Before the COP16 conference kicks off, Dialogue Earth invited four experts to interpret China’s newest biodiversity targets.
In a few short weeks, parties to the UN biodiversity convention will meet in Cali, Colombia, for the COP16 biodiversity conference.
Two years ago, at COP15, they reached a historic agreement to halt and reverse global biodiversity loss. Known as the Kunming-Montreal Global Biodiversity Framework, it saw countries commit to protect 30% of the world’s land, ocean, coastal areas, and inland waters by 2030 via an initiative called 30 by 30.
COP16 will focus on resource mobilisation and implementation, to ensure the framework is much more than empty words. Before the conference starts on 21 October, parties need to submit their implementation plans, which are called National Biodiversity Strategies and Action Plans (NBSAPs).
At the time of writing, only 24 countries and the EU had done so out of 196 parties.
As the chair of COP15, China has been one of the more proactive countries, submitting its updated NBSAP in January. The plan covered policy outlines including protection, restoration, pollution management, and combating the illegal wildlife trade.
The first version of this document had been released prior to the 2010 Aichi Biodiversity Targets. It was following the world’s failure to reach the Aichi targets by the 2020 deadline that countries discussed updating the targets, and established the Kunming-Montreal Framework.
What’s been updated in this version of China’s NBSAP? Where does it shine and where does it fall down? Is it consistent with the goals of the Kunming-Montreal Framework? We asked several experts for their thoughts.
Vague marine protection goals
The key difference between China’s new NBSAP and the 2010 version is the inclusion of the 30 by 30 goal. This plan puts China into alignment with the Kunming-Montreal Framework. As of 2018, China has established 271 marine protected areas of differing levels and types, protecting around 124,000 sq km, according to official government data. Its new NBSAP states that by 2030, the area within marine ecological redlines will be “not less than 150,000 sq km”.
Both China’s existing marine protected areas, and its goal on drawing marine ecological redlines, fall short of 30 by 30.
How countries will contribute to 30 by 30 has yet to be decided, Peng Kui, programme manager at the Global Environmental Institute (GEI), a Beijing-based think-tank, told Dialogue Earth. Once all NBSAPs have been submitted, they will need to be analysed to determine whether they are compatible with the initiative’s goal. Such analysis is expected to be a key focus of COP16.
Zhang Yimo, director of WWF Beijing’s Sustainable Blue Economy programme, said that when 30 by 30 was proposed, there was no stipulation as to the proportion of its own marine area each country had to protect. Moreover, he said, China still hasn’t incorporated its ecological conservation redline areas and other areas of conservation significance into Other Effective Area-Based Conservation Measures (OECMs). In other words, areas that effectively protect biodiversity in the long term, beyond official conservation areas, are not yet included in China’s protected area total.
All types of marine protected areas in China have strict regulations, which restrict surrounding economic and other human activities. Establishing these areas is often difficult, time consuming, and can create socio-economic problems, Zhang Yimo said. He added that it is more feasible to promote a flexible marine ecological conservation redline policy and include it as an OECM measure, than to designate new marine protected areas to increase the overall area.
However, the legal basis and regulations of the ecological redline policy still need further clarification, he noted. China has also yet to clearly define the standards for OECMs. “These are the two key points of [the work] implementing the 30 by 30 goal,” he said.
Consistency with the Kunming-Montreal Framework
The new NBSAP has significant revisions beyond the inclusion of the 30 by 30 goal. A study by the Beijing Greenovation Institute for Public Welfare Development identified three highlights: structural consistency with the Kunming-Montreal Framework; provision of guidance for enterprises and other market players to participate in biodiversity protection; and a key focus on coordinating biodiversity conservation and other work.
The experts Dialogue Earth spoke to support this view. Peng Kui said that the updated NBSAP was highly consistent and almost in accordance with the Kunming-Montreal Framework, though there were differences in expression. For example, the phrase “participation of local communities”, as is common in China, is used rather than the “Indigenous rights” preferred internationally.
The Kunming-Montreal Framework states that biodiversity conservation is a whole-government and whole-society effort. Peng Kui believes this important stance is reflected in the new plan, which opens with a reference to “mainstreaming biodiversity”. Additionally, he says the NBSAP “mentions conservation through the OECM for the first time, as well as the participation of non-state actors, including businesses and civil society organisations”.
Yang Fangyi, former China programme director for IUCN (International Union for Conservation of Nature), made similar observations. He told Dialogue Earth that the updated NBSAP made significant improvements in green finance, including by encouraging and pushing for financial institutions to take into account biodiversity concerns when making investment and financing decisions, and promoting nature-related corporate disclosure.
Funding challenges
While green finance features prominently in the NBSAP, broader biodiversity funding remains a challenge.
An early draft of the Kunming-Montreal Framework had called for filling the USD 700 billion annual shortfall in biodiversity funding by 2030. The final draft tried to solve this by mentioning the mobilisation of USD 200 billion from various sources for biodiversity conservation, and “substantially phasing out” harmful subsidies by at least USD 500 billion a year by then.
The framework additionally calls for increasing the flow of funding to developing countries to at least USD 20 billion a year by 2025, and USD 30 billion a year by 2030. COP15 also adopted a resolution establishing a Global Biodiversity Framework Fund (GBF) under the UN’s Global Environment Facility.
While its NBSAP has set no clear funding targets, China announced in October 2021 that it would take the lead in investing CNY 1.5 billion (USD 211 million) to establish the Kunming Biodiversity Fund. Formally launched in May this year, the fund supports biodiversity conservation in developing countries.
In a July article, Zhang Yujun, director of the environment ministry’s Department of Nature and Ecology Conservation, emphasised that the Kunming Biodiversity Fund is “different from China’s traditional bilateral aid, will adhere to the basic principles of multilateralism and international operation”, and work together with the GBF and other financing measures to increase efficiency. According to Yang Fangyi, the Kunming fund has launched a call for projects, and could reveal before COP16 the first list of specific projects to be funded.
Innovative financing mechanisms for nature conservation, including debt-for-nature swaps, exist globally. Zhang Yimo of the WWF suggested that China could look at ways to increase funding to attract more capital for ecological or marine conservation efforts. China could also introduce incentive policies and actionable tools to entice existing private investment not already involved in conservation into nature-friendly areas, he said.
Globally, biodiversity funding faces serious hurdles. This is partly because assessment mechanisms for biodiversity protection have not been optimised, and funder countries may have concerns about tracking funds and evaluating actual impact, said Peng Kui. Assessment mechanisms will be a key point of discussion at COP16, he told Dialogue Earth.
Eliminating harmful subsidies
Reducing and reforming subsidies that are harmful to nature is also seen as vital. Some subsidies that support fossil fuels, agriculture, and fishing harm biodiversity by reducing the cost of exploiting natural resources, leading to overexploitation, overcapacity, and ecological destruction, for instance. Reforming and redirecting these subsidies towards ecological conservation and management could plug around half of the funding gap, according to a 2021 study.
Though China’s NBSAP does not directly adopt the term “harmful subsidies”, the chapter on “diversified financing mechanisms” mentions the need to “gradually reform and phase out policy measures that are detrimental to biodiversity”. This clearly implies harmful subsidies, said Peng Kui.
Zhu Zhengguang, a former official at the State Oceanic Administration, noted that China was one of the first to accept the WTO’s 2022 agreement to end harmful fisheries subsidies. During a second round of negotiations early this year to discuss banning subsidies which cause overfishing, China supported the ban despite it failing to pass in the end, he added. But relevant work on this has not yet been included in the NBSAP. He explained that this was do with the term “harmful subsidies” not being accepted in the Chinese policy context.
The WTO agreement prohibits subsidies to illegal, unreported and unregulated vessels and operators, fishing on parts of the high seas not under the jurisdiction of regional fisheries management bodies, and activities targeting overexploited fish populations.
Zhu said that under China’s new fishery subsidy policy introduced in 2021, subsidies have shifted to supporting high-quality development of the fishing industry. They will be used to help coastal fishers “reduce fleets and transition to alternative industries, and for the green development of the aquaculture industry.” However, to date, there has been no discussion in China as to what constitutes harmful subsidies, he said.
International influence
Yang Fangyi and Peng Kui both said that China will continue trying to be at the vanguard of international trends on biodiversity issues, following the considerable leadership it showed in achieving the Kunming-Montreal Framework.
The Kunming Fund, for instance, is preparing to invest in specific projects, and a list of these is expected to be published before COP16. Updates and key actions of China’s NBSAP can be shared with more developing countries through the Kunming Fund, Yang said. China has also taken some international action, such as during the meeting between Xi Jinping and Emmanuel Macron in May this year, when biodiversity and ocean issues came up. The two countries issued a joint statement “on strengthening biodiversity and ocean cooperation: from Kunming-Montreal to Nice”, which called for more countries to submit their NBSAP as soon as possible.
Peng said: “In the future, we hope to see China play a more important role on the global stage. For example, we hope that more countries can join the Kunming Fund or other Chinese-led initiatives, so China can further demonstrate its international influence.”
Zhang Yimo hopes that China can share its experience of implementing the Kunming-Montreal Framework as a reference for other countries: “Since China took the lead in passing the Kunming-Montreal Framework, we [have been] confident that the country will have the willingness and determination to offer some demonstrations and case studies.”
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