Climate action beyond mitigation and the global North


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PARIS has seen the most comprehensive kind of framework for non-state and sub-national climate action to date. The growing importance of such action is part of a larger development towards polycentric climate governance in which traditional state based regimes are complemented by private and hybrid regimes involving both national and sub-national governments, as also civil society, business and investors.

This article focuses on the implications for developing countries and points out three challenges and criticisms of the outcomes of the Paris climate conference to facilitate non-state action. First, both policy and academic discussions have in general been biased towards direct mitigation actions while neglecting action in developing countries. Second, though there is great potential for non-state climate action in the global South, many actions remain ‘under the radar’. Third, in the period before 2020, the international community is heavily betting on non-state and sub-national action. This is a risky strategy when the range of options left to prevent dangerous climate change have shrunk.

Paris has seen a surge in efforts to address climate change by a wide variety of non-state and sub-national stakeholders, including business, investors, civil society, cities and regions. The Non-State Actor Zone for Climate Action (NAZCA), a platform launched at the 2014 Lima Climate Conference by the Peruvian government in collaboration with the UNFCCC, currently features more than 11,000 actions. Through initiatives such as NAZCA and high-level events during climate conferences, non-state actions have gained greater visibility and international acknowledgement. However, increased visibility and acknowledgment is not without risk. A lack of guidelines for (featured) non-state actions could lead to easy UN stamps of approval and green-washing, such that business-as-usual is represented as clean and green. Moreover, without a more systematic tracking of climate actions, overall implications for mitigation and adaptation to climate change may never be properly understood.1 Nonetheless it must be acknowledged that governments have agreed to the most comprehensive framework for non-state and sub-national climate action to date in Paris.

Elements of this framework include (i) an expanded NAZCA platform to register non-state and sub-national action; (ii) the continuation of technical examination processes for mitigation related solutions and enhanced actions before 2020, and a new parallel technical examination processes for adaptation related actions; and (iii) the installation of ‘high-level champions’ to coordinate activities to reach out to a variety of stakeholders.2

Together these elements improve visibility and acknowledgement of non-state and sub-national climate actions within the international climate regime, as well as strengthen the interface between various stakeholders and policy makers. Moreover, these elements constitute an institutional anchor for the continued mobilization of non-state and sub-national actors until at least 2020.3 However, this framework is skewed towards ‘high impact’ mitigation actions, and does not expressly address the under-representation of developing country based stakeholders among climate actions.4 Overall, a heavy reliance on non-state and sub-national actions, even with a more comprehensive framework, remains a risky pre-2020 strategy to prevent dangerous climate change.


A focus on high mitigation potential seems reasonable and necessary to prevent dangerous climate change. In the context of the UNFCCC, the Climate Technology Centre and Network (CTCN), as well as the Technical Examination Process (and related meetings) have focused on identifying high mitigation potential actions and action areas and solutions that are scalable and replicable, though the strategy is not without its risks. In the following I would like to comment on three elements of ‘high mitigation potential’, namely: ‘high’, ‘mitigation’, and ‘potential’.


First, high mitigation potential assumes large-scale action that can accrue significant and measurable GHG emissions reductions. Large-scale action may be ‘scaled up’ from demonstrated mitigation solutions. However, transformative technologies and innovative solutions may (initially) be small-scale, with low mitigation potential in absolute terms. Transformative technologies will need to be demonstrated before they are applied at scale. A comprehensive framework for climate action should, therefore, facilitate innovation and allow for the incubation of transformative technologies rather than only promote large-scale solutions.


Second, high mitigation potential implies a greater focus on GHG emissions reductions than on other aspects of climate change, most notably problems related to resilience and adaptation to climate change impacts. However, a facilitative framework should not ignore the need for adaptation and greater resilience for at least three reasons:

1. Given that many developing countries have long been sceptical of greater non-state and sub-national engagement, their political support for such engagement will depend on sustainability co-benefits of climate actions, rather than only mitigation.5

2. To some extent the post-Paris framework for non-state and sub-national climate action addresses the imbalance between mitigation and adaptation by extending the Technical Examination Process to adaptation.6 However, adaptation and resilience actions still need more support to become effective, as these actions have been relatively underperforming.7

3. A lot of actions labelled ‘high mitigation potential’ are in fact not directly aimed at mitigation.8 Rather, they address a variety of other climate related challenges, including adaptation and aspects of sustainable development. Their designation as ‘high mitigation potential’ is more often a political projection rather than a reflection of the actual and self-stated purposes of climate actions.


Third, the potential of climate actions is often defended on theoretical grounds and more likely to differ from actual impacts. Theoretically speaking, only a few targeted non-state actions and sub-national efforts in high emission sectors could close the global mitigation gap.9 There are, however, problems in realizing this potential.

For one, newly emerging actions rarely help set mitigation targets. Even if they do, their mitigation potential falls (far) short of actually closing the global mitigation gap.10 Current research suggests that non-state and sub-national actions rarely meet – let alone over-achieve – their targets.11 Therefore, a simplistic focus on high mitigation potential may lead to unwarranted and overly optimistic estimations of non-state and sub-national efforts.

An associated concern relates to the double counting of GHG emission reductions. For instance, reductions by a city action may be simultaneously counted as reductions by the city, region, and/or country in which an action takes place.12 This raises the question whether separate emissions accounting at the level of individual climate actions is possible and necessary. I argue that a standardized accounting methodology for emissions across all climate actions is undesirable for political and practical reasons.

First, in the context of the UNFCCC, all emissions accounting occurs at the national level. Second, when non-state and sub-national climate actions are subject to rigid Monitoring, Reporting and Verification (MRV), they are likely to be seen in competition with the international UNFCCC regime. Moreover, quantified emission reductions by climate actions should not become a reason for governments to resile from their mitigation responsibilities. Third, most climate actions would not benefit from, or even be in a position to conduct rigid MRV. Only a few climate actions set direct mitigation targets; many more focus elsewhere. For instance, an action could aim to improve health by combating air pollution – while also generating emissions reduction as a ‘co-benefit’. It is doubtful whether smaller actions should especially invest their scarce capacities into standardized MRV, in particular when mitigation is not the main purpose.


Nonetheless, there is analytical value in tracking climate actions and their mitigation impacts to demonstrate particularly effective solutions and to better understand the scale and aggregate impact of climate actions. The task of tracking non-state climate action, however, should not burden the UNFCCC process, the UNFCCC Secretariat, or smaller-scale climate actions and those that do not primarily focus on mitigation. Existing initiatives such as CDP (for business) and ICLEI’s Carbonn (for cities) should continue to play a role in the tracking of climate actions. Moreover, the analytical community, including researchers, experts and consultants, have already conducted studies and set up databases to track climate actions.13 Most studies and data collection initiatives, however, have focused on tracking promises and mitigation potential (see above). What really matters is to determine what climate actions actually achieve, and under what circumstances.


Multiple studies confirm that developing country based stakeholders are vastly under-represented in non-state and sub-national climate actions.14 While most climate actions (claim to) implement across the developing world, the actions seem to be primarily led by Europe or North American based actors. This pattern seems to reflect an imbalanced reality in which major North based actors define design, fund, and manage climate actions.

Observed imbalances may also be due to a selection bias in international processes (such as the existing Technical Examination Process) and platforms such as NAZCA. Their focus on ‘high mitigation potential’ directs attention to high profile actions, for instance by multinational corporations mostly based in the global North, while ignoring many smaller and community based resilience and adaptation actions in developing countries. A similar selection bias is also found in research, most studies on non-state and sub-national climate action are chiefly concerned with mitigation.15 Very few studies take into account sustainability impacts.16

To effectively respond to the under-representation of developing country based non-state and sub-national stakeholders, a comprehensive framework should both help improve the visibility of non-state and sub-national action in developing countries and also reach out to non-state and sub-national stakeholders in the developing world. Efforts have been undertaken to improve the visibility of climate actions in developing countries, most notably in the contexts of the 2014 UN Climate Summit and the UNFCCC’s Momentum for Change Initiatives.


In the run-up to the Paris Climate Conference, the organizing team of the 2014 UN Climate Summit mobilized new and enhanced climate non-state, sub-national and cooperative initiatives across eight ‘action areas’. Initially these areas encompassed sectors with high mitigation potential, such as transport, energy and forests. However, to better accommodate development needs, ‘resilience’ was added as a separate climate action area.17 Resilience actions focused more on the needs of developing countries, in particular low-income economies.18 However, a year after being launched, it became clear that progress on this front was slow and that many countries had failed to start work.


The UNFCCC secretariat features climate actions with development benefits in its ‘Momentum for Change’ campaign. The campaign highlights initiatives in four focus areas: ‘urban poor’ (‘recognizing climate action that improves the lives of impoverished people in urban communities’); ‘women for results’ (‘recognizing the critical leadership and participation of women in addressing climate change’); ‘financing for climate friendly investment’ (‘recognizing successful and innovate climate smart activities’); ‘ICT solutions’ (‘recognizing successful climate change activities in the field of information and communication technology’). Although the Momentum for Change campaign highlights wider economic, social and environmental challenges, it does not directly redress imbalances between developing and developed countries. In fact, a large majority of initiatives winning the ‘Momentum for Change Lighthouse Activity Award’ is led by stakeholders based in the developed countries.19

To address the under-representation of developing country based stakeholders, continued efforts are necessary. One promising development is the incorporation of the resilience action area in the ‘Action Agenda’, initiated by the French and Peruvian governments, the UNFCCC Secretariat, and the Executive Office of the Secretary of the United Nations. However, not all developing country based climate actions are addressing resilience, and long-term attention is needed to improve the visibility of developing country based climate actions. While parts of the action agenda has been mandated in Paris (in particular relating to pre-2020 action), specific attention to stakeholders in developing countries is not guaranteed. For instance, the Momentum for Change campaign is financed through the budget of the UNFCCC Secretariat, and contingent on the political commitment by the Executive Secretary of the UNFCCC and the (quiet) consent of Parties to the UNFCCC.


The most visible activities to reach out to in the developing world happen at climate conferences, for instance through so-called ‘High-Level Meetings on Climate Action’ (or ‘Action Days’). However, it is questionable whether such events are suitable for facilitating climate action in the developing world. Stakeholders from developing countries may have a limited (e.g. financial) capacity to be present at these events. While such events provide a rare interface between negotiators and non-state and sub-national stakeholders, developing country delegations are usually minimally staffed and need to focus on simultaneous negotiations rather than side events. Regional or national events and processes to explore the potential of non-state and sub-national climate action in developing countries may better address the limitations of smaller developing country based stakeholders and governments.

Not only is there huge potential, but also a need for global South based stakeholder engagement in climate action. In particular, the involvement of cities in developing countries as drivers of climate action will be vital in the next decade. Future infrastructure alone, mostly in the urban global South, would require an estimated third of the remaining carbon budget.20 The good news is that in the run-up to Paris many commitments have been made by cities and regions. Moreover, cities in developing countries are not necessarily under-represented in climate actions such as the ‘C40’ initiative or the ‘Compact of Mayors’, although in other transnational networks they remain under-represented.21 Many city commitments, however, are declarational in nature, for instance in the Paris City Hall Declaration in which mayors promised to exceed the Paris Agreement targets. Engaging cities in the global South is a first step, but commitments and promises need to become actionable. Concerted efforts by the UNFCCC, the wider UN system and governments should help the realization of city commitments, for instance by facilitating access to expertise and finance.


Another, relatively neglected type of stakeholder is business in the global South. Efforts by North based multinational corporations attract much attention at the global stage. However, for most developing countries, small and medium sized enterprises are of greater economic and social importance. One option to increase local business engagement is to focus on upgrading global value chains instead of a single (multinational) corporation. This would create opportunities for smaller suppliers in developing countries to innovate and create more value. Additionally, the role of business should also not be narrowed down to private business alone. State owned enterprises are important drivers and inhibitors of climate action, especially in emerging countries like China, Vietnam and India.


At the 2011 Durban Climate Conference, governments agreed to a separate work stream on pre-2020 mitigation action in the negotiations towards a new agreement. Pre-2020 climate action is necessary to increase the likelihood of limiting the increase of global average temperature below 2 °C above pre-industrial levels. This continues to hold true after Paris, as commitment cycles in which countries update or communicate their climate pledges will only take effect after 2020.

The only agreed strategy on pre-2020 climate action heavily relies on dialogue with non-state and sub-national stakeholders, information sharing, and the ‘technical examination processes’ on mitigation and adaptation. This is a high risk strategy, since very little is known about the effectiveness of non-state and sub-national climate action. Non-state and sub-national actions do not seem a safe bet to produce the pre-2020 results that would allow for a peak and decline of GHG concentration levels by the mid-century (as described in RCP 2.6 and RCP 24.5 scenarios, IPCC AR5).22 First, the gap between potential and realized emissions reductions is likely to be wide (see above). Second, there is also political risk in relying on non-state and sub-national climate actions in the pre-2020 period.

The post-Paris Action Agenda remains overly dependent on the political whims of governments and political leaders. High-level leadership changes within the UN system, in particular a new Executive Secretary of the UNFCCC and a new Secretary General of the United Nations will impact on efforts to engage non-state action. A greater reliance on non-state and sub-national climate actions also requires a high level of political commitment to a more comprehensive facilitative framework that not only solicits promises and commitments, but also encourages real mitigation and adaptation contributions.


There is little doubt that Paris has seen the emergence of the most comprehensive framework for climate action yet. The Paris COP decision has expanded technical examination processes that include non-state and sub-national stakeholders; it has also reaffirmed the NAZCA platform which gives visibility to over 11,000 climate actions; and it institutionalized a longer-term Action Agenda by the appointment of high-level champions for climate action. Nevertheless, this framework is not comprehensive enough. Functionally, it is far too narrowly focused on actions with a ‘high mitigation potential’, while adaptation actions go relatively under-appreciated. In participatory terms, the action agenda does little to address the relative under-representation of stakeholders based in the global South. Therefore, the post-Paris Action Agenda should combine a broader focus on climate impacts with broad engagement with actors in the global South.



1. A. Hsu, et al. ‘Track Climate Pledges of Cities and Companies’, Nature 532, 2016, pp. 303-306.

2. S. Chan, C. Brandi, and S.Bauer, ‘Aligning Transnational Climate Action with International Climate Governance: The Road from Paris’, Review of European, Comparative and International Environmental Law (RECIEL). (forthcoming 2016).

3. S. Chan and P. Pauw, A Global Framework for Climate Action: Orchestrating Non-State and Sub-national Initiatives for More Effective Global Climate Governance. DIE Discussion Paper. Bonn, German Development Institute/Deutsches Institut für Entwicklungspolitik (DIE), 44, 2014; T.N. Hale and L. Chambers, Design Considerations for a Registry of Sub- and Non-State Actions in the UN Framework Convention on Climate Change. Policy Memo, Oxford Blavatnik School of Government, University of Oxford, 2014, 5; S. Chan, R. Falkner, H. Van Asselt, M. Goldberg, Strengthening Non-State Climate Action: A Progress Assessment of Commitments Launched at the 2014 UN Climate Summit. Centre for Climate Change Economics and Policy Working Paper. CCCEP, London, Grantham Research Institute on Climate Change and the Environment, German Development Institute/Deutsches Institut für Entwicklungspolitik, 2015, 53; S. Chan, et al. ‘Reinvigorating International Climate Policy: A Comprehensive Framework for Effective Nonstate Action’, Global Policy 6(4), 2015, pp. 466-473; S. Chan, C. Brandi, and S.Bauer, forthcoming 2016, op. cit., fn. 2.

4. See: L.B. Andonova, et al., How do Domestic Politics Condition Participation in Transnational Climate Governance? Working Paper. Oxford, UK and Princeton, NJ, USA, Political Economy of International Organizations Conference, 35, 2014; H. Bulkeley, et al., Transnational Climate Change Governance. Cambridge University Press, 2014; S. Chan, R. Falkner, H. Van Asselt, M. Goldberg, op. cit., 2015, fn. 3; S. Chan and T. Hale, Galvanizing the Groundswell of Climate Actions in the Developing World. GGCA Working Paper, 2015, 1; Galvanizing the Groundswell of Climate Actions, Lima-Paris Action Agenda Independent Assessment Report, GGCA, 2015, 29.

5. S. Chan and T. Hale, op. cit., 2015, fn. 4.

6. UNFCCC, Adoption of the Paris Agreement. UN Doc. FCCC/CP/2015/L.9/Rev.1 of 12 December 2015, art 124.

7. S. Chan, R. Falkner, H. Van Asselt, M. Goldberg, op. cit., 2015, fn. 3.

8. S. Chan, R. Falkner, H. Van Asselt and M. Goldberg, op. cit., 2015, fn. 3; A. Hsu, et al., ‘Towards a New Climate Diplomacy’, Nature Climate Change 5(6), 2015, pp. 501-3.

9. K. Blok, et al., ‘Bridging the Greenhouse-Gas Emissions Gap’, Nature Climate Change 2(7), 2012, pp. 471-474.

10. A. Hsu, et al., op. cit., 2015, fn. 8; M. Roelfsema, et al., Climate Action Outside the UNFCCC: Assessment of the Impact of International Cooperative Initiatives on Greenhouse Gas Emissions. PBL Policy Brief. The Hague, PBL Netherlands Environmental Assment Agency, 2015, 40; UNEP, Climate Commitments of Sub-national Actors and Business: A Quantitative Assessment of their Emission Reduction Impact. United Nations Environment Programme, Nairobi, 2015.

11. P. Pattberg, et al. (eds.), Public Private Partnerships for Sustainable Development: Emergence, Influence and Legitimacy. Edward Elgar, Cheltenham, 2012; S. Chan, R. Falkner, H. Van Asselt, M. Goldberg, op. cit., 2015.

12. M. Roelfsema, et al., op. cit., 2015, fn. 10; UNEP, op. cit., 2015, fn. 10.

13. S. Chan, R. Falkner, H. Van Asselt, M. Goldberg, op. cit., 2015, fn. 3; Climate Initiatives Platform, Cambridge Institute for Sustainability Leadership, Ecofys, World Resources Institute, Nordic Council of Ministers, 2015; S. Chan and T. Hale, op. cit., 2015, fn. 4.

14. H. Bulkeley, ‘Governing Climate Change: The Politics of Risk Society?’ Transactions of the Institute of British Geographers 26(4), 2001, pp. 430-447; H. Bulkeley, et al., ‘Governing Climate Change Transnationally: Assessing the Evidence from a Database of Sixty Initiatives’, Environment and Planning-Part C 30(4), 2012, p. 591; H. Bulkeley, et al., op. cit., 2014, fn. 4; S. Chan, , R. Falkner, H. Van Asselt, M. Goldberg, op. cit., 2015, fn. 3; O. Widerberg and P. Pattberg, ‘International Cooperative Initiatives in Global Climate Governance: Raising the Ambition Level or Delegitimizing the UNFCCC?’, Global Policy 6(1), 2015, pp. 45-56.

15. K. Blok, et al., op. cit., 2012, fn 9; A. Hsu, et al., op. cit., 2015, fn. 8; M. Roelfsema, et al., op. cit., 2015, fn. 10; The Global Commission on the Economy and Climate, Seizing the Global Opportunity: Partnerships for Better Growth and a Better Climate. The 2015 New Climate Economy Report. Washington, DC, 2015; UNEP, op. cit., 2015, fn. 10.

16. For an exception, see: K. Szulecki, et al., ‘Explaining Variation in the Effectiveness of Transnational Energy Partnerships’, Governance 24(4), 2011, pp. 713-736.

17. S. Chan, Bonn Groundswell Event – Report. Bonn Groundswell Workshop: Catalyzing Climate Action for Resilient Development. German Development Institute/Deutsches Institut für Entwicklungspolitik (DIE), Bonn, Galvanizing the Groundswell of Climate Actions, 2015.

18. S. Chan, R. Falkner, H. Van Asselt, M. Goldberg, op. cit., 2015, fn. 3.

19. F. Eichhorn and S. Chan, Determinants of Effectiveness of Climate Actions: The Case of the ‘Momentum for Change’ Campaign (unpublished).

20. D.B. Muller, et al., ‘Carbon Emissions of Infrastructure Development’, Environmental Science and Technology 47(20), 2013, pp. 11739-11746; A. Revi, et al., Urban Areas. Climate Change 2014: Impacts, Adaptation, and Vulnerability. Part A: Global and Sectoral Aspects. Contribution of Working Group II to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. C.B. Field, V.R. Barros, D.J. Dokken, et al. Cambridge, United Kingdom, and New York, USA, Cambridge University Press, 2014, pp. 535-612.

21. J.S. Bansard, et al., ‘Cities to the Rescue? Assessing the Performance of Transnational Municipal Networks in Global Climate Governance’, International Environmental Agreements: Politics, Law and Economics, 2016, pp. 1-18.

22. scenario_process/RCPs.html