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14 February 2014 NON-PAPER on the Draft Technical Paper FCCC/TP/2013/3 I. This paper contains the comments of Turkey on the draft technical paper FCCC/TP/2013/3 prepared by the Secretariat in line with the mandate given by the COP decision 1/CP.18. II. Decision 2/CP.17 stipulates that the modalities for provision of support to Turkey in the fields of mitigation, adaptation, technology development and transfer, capacity building and finance need to be discussed and decided. III. Following the COP 17, Turkey sent a letter to the Secretariat on 30 April 2012 requesting the Secretariat and the executive committees of the relevant bodies under the Convention to elaborate on the ways and means through which Turkey will be able to benefit from the support mechanisms under the Convention. However, no progress has been made in this regard and a need for implementing decision 2/CP.17 emerged. IV. Decision 1/CP.18, which is a follow-up to decision 2/CP.17, reaffirmed the importance of financial, technological and capacity-building support to Turkey to enhance its efforts in combating climate change and urged Annex-II Parties, which are in a position to do so, to support Turkey. Decision 1/CP.18 requested the Secretariat to identify opportunities for Turkey to benefit from support from the relevant bodies and institutions. Therefore, at the COP 18, Parties gave a mandate to the Secretariat to assume a “guiding role” for the identification of the modalities by providing technical and legal opinion regarding the current and prospective opportunities for provision of support to Turkey under the Convention. V. The Secretariat prepared and distributed a draft technical paper on 30 May 2013. In fact, the paper was drafted unilaterally by the Secretariat without consulting with Turkey. VI. The draft technical paper falls short of fulfilling the above-mentioned mandate and the expectations of Turkey. In this context, it needs to be improved by taking the following suggestions and observations into consideration: 1 1. Paragraph 8 of Chapter II Section A points out that Turkey is an upper middle income country that remains eligible for official development assistance. In addition to that, it would be appropriate to make a reference in this section to the fact that Turkey is a “developing country”. 2. Paragraph 9 of Chapter II Section A should be extended by presenting indicators regarding Turkey’s economic growth rate, rate of increase in annual energy demand, energy intensity, per capita greenhouse gas emissions etc. in line with the 5th National Communication of Turkey and the 1990-2011 National Greenhouse Gas Inventory of Turkey. 3. The title of the Chapter II Section C should be amended as “Climate change policies of Turkey” since it contains the principal elements of the climate change policy of Turkey as set out by the relevant national documents. 4. Chapter III needs to be restructured to reflect the areas for support mentioned in the relevant COP decisions with regard to Turkey and its title should be renamed accordingly. Opportunities need to be elaborated and identified under separate sections on “mitigation”, “adaptation”, “technology development and transfer”, “capacity building” and “access to finance” instead of being discussed in conjunction with the mandates and work of the bodies and other arrangements established under the Convention and the Kyoto Protocol. Some useful elements presented in the sections under Chapter III of the current draft should be reflected to the relevant sections of the new Chapter III. There is no need to retain Sections B, E and J under Chapter III of the current draft. 5. Chapter II Section D should be moved to Chapter III Section on Capacity Building. The priority areas in this section are identified with a view to addressing only the capacity building needs of Turkey and they are inspired from the relevant decisions taken for the countries that are undergoing the process of transition to a market economy. 6. The following priority areas should be included in “Mitigation Section” under Chapter III: a. Identification and implementation of NAMAs, b. Identification of emission reduction alternatives in each sector, 2 c. Quantifying economy wide impacts of mitigation policies, d. Analysis for impediments and obstacles such as large capital costs or technology, e. Developing market based mechanisms and other approaches. This section can be improved using the following: Turkey has reduced its GHG emissions 21 per cent from the business as usual scenario during the period 1990-2012 by mostly domestic measures and resources. The total amount of GHG emission reduction is estimated as 1.5 billion tons of CO2 equivalent. This figure does not include the forestry in which Turkey has invested US$ 2 billion between 2008 and 2012. The carbon intensity (kg CO2 per PPP $ of GDP) of the Turkish economy was reduced more than 50 per cent, i.e. from 0.61 to 0.3 between 1990 and 2010. There is no provision in the Convention which prevents Annex-I Parties from taking NAMAs. Furthermore, section 3 of decision 1/CP.16 on “Enhanced Action on Mitigation” provides the flexibility in this regard. Turkey plans to reduce its emissions relative to business as usual emissions by taking nationally appropriate mitigation actions (NAMAs). It is the only way through which Turkey can contribute to the global efforts to mitigate climate change. In this vein, NAMAs to be presented by Turkey are expected to be supported financially and technologically. 7. The following priority areas should be included in “Adaptation Section” under Chapter III: a. Strengthening water resources management capacity with regard to adaptation to climate change, b. Identifying social, economic and environmental vulnerabilities in watersheds, and developing and implementing adaptation programs and actions to address them, c. Formulating, developing and disseminating innovative alternative solutions to increase adaptation capacity to climate change, d. Identifying threats and risks for management of natural disasters caused by climate change, e. Establishing, expanding or improving monitoring and observation networks and developing forecasting and early warning systems. This section can be improved using the following: 3 “The COP at its seventeenth session invited the operating entities of the financial mechanism of the Convention, bilateral and multilateral organizations and other institutions, to provide financial and technical support to developing country Parties to plan, prioritize and implement their national adaptation planning measures. Decision 12/CP.18 urged developed country Parties to mobilize financial support for the national adaptation plan process for interested developing country Parties that are not least developed country Parties through bilateral and multilateral channels, including through the Special Climate Change Fund, in accordance with decision 1/CP.16. In this context, the Adaptation Committee can consider the modalities for provision of support to Turkey.” 8. Turkey has been benefiting from the Fast Start Financing, GEF and bilateral support. Information with regard to the support received by Turkey is annexed to this Non-Paper. Chapter IV of the draft technical paper should be revised in line with the information provided. 9. Given that the COP, at its eighteenth session, urged Parties to support Turkey included in Annex II to the Convention which are in a position to do so, to provide support to Turkey in conjunction with its special circumstances and that Turkey has been benefiting from various financial support mechanisms as mentioned above, it is highly important for Turkey to receive such a support in the future in an equitable manner. In this regard, Turkey should benefit from the long term finance under the Convention, in particular, the Green Climate Fund. Therefore, in addition to afore-mentioned points, the “Access to Finance Section” under Chapter III can be drafted using the following: “The COP, at its sixteenth session, decided to establish a Green Climate Fund, to be designated as an operating entity of the financial mechanism of the Convention under Article 11, to support projects, programmes, policies and other activities in developing country Parties to limit or reduce their greenhouse gas emissions and to adapt to the impacts of climate change. The Fund will be ready for capitalization in the second half of 2014 and will play a key role in channeling new, additional, adequate and predictable financial resources to developing countries. The Fund will be scalable and flexible and will be a continuously learning institution guided by processes for monitoring and evaluation. The Fund will receive financial inputs from developed country Parties (Annex II Parties) to the Convention. 4 A significant share of new multilateral funding for adaptation will flow through the Green Climate Fund. The Fund will finance agreed full and agreed incremental costs for activities to enable and support enhanced action on adaptation, mitigation (including REDD-plus), technology development and transfer (including carbon capture and storage), capacity building and the preparation of national reports by developing countries. There is no provision in any decision by the COP with regards to the Green Climate Fund stipulating that Annex I Parties cannot be supported through the Fund. The Fund will support developing countries in pursuing project-based and programmatic approaches in accordance with climate change strategies and plans, such as low-emission development strategies or plans, nationally appropriate mitigation actions, national adaptation plans of action, national adaptation plans and other related activities. The COP, at its eighteenth session, urged Parties included in Annex II to the Convention which are in a position to do so, through multilateral agencies, including the Global Environment Facility within its mandate, relevant intergovernmental organizations, international financial institutions, other partnerships and initiatives, bilateral agencies and the private sector, or through any further arrangements, as appropriate, to provide financial, technological, technical and capacity-building support to Parties included in Annex I to the Convention (Annex I Parties) whose special circumstances are recognized by the Conference of the Parties in order to assist them in implementing their national climate change strategies and action plans and developing their low-emission development strategies or plans in accordance with decision 1/CP.16. The COP, by this decision, confirmed once again that Turkey is eligible for support through operating entities under the Convention as well as various other arrangements. In conjunction with the decision, the Green Climate Fund is regarded within “any further arrangement” through which Turkey can receive financial support, since the establishment process of the Fund has not been completed when decision 1/CP.18 was made by the COP. In this context, the Board of the Green Climate Fund can discuss Turkey’s situation in a separate agenda item with a view to developing and approving operational and access modalities which enable Turkey to access financial resources to implement its low-emission development strategies, nationally appropriate mitigation actions and national adaptation plans. In fact, the decision 2/CP.17 gives a mandate to all subsidiary bodies under the Convention to discuss the modalities for provision of support to Turkey. 5 The Secretariat can liaise with Turkey to provide necessary guidance and information to implementing entities, and cooperating bilateral and multilateral institutions and agencies and include Turkey in the operationalization of the project and programme cycle processes.” 10. The Technology Section under Chapter III can be drafted using the following: “Article 4, paragraph 5 of the Convention stipulates that the developed country Parties and other developed Parties included in Annex II shall take all practicable steps to promote, facilitate and finance, as appropriate, the transfer of, or access to, environmentally sound technologies and know-how to other Parties, particularly developing country Parties, to enable them to implement the provisions of the Convention. The COP, at its seventeenth session, noted that Turkey is not included in Annex II to the Convention and as such is not subject to the commitments of Article 4 paragraphs 3 to 5 of the Convention and that Turkey is eligible for support under Article 4 paragraph 5 of the Convention. In this vein, Turkey is eligible to receive environmentally sound technologies and know-how from the developed country Parties listed in the Annex II to the Convention. In fact, it is a commitment made by those Parties to take all practicable steps to promote, facilitate and finance the transfer of essential technologies in order to enhance the capabilities and actions of all Parties in combating climate change. The Technology Mechanism established under the Convention, which consists of TEC and CTCN, has a mandate for facilitating the implementation of enhanced action on technology development and transfer to support action on mitigation and adaptation as well as recommending actions to address barriers to technology development and transfer. The COP, at its seventeenth session, decided that the TEC shall further implement the framework for meaningful and effective actions to enhance the implementation of Article 4, paragraph 5, of the Convention. Paragraph 120 of 1/CP.16 lists the priority areas of the Technology Mechanism that could be considered under the Convention in a flexible manner. Deployment and diffusion of environmentally sound technologies and know-how in developing country Parties is among the priorities. Developing country Parties are highlighted in this paragraph. However, it does not create any barrier for deployment and diffusion of technology to all parties. The subsequent decisions by the COP provide such flexibility as well. In this regard, TEC and CTCN can take the special situation of Turkey as a separate agenda item with a view to; 6 Assisting Turkey to develop and implement national technology plans for mitigation and adaptation, Identifying currently available technologies for mitigation and adaptation that would meet the key low-carbon and climate-resilient development needs of Turkey, Identifying the barriers to technology transfer to Turkey.” 7