How could the adequacy of an NDC’s target be assessed in terms of its ambition, including fairness and equity principles?
Based on our analysis of the text of the Paris Agreement, and the modalities and procedures that have been (or are in the process of being) adopted by Parties to the Agreement, there appears to be limited scope for any substantive assessment of individual NDCs to be conducted by the bodies established under the Agreement or as part of the Agreement’s formal review and transparency mechanisms. Not only is there no body or mechanism that is expressly mandated to carry out individual assessments of NDCs, but, in the case of the Enhanced Transparency Framework (ETF), Global Stocktake and compliance mechanism, the Parties have adopted—or appear to be poised to adopt—rules that explicitly rule out the possibility of any such evaluation taking place. The absence of any such review mechanism from the Agreement is not accidental; rather it reflects a reluctance on the part of a number of State Parties to have the substance of their individual NDCs subjected to formal external assessment. For similar reasons, it appears unlikely that intergovernmental bodies that exist independently of the Agreement, such as the UNEP, would in the foreseeable future be permitted to expand their mandate to conduct individual assessments of NDCs.
The most promising avenue for the individual assessment of NDCs appears to be independent evaluations by academics and NGOs. Although such assessments are less authoritative than a formal review conducted under the auspices of the Agreement, there are a number of examples of rigorous and comprehensive evaluations carried out by individuals and organisations with high levels of technical expertise. These assessments consider factors such as countries’ responsibility for past emissions, their economic capability to reduce emissions, equality in terms of per-capita emissions targets, and the cost efficiency of available emission reduction techniques. Just as the findings of organisations such as Human Rights Watch garner substantial public attention and can indirectly influence the actions of governments in the human rights sphere, there is potential for the analyses and opinions of certain climate change organisations to carry significant weight in the minds of the global public. This may in turn impact the decision-making of governments when revising their NDCs. Moreover, while the Agreement itself does not provide for individual NDC assessments, the information and analyses that State Parties are obliged to provide through mechanisms such as the Global Stocktake and ETF will assist academics and NGOs to produce accurate NDC assessments that reflect the newest and most reliable data.
This memorandum provides an overview of the different options that might be considered for the assessment of individual nationally determined contributions (“NDC”s) under the Paris Agreement (the “Agreement”). Specifically, we discuss below:
- The background to the assessment of NDCs, including (i) the scope of Parties’ obligations with respect to NDCs, (ii) the principles of equity and common but differentiated responsibilities, and (iii) the divergent views regarding the process for reviewing Parties’ NDCs that emerged during the negotiations that led to the Agreement (section 2).
- Potential mechanisms for the individual assessment of NDCs under the Agreement (section 3).
- Potential approaches for the individual assessment of NDCs outside of the Agreement and existing assessment methodologies (section 4).
In our view, the mechanisms established under the Agreement do not envisage the individual assessment of NDCs and are unlikely to provide viable options for such assessment. However, independent organisations have already begun to carry out and publish comprehensive and sophisticated assessments of individual NDCs in terms of their ambition and adequacy. Although conducted outside the auspices of the Agreement, such assessments have the potential to influence State action on climate change and may be the most expedient way to address Parties’ desire for greater individual accountability with respect to the level of ambition in individual NDCs.
One of the core obligations Parties have under the Agreement is to “prepare, communicate and maintain successive nationally determined contributions”, or NDCs. Such NDCs must be published every five years. The scope and content of NDCs is not prescribed in the Paris Agreement, but Article 4.3 of the Paris Agreement provides for an upwards ratcheting of Parties’ NDCs in terms of ambition, stipulating that each Party’s successive nationally determined contribution will represent a progression beyond the Party’s then current nationally determined contribution and reflect its highest possible ambition.
As various commentators have noted, the use of NDCs as the central mechanism for achieving the goals of the Agreement reflects a “bottom up” approach, i.e. one that is driven by the Parties setting their own individual objectives and policies, rather than stipulating hard commitments “from above”, such as specific quotas for reduction of greenhouse gas emissions.
The Paris Agreement makes it clear that the formulation of individual NDCs must take into account principles of equity and common, but differentiated, responsibilities and respective capabilities (“CBDR-RC”). These principles, which are common to various climate change treaties, are embedded in the UN Framework Convention on Climate Change (the “Convention”), which provides at Article 3 that the Parties should protect the climate system for the benefit of present and future generations of humankind, on the basis of equity and in accordance with their common but differentiated responsibilities and respective capabilities.
The principles of equity and CBDR-RC encapsulate the notion that the burden of climate change mitigation and adaptation must be borne fairly. Accordingly, developed countries should shoulder a greater burden in mitigating climate change than developing countries given that developed countries: (i) have contributed more to climate change historically through the process of industrialisation; and (ii) possess greater resources to contribute to mitigating climate change than developing countries.
The principles of equity and CBDR-RC are manifested in various provisions of the Paris Agreement. For example:
- The third paragraph of the Preamble to the Agreement reads as follows: “In pursuit of the objective of the Convention, and being guided by its principles, including the principle of equity and common but differentiated responsibilities and respective capabilities, in the light of different national circumstances”;
- The final paragraph of the Preamble refers to “developed countries taking the lead”;
- Article 2.2 provides that “This Agreement will be implemented to reflect equity and the principle of common but differentiated responsibilities and respective capabilities, in the light of different national circumstances”;
- Article 4.1 provides that the Parties aim to “reach global peaking of greenhouse gas emissions . . . on the basis of equity”; and
- Article 9 provides that “[d]eveloped country Parties shall provide financial resources to assist developing country Parties with respect to both mitigation and adaptation in continuation of their existing obligations under the Convention.”
The above provisions indicate that the principles of equity and CBDR-RC are intended to guide the interpretation and implementation of commitments under the Agreement. Article 2.2 shows that equity and CBDR-RC are intended to underpin the Agreement in general terms, and Article 4.1 makes it clear that equity is meant to specifically inform NDCs. Accordingly it is arguable that such principles should be taken into account in any substantive assessment of individual NDCs.
During the negotiations that led to the Agreement, divergent views emerged regarding whether the ambition of individual NDCs should be evaluated as part of the review process to be established under the Agreement. Some Parties, including the European Union, the Independent Association of Latin America and the Caribbean, and the Marshall Islands, were in favour of assessing contributions on an individual basis, as well as an aggregate basis. Other Parties, such as the US, Switzerland, Korea and Brazil, supported assessment only on an aggregate level, sharing Singapore’s view that the objective is not to pass judgement on individual NDCs. Several Parties, including China, the Arab Group and Australia, opposed any formal evaluation of NDCs against standards of fairness or ambition. As outlined in further detail below, these differing opinions resulted in the absence in the Agreement of any formal mechanism for assessing the ambition of individual NDCs.
3. Potential mechanisms for the individual assessment of NDCs
In its Articles 13 to 15, the Paris Agreement establishes a system to report on climate action taken (enhanced transparency), assess the combined global impact of measures (global stocktake) and facilitate the implementation of commitments (by the Article 15 Committee). This section examines if and to what extent this could potentially include the review of mitigation targets’ adequacy:
3.1 Article 13 – Enhanced Transparency Framework (ETF)
Article 13(1) of the Agreement establishes an enhanced transparency framework for action and support. The framework aims to provide transparency in relation to two main areas of activity under the Agreement: first, the Parties’ mitigation and adaptation efforts (“transparency of action”); and second, the financial support provided and received by Parties in the context of climate change actions (“transparency of support”).
In order to achieve “transparency of action”, the enhanced transparency framework (“ETF”) requires each Party to submit, on a biennial basis, an inventory report of anthropogenic emissions and “[i]nformation necessary to track progress made in implementing and achieving its [NDCs]”. This information will then undergo a “technical expert review” that will consider the Party’s implementation of its NDC and identify areas of improvement. The Parties are also required to participate in a facilitative, multilateral consideration of progress with respect to the implementation of their respective NDCs.
There appears to be limited scope to incorporate the evaluation of individual NDCs within the ETF. The text of the Agreement makes clear that the ETF is intended to provide accountability in relation to the Parties’ implementation of their NDCs as communicated, rather than a means by which to evaluate the ambition or adequacy of the NDCs themselves. Article 13(5) states that the purpose of the framework is “to provide a clear understanding of climate change action . . . including clarity and tracking of progress towards achieving Parties’ individual [NDCs].” Moreover, Article 13(3) specifies that the ETF is intended to be implemented in a “facilitative, non-intrusive, non-punitive manner, respectful of national sovereignty, and avoid placing undue burden on Parties.” This language suggests that the Parties intended to exclude from the ETF process any form of political judgment regarding the adequacy of NDCs.
This interpretation is supported by the detailed rules for the implementation of the ETF that were agreed upon by the Parties in 2018. These rules expressly bar the technical expert review teams from “mak[ing] political judgments” or “review[ing] the adequacy or appropriateness of a Party’s NDC under Article 4 of the Paris Agreement”.
It is possible that Parties could choose to comment on the adequacy of other Parties’ NDCs during the “facilitiative, multilateral consideration of progress” (“FMCP”), which takes places following the publication of a Party’s technical expert review report. Any Party may submit written questions to the Party under review, and may also put questions to the Party during a working group session. However, such questions are required to be “consistent with the scope” of the FMCP, which is described as “a consideration of progress with respect to the Party’s . . . implementation and achievement of its NDC”. States may therefore be reluctant to interrogate the adequacy of a Party’s NDC during this process, and the Party under review will likely not consider themselves obligated to respond to such questions.
3.2 Article 14 – Global stocktake
Article 14(1) tasks the Parties to periodically take stock of the implementation of the Agreement to assess collective progress towards achieving the purpose of the Agreement and its long-term goals. Such a meeting of the Parties, referred to as the “global stocktake”, is to take place “in a comprehensive and facilitative manner” and “in light of equity and the best available science”. It will be held every five years, with the first meeting due to take place in 2023. Article 14(3) specifies that the outcome of the global stocktake shall “inform Parties in updating and enhancing, in a nationally determined manner, their actions and support . . . as well as in enhancing international cooperation for climate change action”. The global stocktake has been described by commentators as “a hybrid between an effectiveness review and an ambition mechanism,” intended to reveal remaining action gaps and to inspire and drive new activities.
In the decision adopting the Agreement, the Parties agreed that the information they would provide when communicating their NDCs “may” include, inter alia, “how the Party considers that its nationally determined contribution is fair and ambitious, in the light of its national circumstances, and how it contributes towards achieving the objective of the Convention”. Whilst this in theory introduces a degree of accountability of Parties’ actions, the global stocktake contains no mechanism by which the accuracy of such statements may be scrutinised or the ambition of individual NDCs may be assessed. Although the outcome of the global stocktake is intended to spur Parties to scale up the ambition of their individual actions, under Article 14(1), the mandate of the global stocktake is limited to the assessment of the Parties’ “collective progress” towards achieving the objectives of the Agreement. This limited mandate is reinforced by the Decision on the modalities for the global stocktake, which emphasizes that NDCs will only be evaluated on an aggregate basis, and that any official conclusions drawn from such analysis will be pitched at the collective, rather than individual, level. For instance, the modalities provide, in relevant part, that:
- the sources of input for the global stocktake will include information at collective level on the overall effect of the nationally determined contributions communicated by Parties; and
- the outputs should focus on the stocktake of the implementation of the Paris Agreement to assess collective progress, have no individual Party focus and include non-policy prescriptive consideration of collective progress.
We note that the sources of input will also include information on fairness considerations, including equity, as communicated by Parties in their NDCs. But it is likely to be of limited or no use in terms of providing ammunition for individual assessments as the modalities make it clear that this information is also to be considered at collective level.
It is therefore unlikely that any meaningful evaluation of individual countries’ NDCs can be incorporated into the formal global stocktake process at this stage. As commentators have observed, the mandate of the GST is too narrow to allow for effective naming and shaming. It is, of course, open to the Parties to agree to expand the mandate of the global stocktake to include the assessment of individual NDCs. This would not necessarily require the renegotiation of Article 14—to the extent that the sum of individual NDCs determines the state of collective progress, it is arguable that the scrutiny of individual NDCs falls within, and is supportive of, the aim of the global stocktake “to assess collective progress towards achieving the purpose of [the] Agreement and its long-term goals”. However, given the divided reactions to the idea of individual NDC evaluations during negotiations, and the apparent consensus that has formed around aggregate assessment of NDCs, it seems unlikely that any such an expansion of the mandate of the global stocktake will take place in the near future.
3.3 Article 15 – Mechanism to facilitate implementation and compliance
Article 15(1) of the Agreement establishes a mechanism “to facilitate implementation of and promote compliance with the provisions of [the] agreement.” Article 15(2) stipulates that the compliance mechanism “shall be expert-based and facilitative in nature and function in a manner that is transparent, non-adversarial and non-punitive.”
The modalities and procedures for the structure and functioning of the compliance mechanism committee (the “Compliance Committee”) were adopted by the COP during the third part of its first session in Katowice from 2-15 December 2018. Such modalities and procedures provided that the Committee would consist of 12 members, to be elected by the Conference of the Parties (the “COP”). Such election would take place “on the basis of geographical representation”, and the Committee would include two members from each of the UN’s five regional groups, as well as one member each from the least developed countries and small island developing States.
On the face of Article 15, the Committee’s mandate could potentially include the assessment of individual NDCs, since the purpose of the compliance mechanism is to “facilitate implementation of and promote compliance with” the Agreement. The formulation and communication of NDCs is a core part of the Parties efforts to achieve the objectives of the Agreement. Thus, the assessment of such NDCs would arguably fall within the scope of facilitating implementation and promoting compliance as referenced in Article 15.
However, the modalities and procedures adopted by the COP with respect to the Compliance Committee appear to exclude the individual assessment of NDCs from the Compliance Committee’s mandate. For example, such modalities and procedures provide that the Compliance Committee “will initiate the consideration of issues in cases where a Party has not . . . (i) Communicated or maintained a nationally determined contribution under Article 4 of the Paris Agreement.” The modalities and procedures therefore appear only to envisage action by the Compliance Committee where a Party has failed to communicate an NDC, not the examination of NDCs that have been submitted. To the extent there was any doubt about the issue, the modalities and procedures further stipulate that “[t]he consideration of the issues referred to in paragraph 22(a) above [i.e. the issues that the Compliance Committee may initiate consideration of] will not address the content of the contributions, communications, information and reports referred to in paragraph 22(a)(i–iv) above [which includes NDCs].”
Thus, it appears unlikely that the assessment of individual NDCs could take place under the auspices of the Article 15 Committee. That said, as with the global stocktake under Article 14, it would be possible to seek to expand the mandate of the Compliance Committee to include the individual assessment of NDCs — as noted above, such assessment would arguably fall within the scope of the Compliance Committee’s overall responsibilities under Article 15. However, the expansion of the Compliance Committee’s mandate to include assessment of individual NDCs may be unlikely at this stage given that the issue appears to have already been considered and discounted in the process of agreeing on the modalities and procedures of the Committee.
3.4 Future developments?
The Paris Agreement, however, is a “living instrument” and parties are free to further develop its operational framework and architecture. As mentioned above they could, for example, amend and supplement the relevant implementation rules (on reporting, transparency, stocktaking and compliance facilitation) accordingly. But they may also agree on new and additional initiatives to review and discuss the adequacy of an NDC’s targets in terms of its ambition, fairness, equity or technical capacities of countries.
Within the UNFCCC system there is scope for launching and pursuing such new programmatic initiatives. A complete listing of these would exceed the scope of this paper and their feasibility also depends on the dynamics in the negotiations at the relevant point in time, the wider balance of powers and interests as well as several other aspects. Based on past experience, such a process could, for example, be initiated through work programmes by the subsidiary bodies (for implementation and/or technical advice), requests for additional scientific advice by the International Panel on Climate Change (IPCC) or others, and the creation of a new group of experts with the mandate to assess specific adequacy criteria (to e.g. determine parties’ technical capacities or ambition levels).
4. Approaches outside the Paris Agreement
Although the preparation of NDCs is an obligation created by the Agreement, the assessment of individual NDCs does not necessarily need to be undertaken by State Parties to, or bodies established under, the Agreement. In the section below, we consider other governmental and non-governmental entities and groups that may be better positioned to conduct evaluations of NDCs.
4.1 Assessment by the UNEP or another UN body
It is possible that a neutral intergovernmental organisation with appropriate expertise could conduct and publish evaluations of Parties’ individual NDCs. It has been suggested that the United Nations Environment Programme (“UNEP”) might be well suited to this role. Climate change is one of the UNEP’s seven thematic areas of work, and for over 10 years the UNEP has published an annual Emissions Gap Report that analyses the difference between the predicted level of greenhouse emissions in 2030 and the level required to avoid the worst impacts of climate change. The UNEP may therefore possess the technical expertise, as well as the requisite level of credibility and perceived neutrality, to effectively analyse and report on the adequacy of individual Parties’ NDCs. However, the UNEP’s programme of work and budget is decided by the UN Environment Assembly, and therefore a broad level of support from State Parties would be required in order for the UNEP to be authorised to take on this task.
4.2 Independent assessments by NGOs and other civil society actors
Numerous non-governmental organisations (“NGOs”) and academics in the field of climate change science and policy already conduct and publish in-depth evaluations of the ambition the Parties’ individual NDCs, using a variety of different methodologies.
Some assessment techniques that have been suggested to date are relatively straightforward. For instance, an NDC may be evaluated by comparing the level of a country’s projected emissions against the country’s emissions levels in 1990, reflecting the expectation that early industrialized (Annex I) countries would reduce their emissions to 1990 levels by 2000. Alternatively, NDCs can be assessed with reference to the country’s projected level of ‘peak’ emissions per capita (i.e. the point at which a country’s greenhouse gas emissions will peak and then decline). However, these more simplistic methodologies come with significant disadvantages. For example, a comparison to 1990 emission levels is inappropriate for countries that were only at an early stage of development in 1990, and a ‘fair’ level of peaking is not equal for all countries, given that, due to technological advancements, a country that peaks later can reach the same development status with lower emissions.
More nuanced assessment methodologies take into account several different criteria or principles and accordingly provide greater room for considerations of equity and CBDR-RC. A few of the most sophisticated and high-profile assessments include: the Climate Action Tracker, a project of Climate Analytics and the NewClimate Institute that is funded by a number of climate foundations as well as the German Ministry for the Environment; the Climate Equity Reference Calculator, which is a project of the thinktank EcoEquity and the Stockholm Environment Institute; and the Paris Equity Check, designed by a group of academic researchers in Europe and Australia.
The principles and criteria most commonly applied as part of these complex assessment methodologies include:
- Responsibility – countries that historically emitted higher levels of carbon dioxide now bear a greater responsibility to reduce their emissions.
- Economic capability – countries with higher levels of economic capability (often measured by GDP per capita) can afford, and are arguably obliged, to do more to reduce their emissions.
- Equality – emissions should be reduced so that cumulative emissions per capita reach the same level.
- Cost efficiency- the total cost of abatement efforts per GDP should be equal.
There are competing views as to which of these principles are most significant when it comes to determining whether an NDC is sufficiently ambitious. These competing views can be reflected in the respective weight that is attributed to each criteria in a given assessment methodology. This weighting determines whether, assessed overall, a particular NDC is considered fair or sufficiently ambitious—the same NDC can be assessed as either adequate or inadequate depending on the weight attributed to each criterion. For instance, if the starting point for an assessment is that the highest historical emitters should bear the greatest burden (i.e. if the ‘responsibility’ criterion is weighted most heavily), the NDC of a country with historically low emissions may be considered adequate overall even if the NDC scores low against other criteria. On the other hand, if a country’s economic capability to mitigate climate change is taken to be the most pertinent consideration, the NDC of a developing country that has done little to cause climate change may be inadequate overall if the planned mitigation efforts are not proportionate to the country’s capabilities.
An assessment methodology should be transparent about the weight it attributes to different criteria, so that the outcome of the assessment can be properly understood. For instance, the Climate Equity Reference Calculator allows users to adjust the calculator’s settings to reflect the relative weight they to place on the principles of ‘responsibility’ and ‘capability’ in the assessment: 
The Climate Action Tracker (“CAT”) is a further example of a sophisticated assessment methodology. Recognising that “[t]here is no single, agreed framework on what is a fair contribution to global efforts,” the CAT assessment draws on seven different criteria from the literature to construct a “Fair Share” range of emission reductions for each country, with the low end of the range corresponding to modest emission reductions and the high end representing greater emission reductions. So, for a country with low historical emissions but strong economic capabilities, the ‘responsibility’ criterion might be set at the lowest end of the Fair Share range (because, from a responsibility standpoint, it is “fair” for the country to have a less ambitious reduction target), whereas the highest end of the range might be set by the ‘capability’ criterion (because, given its capabilities, it is “fair” to expect the country to take more drastic reduction actions).
The CAT then determines whether the country’s projected emissions reduction contribution under the NDC falls within its Fair Share range. Finally, the NDC is evaluated on the basis of where within the Fair Share range it falls, and is categorised as either ‘Insufficient’, ‘2°C compatible’ or ‘1.5°C compatible’. These categories correspond to the temperature outcomes that would result if all other governments were to put forward NDCs with the same relative ambition level. NDCs that are considered ‘fair’ based on some criteria, and that therefore fall within the Fair Share range, may still not be considered sufficient in terms of achieving the Paris Agreement’s 1.5°C warming limit.
4.3 The potential impact of independent assessments
In the lead-up to the Paris Climate Conference, the results of independent analyses of Parties’ intended NDCs were widely disseminated, discussed in the media, and relied upon by Parties and civil society actors in the negotiation process. Going forward, the potential for such assessments to be formally acknowledged or discussed during the Agreement’s review processes is uncertain. In the case of the global stocktake, for instance, the modalities signal an openness to input from civil society, referring to the “active participation of non-Party stakeholders”, listing “[s]ubmissions from [non-Parties and] accredited UNFCCC observer organization stakeholders” as sources of input to the stocktake, and requesting that the secretariat “facilitate online access to all inputs to the global stocktake from Parties [and non Party stakeholders]”. But, as with other inputs to the global stocktake, any official input from civil society would likely be limited to submissions and information regarding the “overall effect” of the NDCs communicated by the Parties.
There will, however, be opportunities for the assessments of individual NDCs by civil society actors to informally feed into the Agreement’s review cycles and to impact State Party decision-making around NDCs. Civil society actors can utilise their usual advocacy techniques to convey their messages, including public shaming (or “faming”, in the case of well-performing Parties), direct lobbying and the dissemination of information through Party meeting side-events, and traditional and social media. There are indications that civil society’s efforts around the global stocktake will be particularly well organised. For instance, a consortium of civil society actors have formed the Independent Global Stocktake (the “iGST”), which aims to move beyond the “the political realities that constrain the formal process” to push for a robust stocktake that empowers countries to take more ambitious climate action. Piggy-backing on the public attention attracted by the global stocktake, the iGST aims, inter alia, to fill the information gaps in the official stocktake and to formulate and communicate country-specific recommendations.
 Paris Agreement to the United Nations Framework Convention on Climate Change, 2 December 2015 (“Paris Agreement”), Article 4.2.
 Paris Agreement, Article 4.9.
 See, e.g., Pieter Pauw et al., Subtle Differentiation of Parties’ Responsibilities under the Paris Agreement, 5(1) Palgrave Communications 1 (2019), p.2.
 Harro van Asselt et al., Assessment and Review under a 2015 Climate Change Agreement, TemaNord (2015), p.55.
 Submission by Singapore to the Ad Hoc Working Group on the Durban Platform for Enhanced Actions (ADP) – Workstream 1, 22 May 2014, p. 4.
 Harro van Asselt et al., Assessment and Review under a 2015 Climate Change Agreement, TemaNord (2015), p.54.
 See Paris Agreement, Article 13(5).
 See Paris Agreement, Article 13(6).
 Paris Agreement, Article 13(7); see also Article 13(4).
 See Paris Agreement, Article 13(12).
 See Paris Agreement, Article 13(12).
 See UNFCCC, Decision 18/CMA.1, Annex 1, Modalities, procedures and guidelines for the transparency framework for action and support referred to in Article 13 of the Paris Agreement (Document FCCC/PA/CMA/2018/3/Add.2, 19 March 2019), paragraph 149.
 See further Romain Weikmans et al., Transparency requirements under the Paris Agreement and their (un)likely impact on strengthening the ambition of nationally determined contributions (NDCs), 1 Climate Policy 11-13 (2019).
 Paris Agreement, Article 14(1).
 Paris Agreement, Article 14(3).
 M. Milkoreit & K. Haapala, The global stocktake: design lessons for a new review and ambition mechanism in the international climate regime, 19 Int. Environ. Agreements 89 (2019), p. 90.
 See Paris Agreement, Article 14(3).
 UNFCCC (2018), Matters relating to Article 14 of the Paris Agreement and paragraphs 99-101 of decision 1/CP.21. Decision 19/CMA.1, paragraph 36(b).
 Decision 19/CMA.1, paragraph 14.
 Decision 19/CMA.1, paragraph 36(h).
 L. G. Hermwille et al., Catalyzing mitigation ambition under the Paris Agreement: elements for an effective Global Stocktake 19(8) Climate Policy 988 (2019), p. 997.
 Paris Agreement, Article 14(1).
 Paris Agreement, Article 15(1).
 UNFCCC, Decision 20/CMA.1, Annex 1, Modalities and procedures for the effective operation of the committee referred to in Article 15, paragraph 2, of the Paris Agreement (Document FCCC/PA/CMA/2018/3/Add.2), 5 (“Article 15 Modalities”).
 Article 15 Modalities, 22.
 Article 15 Modalities, 23.
 See, e.g., Frauke Röser et al., Options for assessing ambition of mitigation commitments beyond Paris, NewClimate Institute, December 2015, pp. 12-13.
 See United Nations Framework Convention on Climate Change, Article 4(2)(b); Niklas Höhne et al., Assessing the ambition of post-2020 climate targets: a comprehensive framework, 18(4) Climate Policy (2018), p. 427.
 Climate Action Tracker, “Comparability of Effort”, https://climateactiontracker.org/methodology/comparability-of-effort/.
 See Romain Weikmans et al., Transparency requirements under the Paris Agreement and their (un)likely impact on strengthening the ambition of nationally determined contributions (NDCs), 1 Climate Policy (2019), p. 2; Frauke Röser et al., Options for assessing ambition of mitigation commitments beyond Paris, NewClimate Institute, December 2015, pp. 11-12.
 Joint reflections note by the presiding officers of the APA, the SBSTA and the SBI. Addendum 7. Matters relating to Article 14 of the Paris Agreement and paragraphs 99–101 of decision 1/CP.21, 15 October 2018, paragraphs 13, 57(i) and 26.
 Joint reflections note by the presiding officers of the APA, the SBSTA and the SBI. Addendum 7. Matters relating to Article 14 of the Paris Agreement and paragraphs 99–101 of decision 1/CP.21, 15 October 2018, paragraph 56(a).
 See https://www.climateworks.org/independent-global-stocktake/; see also Lukas Hermwille et al., Catalyzing mitigation ambition under the Paris Agreement: elements for an effective Global Stocktake 19(8) Climate Policy (2019), pp.998-999.