However, the document was never officially published. Carbon Brief understands that the group has decided not to release it, as there is a risk of alienation of other parties who may not agree with their checklist with high ambitions and as part of an attempt to reach consensus on Article 6 at COP25. The final mechanism of Article 6 for “non-market approaches” is less precisely defined, but it would provide a formal framework for climate cooperation between non-trade countries, such as development assistance. The CDM is widely regarded as a mistake. Instead of pursuing more ambitious targets, analysts believe that most of the emission reductions would have been achieved under the CDM, either because they made financial sense without credit or because they were legislated. If the final regulatory framework leaves too much flexibility, there is concern that Article 6 cooperation will not produce general climate benefits or, worse, an increase in CO2 emissions. Given the risks associated with international hot air transfer and uncertainty about the effectiveness of other approaches to ensuring environmental integrity, this paper recommends that countries take a cautious approach and adopt a portfolio of approaches to ensure environmental integrity, with limit values that may provide for additional safeguards. Given the limited number of countries that have confirmed that they will use international credits and the fact that they are not currently allowed to be respected in most national and regional carbon markets, the extent of demand for these loans is not clear at this time. “The reason we got as far as we did in Katowice is because people were expecting an agreement. These compromises were made as part of an agreement, so if there is no agreement, people will naturally come back from their compromises.┬áThis supports the idea, which was discussed at COP21 but is not included in the Paris text, that emissions reductions should go “beyond the NPNs” of the host country, in accordance with Article 6.4.

Some argue that the use of strict baselines would guarantee “OMGE,” the net reduction benefit required by Article 6.4. The risks arise from both the transfer of old Kyoto credits into the new system and new potentially worthless loans, generated by countries that achieve above-average rates with low NPNs and then act on the surplus in accordance with Article 6.2. Such a system already exists under the Kyoto Protocol`s own development mechanism, with 2% of “certified emission reductions” (RECs) for administrative costs and the Adjustment Fund. “The rules are crucial. If poorly written, instead of facilitating additional emission reductions, they risk thwarting the satisfaction of current contributions and undermining progress. A corresponding option in the draft text relating to Article 6.2 indicates that the general requirements for the prevention of double counting already adopted under paragraph 77, point d), of the Paris Regulation would be “supeceded[d] by the provisions of Article 6. The statement against it is an attempt to reopen the debate. A long part of the current text of the negotiations contains a similar option in which countries can choose their own approach to avoid “double counting”. However, it also includes more restrictive options, one of which would require all countries to use the average method.

Perhaps the biggest concern is a system that would allow for “double counting,” meaning that emissions reductions could be blamed on the objectives of the party selling the credits and those who buy them. (Brazil`s position and the issue of double counting are explained below). A lack of agreement on solving this problem reflects the technical challenges it poses and not the political differences on the appropriate solution, says former co-chair Kizzier.