Enhanced Transparency Framework Research Articles

Transparency is what states make of it: whose climate priorities are reflected in the Paris Agreement’s enhanced transparency framework?

ABSTRACT In this article, we examine the contestations and compromises that underpin the Paris Agreement’s enhanced transparency framework, with the aim to analyze whose climate action priorities are reflected in these arrangements. Key mandatory obligations of the transparency framework relate to submission of greenhouse gas inventories and reporting and review of mitigation-related climate actions. Less analyzed are the non-mitigation focused transparency provisions, particularly those relating to adaptation, loss and damage and financial support, all of which are of key importance to developing countries. We address this research gap here by unpacking what different groups of countries desired with regard to these less examined aspects of the enhanced transparency framework, in the lead-up to finanalization of the Paris Agreement in 2015, and the nature of the political compromises reached on each. Furthermore, we analyze how these agreed transparency provisions are being operationalized since 2015. We find that many of the compromises reached on the scope of the enhanced transparency framework, but perhaps even more so in its subsequent operationalization, marginalize certain aspects of reporting and review that are of the highest priority to developing countries. These include, for example, reporting on adaptation needs, on having voluntary information on loss and damage be reviewed by international experts, and having access to comparable and actionable reporting on support provided by developed countries. This highlights the need for future research to assess the domestic consequences of engaging in global climate transparency arrangements for developing countries; and whether and how such engagement aligns with domestic priorities.

Nationally determined contributions to the 2015 Paris Agreement goals: transparency in communications from developing country Parties

ABSTRACT The goals of the Paris Agreement (PA) on collectively managing climate change can only be reached if all parties to the United Nations Framework Convention on Climate Change (UNFCCC) commit to actions supporting their Nationally Determined Contributions (NDCs). Developing-economy nations play a crucial role in reaching the PA targets, particularly in the Agriculture, Forest, and Other Land Uses (AFOLU) sector. However, developing country Parties also face several constraints in tracking and communicating progress towards their climate policy targets and implementation of their NDCs. The operationalization of Biennial Transparency Report (BTR) and Enhanced Transparency Framework (ETF) under the PA will bring stricter reporting timeframes and advanced transparency for all parties. With these requirements rapidly coming into force, addressing reporting gaps is now a pressing priority. The present study analyzes the NDCs, and Biennial Update Reports (BURs) submitted by developing country Parties under the UNFCCC. In an illustrative exercise, our in-depth analysis concentrates on reporting on the AFOLU sector and identifies issues impeding a comprehensive and comparable Global Stock Take (GST): (i) issues of consistency in reporting timeframes (ii) issues in transparency of reporting on mitigation sectors and on relevant progress indicators (iii) incomparability of methodological approaches proposed and used, and (iv) the implications of limited national capacity for transparent reporting. The UNFCCC and developed country Parties now have the opportunity of providing specialized support for developing country Parties. This could include tailored guidance to address gaps in both greenhouse-gas (GHG) emissions accounting, and reporting challenges, to ensure consistent, comprehensive, and transparent reporting to reinforce capacities moving forward following the next GST.

Lost in the scenarios of negative emissions: The role of bioenergy with carbon capture and storage (BECCS)

Bioenergy with carbon capture and storage (BECCS) can be a useful and cost-effective climate change mitigation tool but it is reliant on economic incentives. With this policy perspective article we question the ongoing discussion about the use of biomass for BECCS with basis in three points: (1) under the enhanced transparency framework under the Paris agreement, all parties to the agreement will use the same guidelines to estimate emissions by sources and removals by sinks, in which the emissions and removals in connection to cultivation of biomass are accounted for in the land-use, land-use change and forestry (LULUCF) sector, (2) adding carbon capture to existing processes may lead to a shift in products from that process rather than an increase in biomass use, and (3) BECCS requires substantial financial incentives. With basis in these points, we argue that a certification framework for BECCS that contradicts the guidelines of the Intergovernmental Panel on Climate Change (IPCC) risks unnecessarily hindering deployment of a potentially cost-effective climate change mitigation tool.

Practical Solutions for Addressing Challenges in National Reporting for the Enhanced Transparency Framework: Cases from Developing Countries in the Asia–Pacific Region

Transitioning to the Enhanced Transparency Framework (ETF) under the Paris Agreement (PA) from the current measurement, reporting and verification (MRV) arrangements under the United Nations Framework Convention on Climate Change (UNFCCC) requires developing countries to enhance their national reporting systems in a sustainable way. There are various challenges that developing countries face in preparing national reporting under the existing MRV framework. The objective of this paper is to identify practical solutions as good practices in the short and long term to address the common challenges facing many developing countries as they prepare their national climate reporting. We collected information on practical solutions implemented by developing countries to overcome common challenges during preparation of their national reporting. There were some limitations regarding data collection using a country survey since we received responses from only six countries and two organizations, resulting in a small sample. Good practices for addressing common challenges include developing a national legal framework for transparency-related work, assigning a main coordinating institution, collaborating with domestic institutions for methodology development on emission reduction, and establishing university curricula on transparency. Replicating these solutions as good practices on how to deal with the challenges would be one way for developing countries to enhance their respective reporting systems in a sustainable manner. Furthermore, the paper highlights three underlying factors (efficiency, accountability, and sustainability) behind those practical solutions. These underlying factors should be considered important as guiding principles for building sustainable reporting systems in order to be able to successfully implement the ETF.

Large-scale high-resolution yearly modeling of forest growing stock volume and above-ground carbon pool

Within the Paris Agreement's Enhanced Transparency Framework, consistent data collections are the prerequisite for a successful reporting of GHG emissions. For such purposes, NFIs are usually the primary source of information, even if they are frequently not designed for producing estimations on a yearly basis and in the form of wall-to-wall high-resolution maps. In this framework, we present a new spatial model to produce yearly growing stock volume (GSV), above-ground biomass (AGB), and carbon stock wall-to-wall estimates. We tested the model in Italy for the period 2005–2018, obtaining a time-series of yearly maps at 23 m spatial resolution. Results were validated against the 2015 Italian NFI reaching an average RMSE% of 19% for aggregated areas. Results were also compared against data reported by the Italian GHG inventory, reaching an RMSE% of 28% and 20% for GSV and carbon stock respectively.We demonstrated that the modeling approach can be successfully used for setting up a forest monitoring system to meet the interests of governments in inventories of GHG emissions and private entities in carbon offset investments.

Opinion: Coordinated development of emission inventories for climate forcers and air pollutants

Abstract. Emissions into the atmosphere of fine particulate matter, its precursors, and precursors to tropospheric ozone impact not only human health and ecosystems, but also the climate by altering Earth's radiative balance. Accurately quantifying these impacts across local to global scales historically and in future scenarios requires emission inventories that are accurate, transparent, complete, comparable, and consistent. In an effort to better quantify the emissions and impacts of these pollutants, also called short-lived climate forcers (SLCFs), the Intergovernmental Panel on Climate Change (IPCC) is developing a new SLCF emissions methodology report. This report would supplement existing IPCC reporting guidance on greenhouse gas (GHG) emission inventories, which are currently used by inventory compilers to fulfill national reporting requirements under the United Nations Framework Convention on Climate Change (UNFCCC) and new requirements of the Enhanced Transparency Framework (ETF) under the Paris Agreement starting in 2024. We review the relevant issues, including how air pollutant and GHG inventory activities have historically been structured, as well as potential benefits, challenges, and recommendations for coordinating GHG and air pollutant inventory efforts. We argue that, while there are potential benefits to increasing coordination between air pollutant and GHG inventory development efforts, we also caution that there are differences in appropriate methodologies and applications that must jointly be considered.

Space-based Earth observation in support of the UNFCCC Paris Agreement

Space-based Earth observation (EO), in the form of long-term climate data records, has been crucial in the monitoring and quantification of slow changes in the climate system—from accumulating greenhouse gases (GHGs) in the atmosphere, increasing surface temperatures, and melting sea-ice, glaciers and ice sheets, to rising sea-level. In addition to documenting a changing climate, EO is needed for effective policy making, implementation and monitoring, and ultimately to measure progress and achievements towards the overarching goals of the United Nations Framework Convention on Climate Change (UNFCCC) Paris Agreement to combat climate change. The best approach for translating EO into actionable information for policymakers and other stakeholders is, however, far from clear. For example, climate change is now self-evident through increasingly intense and frequent extreme events—heatwaves, droughts, wildfires, and flooding—costing human lives and significant economic damage, even though single events do not constitute “climate”. EO can capture and visualize the impacts of such events in single images, and thus help quantify and ultimately manage them within the framework of the UNFCCC Paris Agreement, both at the national level (via the Enhanced Transparency Framework) and global level (via the Global Stocktake). We present a transdisciplinary perspective, across policy and science, and also theory and practice, that sheds light on the potential of EO to inform mitigation, including sinks and reservoirs of greenhouse gases, and adaptation, including loss and damage. Yet to be successful with this new mandate, EO science must undergo a radical overhaul: it must become more user-oriented, collaborative, and transdisciplinary; span the range from fiducial to contextual data; and embrace new technologies for data analysis (e.g., artificial intelligence). Only this will allow the creation of the knowledge base and actionable climate information needed to guide the UNFCCC Paris Agreement to a just and equitable success.

The Nationally Determined Contribution Expert Tool (NEXT): A Comprehensive Greenhouse Gas Accounting Tool to Support Annual Environmental Impact Assessment Over a 30-Year Time Series in the Agriculture, Forestry and Other Land Use Sector

The Nationally Determined Contribution Expert Tool (NEXT) is a greenhouse gas accounting tool developed by the Food and Agriculture Organization of the United Nations (FAO) to support annual environmental impact assessment for the Agriculture, Forestry and Other Land Use sector (AFOLU). It provides a 30-year time series of annual and cumulated estimates of carbon removal and greenhouse gas emission reductions from actions determined by Parties in their climate policies. NEXT was developed using the Intergovernmental Panel on Climate Change (IPCC) methodologies, and estimates can be made using either the IPCC 2006 guidelines or the IPCC 2019 refinement to the IPCC 2006 which are both complemented with the IPCC 2013 Wetlands Supplement. The tool was designed to provide results that directly respond to the provisions of the Enhanced Transparency Framework and support the Nationally Determined Contributions (NDC) development as required by the modalities, procedures and guidelines. NEXT provides a detailed temporal series of results and a wide set of indicators, including the social value of carbon, enabling a comprehensive environmental and economic overview of climate actions in achieving mitigation targets. The tool helps countries to interpret, track and scale up ambition of their NDCs which could ultimately inform the global stocktake of the Paris Agreement in a harmonized way.

China’s Stance on the Normativity of International Climate Change Law: An Interactional Account

Abstract Existing analytical accounts of China’s interactions with international law are underdeveloped. This article proposes the use of an interactional model to explain the normativity of international law from three perspectives: shared understandings, normative qualities of international law, and the reception of individual countries to these normative qualities. Furthermore, the interactional model is used to explain how conceptions of the normativity of international climate change law are developed in China. It finds that China has accepted the common responsibility system under an enhanced transparency framework, while adhering to the facilitative nature of international commitments to accommodate the needs of developing countries and stringently insisting on obligations of support from developed countries being met. In this, China’s position on the normative qualities of international climate change law is influenced by its international identities, power status, national interests, and domestic understandings of anthropogenic climate change. The interactional account that follows implies that future research on China’s interactions with international law should be cautious of both Western centrism and Chinese exceptionalism and consider both the legitimacy of international law and China’s own domestic context.

Addressing uncertainty and bias in land use, land use change, and forestry greenhouse gas inventories

National greenhouse gas inventories (NGHGIs) will play an increasingly important role in tracking country progress against United Nations (UN) Paris Agreement commitments. Yet uncertainty in land use, land use change, and forestry (LULUCF) NGHGHI estimates may undermine international confidence in emission reduction claims, particularly for countries that expect forests and agriculture to contribute large near-term GHG reductions. In this paper, we propose an analytical framework for implementing the uncertainty provisions of the UN Paris Agreement Enhanced Transparency Framework, with a view to identifying the largest sources of LULUCF NGHGI uncertainty and prioritizing methodological improvements. Using the USA as a case study, we identify and attribute uncertainty across all US NGHGI LULUCF “uncertainty elements” (inputs, parameters, models, and instances of plot-based sampling) and provide GHG flux estimates for omitted inventory categories. The largest sources of uncertainty are distributed across LULUCF inventory categories, underlining the importance of sector-wide analysis: forestry (tree biomass sampling error; tree volume and specific gravity allometric parameters; soil carbon model), cropland and grassland (DayCent model structure and inputs), and settlement (urban tree gross to net carbon sequestration ratio) elements contribute over 90% of uncertainty. Net emissions of 123 MMT CO2e could be omitted from the US NGHGI, including Alaskan grassland and wetland soil carbon stock change (90.4 MMT CO2), urban mineral soil carbon stock change (34.7 MMT CO2), and federal cropland and grassland N2O (21.8 MMT CO2e). We explain how these findings and other ongoing research can support improved LULUCF monitoring and transparency.

The CO2 Human Emissions (CHE) Project: First Steps Towards a European Operational Capacity to Monitor Anthropogenic CO2 Emissions

The Paris Agreement of the United Nations Framework Convention on Climate Change is a binding international treaty signed by 196 nations to limit their greenhouse gas emissions through ever-reducing Nationally Determined Contributions and a system of 5-yearly Global Stocktakes in an Enhanced Transparency Framework. To support this process, the European Commission initiated the design and development of a new Copernicus service element that will use Earth observations mainly to monitor anthropogenic carbon dioxide (CO2) emissions. The CO2 Human Emissions (CHE) project has been successfully coordinating efforts of its 22 consortium partners, to advance the development of a European CO2 monitoring and verification support (CO2MVS) capacity for anthropogenic CO2 emissions. Several project achievements are presented and discussed here as examples. The CHE project has developed an enhanced capability to produce global, regional and local CO2 simulations, with a focus on the representation of anthropogenic sources. The project has achieved advances towards a CO2 global inversion capability at high resolution to connect atmospheric concentrations to surface emissions. CHE has also demonstrated the use of Earth observations (satellite and ground-based) as well as proxy data for human activity to constrain uncertainties and to enhance the timeliness of CO2 monitoring. High-resolution global simulations (at 9 km) covering the whole of 2015 (labelled CHE nature runs) fed regional and local simulations over Europe (at 5 km and 1 km resolution) and supported the generation of synthetic satellite observations simulating the contribution of a future dedicated Copernicus CO2 Monitoring Mission (CO2M).

Strengthening the Paris Agreement by Holding Non-State Actors Accountable: Establishing Normative Links between Transnational Partnerships and Treaty Implementation

AbstractWhile the intergovernmental climate regime increasingly recognizes the role of non-state actors in achieving the goals of the Paris Agreement (PA), the normative linkages between the intergovernmental climate regime and the non-state dominated ‘transnational partnership governance’ remain vague and tentative. A formalized engagement of the intergovernmental climate regime with transnational partnerships can increase the effectiveness of partnerships in delivering on climate mitigation and adaptation, thereby complementing rather than replacing government action. The proposed active engagement with partnerships would include (i) collecting and analyzing information to develop and prioritize areas for transnational and partnership engagement; (ii) defining minimum criteria and procedural requirements to be listed on an enhanced Non-state Actor Zone for Climate Action platform; (iii) actively supporting strategic initiatives; (iv) facilitating market or non-market finance as part of Article 6 PA; and (v) evaluating the effectiveness of partnerships in the context of the enhanced transparency framework (Article 13 PA) and the global stocktake (Article 14 PA). The UNFCCC Secretariat could facilitate engagement and problem solving by actively orchestrating transnational partnerships. Constructing effective implementation partnerships, recording their mitigation and adaptation goals, and holding them accountable may help to move climate talks from rhetoric to action.

Effective tracking of nationally determined contributions: A case study on South Africa

The Paris Agreement’s enhanced transparency framework requires that all Parties track and report progress toward their nationally determined contributions (NDCs). This paper develops a qualitative, multi-criteria framework that can be used to either design effective NDC tracking systems or evaluate the extent to which Parties are prepared for NDC tracking. The paper also applies the framework to a case study on South Africa, with results indicating that the country is progressing well in terms of selecting appropriate indicators, enacting legislation, and enhancing transparency. In areas of collecting data, reporting on socio-economic outcomes, and making changes in national policy, there is room for improvement, and the paper explores options to this end. Since South Africa has a relatively advanced system for tracking mitigation goals, the findings of the paper suggest that other developing country Parties may require additional resources and capacity to track NDCs effectively.

Assessing state compliance with multilateral climate transparency requirements: ‘Transparency Adherence Indices’ and their research and policy implications

ABSTRACT Transparency is increasingly central to multilateral climate governance. In this article, we undertake one of the first systematic assessments of the nature and extent of compliance with transparency requirements under the United Nations Framework Convention on Climate Change (UNFCCC). Extensive resources are now being devoted to setting up national and international transparency systems that aim to render visible what individual countries are doing with regard to climate change. It is widely assumed that such transparency is vital to securing accountability, trust and thereby also enhanced climate actions from all. Yet, whether transparency lives up to this transformative promise remains largely unexamined. We generate a first systematic overview here of the nature and extent of country engagement with and adherence to UNFCCC transparency requirements. Drawing on extensive primary documents, including national reports and technical expert assessments of these reports, we generate ‘Transparency Adherence Indices’ for developed and developing country Parties to the UNFCCC. Our results reveal wide variations in adherence to mandatory reporting requirements and no clear general pattern of improvement since 2014. Our Indices help to illustrate trends and highlight knowledge gaps around the observed adherence patterns. This is timely since the 2015 Paris Agreement calls for an ‘enhanced transparency framework’ to be implemented by 2024 that builds on existing UNFCCC transparency systems. We conclude with identifying a research and policy agenda to help explain observed patterns of adherence, and emphasize the need for continued scrutiny of assumed links between transparency and climate action. Key policy insights The UNFCCC and its 2015 Paris Agreement call for ever greater climate transparency from all countries. We develop ‘Transparency Adherence Indices’ that reveal frequency of engagement and adherence to reporting requirements of both developed and developing countries. Our findings reveal high engagement in transparency arrangements by developed countries and variable engagement from developing countries. We question what variable adherence to reporting requirements actually signifies, given how such adherence is assessed within UNFCCC technical expert reports. Further research to explain the range of observed adherence patterns is important, in light of the Paris Agreement’s requirements for enhanced transparency from all. The assumed link between enhanced transparency and climate action needs further analysis.

Report on the National Workshop on “Strengthening National Capacity to Meet the Enhanced Transparency Framework of the Paris Agreement in Bangladesh”

Report on the National Workshop on “Strengthening National Capacity to Meet the Enhanced Transparency Framework of the Paris Agreement in Bangladesh”

Towards Enhanced Transparency in Non-Annex 1 Countries? Challenges and Options for Measurement and Reporting in Georgia

This paper explores what the main challenges are for Georgia and other non-Annex 1 countries to meet the requirements under the Paris Agreement’s Enhanced Transparency Framework, and discusses what the options are for overcoming these challenges. The paper draws on primary data from Georgia’s energy sector and on case-based literature from various non-Annex 1 countries. The literature points to challenges such as insufficient budgets, low capacity, and inadequate institutional set-ups, and proposes increased financial and technical support and standardized guidelines for measurement and reporting as best options. Cases from South Caucasus and Georgia are rare. We therefore examine how Georgia’s current system for Measurement and Reporting is organized, and what the main technical-administrative challenges are for the sector to meet the transparency requirements as seen from key stakeholders’ and implementers’ perspectives. In addition to challenges similar to those identified in the literature, we find that the most fundamental challenge is a lack of domestic political motivation and support. The perceived complexity of the transparency requirements is a major deterrent in combination with the limited capacity to deal with it. We therefore focus our discussion on options for how to foster domestic political support, and argue that emphasizing existing and new co-benefits, including increasingly linking Measurement and Reporting to the carbon market, could be a way forward. Given the urgency of reducing emissions, we find that efforts towards reducing the complexity of the requirements, activities and tools for Measurement and Reporting (M&R) could help adapt the Enhanced Transparency Framework to the actual situation of non-Annex 1 countries and make Measurement and Reporting more worthwhile for these countries.

Toward an Operational Anthropogenic CO2 Emissions Monitoring and Verification Support Capacity

AbstractUnder the Paris Agreement (PA), progress of emission reduction efforts is tracked on the basis of regular updates to national greenhouse gas (GHG) inventories, referred to as bottom-up estimates. However, only top-down atmospheric measurements can provide observation-based evidence of emission trends. Today, there is no internationally agreed, operational capacity to monitor anthropogenic GHG emission trends using atmospheric measurements to complement national bottom-up inventories. The European Commission (EC), the European Space Agency, the European Centre for Medium-Range Weather Forecasts, the European Organisation for the Exploitation of Meteorological Satellites, and international experts are joining forces to develop such an operational capacity for monitoring anthropogenic CO2 emissions as a new CO2 service under the EC’s Copernicus program. Design studies have been used to translate identified needs into defined requirements and functionalities of this anthropogenic CO2 emissions Monitoring and Verification Support (CO2MVS) capacity. It adopts a holistic view and includes components such as atmospheric spaceborne and in situ measurements, bottom-up CO2 emission maps, improved modeling of the carbon cycle, an operational data-assimilation system integrating top-down and bottom-up information, and a policy-relevant decision support tool. The CO2MVS capacity with operational capabilities by 2026 is expected to visualize regular updates of global CO2 emissions, likely at 0.05° x 0.05°. This will complement the PA’s enhanced transparency framework, providing actionable information on anthropogenic CO2 emissions that are the main driver of climate change. This information will be available to all stakeholders, including governments and citizens, allowing them to reflect on trends and effectiveness of reduction measures. The new EC gave the green light to pass the CO2MVS from exploratory to implementing phase.

Article 13: Enhanced Transparency Framework for Action and Support

This chapter provides a commentary on Article 13 of the Paris Agreement focusing on the enhanced transparency framework for action and support.

Transparency requirements under the Paris Agreement and their (un)likely impact on strengthening the ambition of nationally determined contributions (NDCs)

ABSTRACTHow will the Paris Agreement drive countries to address climate change? One expectation of the Agreement is that transparency will stimulate countries to increase the ambition of their pledges by revealing information on Parties’ climate efforts. To this end, the Agreement introduced a new ‘enhanced transparency framework’ (ETF) to report and review information on Parties’ greenhouse gas emissions, progress made in implementing and achieving nationally determined contributions (NDCs), their adaptation actions, and the financial, technological and capacity-building support needed, received and provided to developing country Parties. However, this relationship between transparency and progressive ambition over time remains largely untested. In this article, we first outline several pathways through which increased transparency could potentially lead to increased ambition. These pathways notably depend on the availability of comparable, complete and timely information on the performance of Parties. By reviewing the experience with past and existing transparency arrangements, we identify four types of challenges that will likely pose barriers to the generation of such information by the ETF, and suggest some efforts that might address these challenges to support greater ambition in future rounds of NDCs.Key policy insightsThe potential use of the flexibilities offered to developing countries on some dimensions of the ETF may lead to the generation of incomplete and incomparable information.It will be difficult to assess and compare progress made by Parties towards achieving their NDCs due to heterogenous, qualitative and conditional NDCs; the variety of indicators that Parties will choose to track their progress; and to weaknesses in the reporting guidelines on climate action and support.Despite ongoing efforts to address this, the information generated by the ETF may be outdated and non-comprehensive due to capacity gaps.The apolitical design of the ETF means that it will not lead to judgments, for example on the level of ambition of an NDC, or even on whether a country is achieving its NDC. The ETF is also not equipped to deal with cases of political unwillingness to participate in the ETF itself.

The Paris Agreement’s Implications for Monitoring, Reporting, and Verification of Greenhouse Gas Emissions and Climate-Related Policies and Measures in Developing Countries

Under the terms of the Paris Agreement there will be much more information than ever before on the quantities and mix of greenhouse gases that each country emits and on the action it is taking to respond to climate change. The information will be regularly updated, and to some extent it will be standardized and made comparable across countries. It is a welcome prospect — or is it? In December 2018 the Conference of the Parties to the Paris Agreement (CMA) issued rules to operationalize the treaty, including rules on the “enhanced transparency framework” (ETF) — another term for a monitoring, reporting, and verification (MRV) system. The CMA’s rules on MRV are heavily qualified, introducing uncertainty into their application. Just like the treaty itself, the Agreement’s rules on MRV favour developing countries with a multitude of exceptions. The normative principle behind them is a compound of convictions about “national self-determination”, flexibility in implementation for developing countries, and state immunity from review (except for a low-level, “technical”, review of state reports, to check conformity with ETF requirements). This principle is a bloated version of the common but differentiated responsibility (CBDR) principle. A better term for it is “principle of indeterminacy”, for its effect is to keep state conduct on climate change indeterminate and unpredictable. The rise of a sprawling ETF under the Paris Agreement is worrisome, in a context where neither the Agreement nor the Rules provide for a process to determine equitable mitigation effort by parties, both in general and in relation to the 2°C warming limit. Instead, the regime creates many new opportunities for open-ended talking (and, more generally, interaction) among state representatives, which some will see as a positive development, but it also increases the unpredictability of mitigation outcomes. The MRV-related risk is that the ETF will usher in a period of mass information generation whose handling will overpower efforts to raise the level of mitigation ambition among states.