local communities, migrants, children, persons with disabilities and people in vulnerable situations and the right to development, as well as gender equality, empowerment of women and intergenerational equity…”

We want to reiterate—on behalf of the Citizen’s Climate International network of stakeholder advocates in 76 countries, across 6 continents—that a livable future is a human right. Making the future livable is a core obligation of all public institutions. Honoring these transcendent rights is an efficient way to raise ambition and accelerate implementation across the board.


If you want more information on what’s happening in the negotiations, don’t forget to check the Earth Negotiations Bulletin from IISD for daily reports. 

CCI COP28 activities are outlined at

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