Paris Agreement Article 4.13 states that “Parties shall account for their nationally determined contributions.”  NDCs must be constructed using internationally-agreed standards, and the Paris Agreement provision related to transparency means outsiders should be able to verify whether actions and goals in the NDC are being achieved.

The NDC should include an Inventory of greenhouse gas emissions, as well as any ‘removals’.  ‘Removals’ is the formal term for carbon uptake, or ‘sequestration’, for example through the re-growth of forests.

The Inventory should include all existing emissions. The full NDC will usually have a ‘target level of emissions’ in a future year.  While different countries will have different targets, based on their level of development, the purpose of the Paris Agreement is to reduce emissions overall, and so the ‘target level of emissions’ for most countries will be lower than the current level of its existing emissions.

Countries may also use a ‘base year’ from which to measure emission decreases, or a ‘base period’, which is takes the average of a number of year’s emissions.   It’s important that the ‘base year’ is truly representative — not a year which had an unusually high level of emissions.

Land use sector accounting is the most complex, and decisions about which accounting approaches to use in the land sector are critical.  There are a range of technical considerations – how to define managed land; how to define afforestation and reforestation; how to define forest conversion.   For example, it may be very important to make sure that the methods and baselines used do not encourage further deforestation, forest conversion, or ‘land grabs’.

The NDC information submitted is later reviewed by technical experts, who look at whether the NDC is consistent with Article 4.13 provisions related to “environmental integrity, transparency, accuracy, completeness, comparability, and consistency, and ensure the avoidance of double counting.”

‘Environmental integrity’ and ‘avoidance of double counting’ refer to the idea that emission reductions should only be counted once.  This becomes very important in discussions about ‘cooperative approaches’ to climate mitigation, where two different parties may want to take credit for the emission reduction (see next section).

The idea of ‘environmental integrity’ goes beyond just ‘avoiding double counting’ to include quality of the credits exchanged, and whether the exchange led to an overall reduction in emissions in the transferring country.  This term however should NOT be confused with ‘ecological integrity’.  ‘Ecological integrity’ is the goal when biodiversity and climate change are addressed in an integrated manner.

CLARA members have a few recommendations for land-use accounting:

• Land use change should be accounted separately from fossil-fuel sectors. Ideally, an NDC will include a separate ‘pillar’ to measure ambition in forestry, agriculture, and other land-use sectors, so that those efforts can be addition to efforts to phase out fossil fuels.
• No undermining the mitigation efforts of other sectors by using land-based credits.
• Mitigation activities for the land use sector need to also prioritize preserving biodiversity – that is, toward achieving ‘ecological integrity’.

Measuring mitigation success through avoided deforestation and forest restoration requires a good measure of existing forest resources, usually called a forest inventory.  Additionally, for REDD+ programs, countries are encouraged to develop a forest reference level for a particular year, from which progress is measured.

Developing a forest inventory is data- and resource-intensive, and requires an ongoing process of revision.  Remote sensing and satellite technologies are making the task easier, but obtaining appropriate imagery is just the first step.  It then needs to be analyzed.  Deforestation of large areas is generally easy to see on satellite images; but forest degradation, which often occurs at the sub-canopy level, is more challenging.

Another challenge is how plantations are included in the forest reference level.   Current FAO and UNFCCC definitions of ‘forest’ are so broad that they include any planted forest, even a monoculture plantation with all trees of the same age.  Those artificial forests have much lower levels of biodiversity and ecological integrity than natural forests.  But in forest inventories, it is often difficult to distinguish between natural and planted forests, despite their very different carbon endowments and contributions to climate resilience.  CLARA member Global Forest Coalition has criticized the decision to allow ecologically destructive monoculture plantations to be included in forest inventories as though they were the same as natural forests. 

In addition to the technical issues of land-data interpretation, there are often also political decisions about how the forest reference level is constructed.  For example, there are some cases where countries have chosen a year with very high deforestation rates to use as the ‘base year’ for its forest reference level.

If the target is a reduction in deforestation, then using a high-deforestation base year makes it easier to show progress.  If the target is an increase in forested area, then there’s an incentive to use data showing a smaller forest area in the base year.

In all cases, it’s important to ask about the methods by which the forest reference level was constructed.  Many technical assistance programs have helped developing countries to improve their forest inventories, and thus their ability to set forest reference levels.  The raw data, and remote-sensing imagery, associated with baseline setting should be reviewed by civil society, if possible.  A high-ambition NDC should lead to an increase in forest cover, and an increase forest carbon stocks.  For some countries, just ending deforestation is already a major commitment.

The use of forest reference levels has become a big controversy in relation to REDD+ ‘Results Based Payments’.  Brazil for example set such a high forest reference level for its submission to the Green Climate Fund – reaching back to its peak deforestation years in order to set reference levels – that it was able to collect millions of dollars from the GCF in spite of rapid increases in deforestation in 2019 and 2020.  In fact, according to research by CLARA member Global Forest Coalition, the reference level used by Brazil for its submission to the Green Climate Fund for REDD+ payments was “well above actual deforestation rates in the last decade.”  If Brazil had used a more recent reference level, it might not have been eligible for payments.  See Mongabay article about this topic.

There is a large literature on setting forest reference levels.  A key distinction in the literature is between approaches that focus solely on creating a high-quality inventory of forest resources, suitable for reporting to the UNFCCC; and approaches that are linked to carbon markets and ‘results based payments’, such as in REDD+.  Here we provide links to three publications that provide different methodological approaches to level-setting:

Remote Sensing Technology Applications in Forestry and REDD+

World Bank Carbon Fund Methodological Framework

Emerging Approaches to Forest Emission Reference Levels

Mapping Forest Carbon Fluxes

‘Cooperative approaches’ is the term used to refer to actions under Article 6 of the Paris Agreement.  Article 6 is where basic rules to create a global carbon market were included.  But Article 6.8 of the Paris Agreement also provides a ‘non-market’ approach to international cooperation on mitigation.  This is addressed in more detail on the Climate Finance page.

What’s important to understand here in relation to accounting is that country NDCs may often include both an ‘own effort’ target level of emissions, and also, a ‘conditional’ target.  The greater ambition shown in the ‘conditional’ target is based on the expectation that developed countries and international institutions will make appropriate climate finance available to developing countries to pursue that greater level of ambition.  Usually, the country will keep the same ‘baseline’ and list of policy actions; but some of the policy actions depend on external funding – so they are ‘conditional’.

And so a key question is whether conditional contributions within the NDC need to be accounted for separately, and how.

An increasing number of NDCs use ‘net zero’ targets.  The term ‘net zero’ doesn’t appear in the Paris Agreement, but is derived from language in Article 4 of the agreement that calls for countries to ‘achieve a balance between anthropogenic emissions by sources and removals by sinks of greenhouse gases in the second half of this century, on the basis of equity’.  This is explained in more detail at the Mandate from Paris Agreement page.

‘Net Zero’ is mixed up with the question of ‘cooperative approaches’.  If a country manages to replant a lot of forests while bringing emissions in power, building, and transport sectors to near zero, then it is possible that the country could be ‘net zero’.  But CLARA notes the importance of having separate targets for fossil-fuel sectors, and the land-use sector.  In that case, there is no reason to use ‘net zero’.  The country reports two figures:  any remaining fossil-fuel emissions, and then separately the combination of emissions and removals that’s found in the land-use sector.  This is called ‘gross emission accounting’ – meaning that the gross emissions are accounted for per sector.

What happens when a rich country, using ‘cooperative approaches’ wants to pay for emission reductions in a developing country, but then claim those reductions as part of its own ‘nationally determined contribution’?  Article 4.13 makes it clear that ‘double counting’ must be avoided, so the emission reduction can only be credited once.  This is the accounting challenge of Paris Agreement Article 6, in cases where countries – or corporations – want to take credit for emission reductions.

Right now, there is nothing to prevent a country from including a ‘conditional target’ in its NDC, noting the importance of climate finance for reaching that conditional target – but not indicating whether those emission reductions will count toward the country’s effort, or whether those emission reductions are assigned to another party.

CLARA joins with many other networks and organizations in calling for the use of ‘real zero’ emission targets – not ‘net zero’.  See CLARA’s analysis here.  A ‘real zero’ target can be applied on a sector-by-sector basis.  CLARA joins with Climate Action Network (CAN) International in supporting the use of a land-sector target that is separate from the overall economy-wide mitigation target.  It is critical to reach ‘zero emissions’ in fossil-fuel-dominated sectors of the economy, as fast as possible.  Mitigation performance in the land sector should NOT be used to offset or excuse inaction, or weaker action, in transportation, industry, buildings, or the electric-power sector.

CLARA is concerned with the term ‘negative emissions’ for that reason.   This term is commonly used in conjunction with ‘net zero’ targets.  At its broadest, it refers to the removal of carbon dioxide from the atmosphere.  Proponents of geoengineering have used the term ‘negative emissions’ as a way to promote carbon dioxide removal as equivalent to avoided or reduced emissions.  The term is also loosely used to cover carbon sequestration in trees and soils.  But ‘negative emissions’ do not decrease the need for very rapid emission reductions.  See analysis here. 

CAN-International released a ‘high level principles and recommendations’ for achieving real zero emissions in September 2020.

See also this FAQ on ‘negative emissions’ produced by FERN.

The OECD has written a technical paper on accounting for baseline targets in NDCs.

In 2018, WRI published a guide to ‘Accounting for Mitigation Components of NDCs’ which includes recommendations for accounting in the land sector.

Kate Dooley and Sivan Kartha analyzed risks associated with ‘negative emission technologies’ (NETs) – looking at feasibility, reversibility, and ecological and social impacts. 

CLARA members led by ETC Group put together a 2018 sign-on letter calling out the risks from geoengineering. See manifesto here.