The Paris Agreement - EY - USFILE/ey-the-paris-agreement.pdfThe Paris Agreement | 2 Overview of the...

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The Paris Agreement A Universal Call to Action for Governments and Businesses What it means for India

Transcript of The Paris Agreement - EY - USFILE/ey-the-paris-agreement.pdfThe Paris Agreement | 2 Overview of the...

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The Paris AgreementA Universal Call to Action for Governments and Businesses

What it means for India

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1 | The Paris Agreement

ContentsAbout COP 21 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Overview of the Paris Agreement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

India’s INDC and commitment to addressing climate change . . . . . . . . . 6

International Alliance for Solar Energy . . . . . . . . . . . . . . . . . . . . . . . . . 10

What the Paris Agreement means for business . . . . . . . . . . . . . . . . . . 12

Way forward for businesses and policy makers in India . . . . . . . . . . . . 15

References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

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About COP 21

The Paris Climate Change Conference was held between 29 November and 13 December 2015. It was the 21st meeting of the Conference of Parties (COP 21) of United Nations Framework Convention for Climate Change (UNFCCC).

This conference marks a signi cant milestone in global efforts to combat climate change. The conference delivered a new universal climate change agreement aimed at utting the world rml on track to a low carbon sustainable future that keeps a global temperature rise under 2 degrees Celsius of what it was in pre industrial era.

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Overview of the Paris Agreement

e features and components of the Paris greement can be summarized as follows:

Key aspects of the Agreement

Overall objectives

• Holding the global average temperature rise to ‘well below’ 2 degrees Celsius above pre industrial levels and to pursue efforts to limit the temperature increase to 1.5 degrees Celsius above pre industrial levels

• Increasing the abilit to adapt to the adverse impacts of climate change and foster climate resilience and low greenhouse gas emissions development in a manner that does not threaten food production;

• aking nance ows consistent with a pathwa towards low greenhouse gas emissions and climate resilient development.

The Paris greement does not call for legall binding emission reduction targets as was the case with the oto Protocol. Instead the agreement is based on voluntar commitments to climate change actions made b each countr based on its respective national circumstances (INDCs). While the emission reduction targets themselves are not legall binding the process of regular review and submission of INDCs is binding.

The ke success of the Paris greement lies in the fact that it managed to bring together 195 nations (virtuall the entire world). Out of these 1 nations have alread submitted their INDCs to UNFCCC. However it has been estimated that with the current commitments temperature rise will be limited to 2. degrees Celsius falling well short of the target of 2 degrees Celsius set out in the agreement.

dditional contributions or progressivel increasing contributions will be essential to reach the goal of 2 degrees Celsius or the aspiration of 1.5 degrees Celsius.

Points to note

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Adaptation

• daptation: The agreement calls for strengthening cooperation between countries enhancing action on adaptation taking into account the Cancun daptation Framework including: sharing adaptation information knowledge strengthening institutional arrangements strengthening scienti c knowledge on climate change assisting developing countries in developing implementing adaptation action plans and improving sustainabilit of adaptation actions.

• Loss and Damage: The agreement also calls for continuation of the Warsaw International Mechanism (WIM) for Loss and Damage associated with Climate change Impacts. The WIM was established two ears ago at COP19 support developing countries particularl vulnerable to climate change with addressing loss and damages associated with adverse effects of climate change.

Developing countries like India are particularl vulnerable to climate change and re uire signi cant funding towards adaptation. In India a large portion of the population remains dependent on agriculture and or resides in low l ing coastal areas. It has been estimated that India will need to spend U 20 billion between 2015 and 2030 on adaptation measures for agriculture forestr sheries infrastructure water resources and ecos stems.

It is not onl people’s livelihoods which are under threat from climate change. everal industries face climate change risks in their own operations or their suppl chain. This is particularl true for those industries which are dependent on agricultural products in their value chain and those which have water intensive processes. treme weather events can impact all sectors.

Points to note

Points to note

India submitted its INDC on 1 October 2015 prior to COP 21 (refer section on India’s INDC). While India’s INDC is ambitious (particularl with respect to the 0 target for non fossil fuel based power generation) if the e isting National olar Mission and other ongoing climate change polic initiatives deliver the INDC targets would not be far from India’s grasp.

The agreement makes a provision for internationall transferred mitigation outcomes. This will translate into a new market based mechanism for carbon trading which ma combine features of CDM and I. The supervisor bod for this mechanism will be setup up b the Conference of Parties. The mechanism will aim to promote mitigation of H emissions while fostering sustainable development facilitate participation b public and private entities allow one countr to mitigate emissions through pro ects in another host countr and deliver overall mitigation in global emissions. It ma be possible to integrate this new mechanism with e isting voluntar carbon market and other market based mechanisms.

Intended Nationally Determined Contributions (INDCs)

• e uires all countries signing the greement to submit updates ever ve ears on their Nationall Determined Contributions on actions to address Climate Change

• ach successive Nationall Determined Contribution will represent a progression be ond the countr ’s previous contribution re ecting the highest possible level of ambition

• Developed countries to continue taking lead in undertaking econom wide absolute emission reduction targets

• Developing countries to continue enhancing their mitigation efforts and encouraged to move over time towards econom wide emission reduction or limitation targets in the light of different national circumstances

• Provision for internationall transferred mitigation outcomes to achieve nationall determined contributions while avoiding double counting of mitigation actions

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Technology development and transfer

• The agreement calls for strengthening mechanisms for development and transfer of technolog through further work on technolog research development and demonstration as well as development and enhancement of endogenous capacities and technolog

Capacity building

• The agreement establishes the Paris Committee on Capacit building which will aim to address gap and needs both current and emerging in implementation capacit building in developing countries

Counties like India are banking on e ternal support for adaptation and mitigation actions. The cost of implementing climate change mitigation and adaptation measures in India from 2015 to 2030 has been estimated to be at least U 2.5 trillion at 201 15 prices.

Further the agreement does not limit itself to nancial ows between governments. It also encourages nancial institutions to adopt measures for make lending (particularl for development assistance)

consistent with a pathwa towards low carbon and climate resilient development. ecentl 2 nancial institutions from developing and developed countries with combined balance sheets of more than US$11 trillion have adopted voluntar Principles to Mainstream Climate ction within Financial Institutions.

It has been recognized that more work is re uired to assist developing countries with research and development with respect to low carbon technologies and climate resilient infrastructure. In the past technolog transfer though recognized as a ke re uirement for addressing climate change has been implemented to a limited e tent.

Points to note

Points to note

Finance

• The agreement places a legall binding obligation on developed countries to provide nancial resources to assist developing countries with climate change adaptation and mitigation. Developing countr Parties have been strongl urged to scale up the level of nancial support to developing countries to a minimum of US$ 100 billion per ear collectivel b 2020. while signi cantl increasing adaptation

nance from current levels. However the goal of achieving US$ 100 billion nancing b 2020 is not legall binding.Provision for internationall transferred mitigation outcomes to achieve nationall determined contributions while avoiding double counting of mitigation actions

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Following the adoption of the Paris greement b the COP (Conference of the Parties) it will be deposited at the UN in New ork and be opened for one ear for signature on 22 pril 201 Mother arth Da . The agreement will enter into force after 55 countries that account for at least 55 of global emissions have deposited their instruments of rati cation.

Once the agreement is signed countries will have to get to work on delivering the commitments made through their INDCs. Finance departments of governments around the globe have their task set out for them as the will have to ensure decarbonisation is integrated into scal policies and budgets. s these policies and

scal measures are implemented the will likel have an impact on businesses which are carbon intensive.

Transparency

• The agreement establishes an enhanced transparenc framework to build mutual trust and con dence with in built e ibilit taking into account differential capacities of countries; The transparenc framework would including national communications biennial reports and biennial update reports international assessment and review

Global stocktake

• Provision for periodicall taking stock of the implementation of the Paris greement to assess the collective progress towards achieving the greements

ob ectives and long term goals;

• The rst global stocktake will take place in 2023 and subse uentl once ever ve ears

Including a robust monitoring and veri cation (M ) framework in climate change pro ects programs will be essential for addressing re uirements with respect to transparenc . s emission reduction targets set under INDCs are not legall binding transparenc and global stocktake are critical for pushing countries to remain committed to their climate change goals. Public disclosure on progress against INDCs will add pressure on countries to deliver.

Points to note

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India’s INDC and commitment to addressing climate change3

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The targets set under the INDC are particularl challenging considering that India has around 300 million people without access to electricit and is home to 30 of the global poor. India needs to simultaneousl address its development needs and adopt low carbon growth. s per some estimates India’s emissions intensit target will lead to a total inventor of 6.5 tCO2e b 2030 around 2 tCO2e lesser than businessas usual. If India successfull achieves its ambitious renewable energ goals (for instance achieving 100 W capacit in solar power b 2022) and implements its other climate change programs it could e ceed the emission intensit target.

part from the mitigation goals there is also a strong focus on climate change adaptation in India’s INDC which highlights current initiatives in sensitive sectors including agriculture water health and more and points toward plans under development in each state.

The price tag for implementation of India’s INDC has been estimated b the overnment of India as at least US$ 2.5 trillion at 201 15 prices. This includes at least US$ 206 billion for adaptation actions b 2030. This cost is signi cantl higher than that uoted b other developing nations in their INDCs primaril because India’s baseline electricit consumption is set to triple b 2030 up to 2 99 TWh. Meeting this electricit demand while decoupling economic growth from emissions growth will undoubtedl be a costl affair. Funding for implementation of India’s INDC is likel to come from a combination of domestic budgets private sector and additional funding from developed countries.

India submitted its Intended Nationally Determined Contribution on 1 October 2015, prior to the UN climate conference in Paris. India’s INDC was developed based on stakeholder consultations involving key Ministries, State Governments, civil society organisations, think tanks and other institutions. Further greenhouse gas (GHG) modelling studies for projections of GHG emissions till 2050 were carried out to provide a basis for framing targets for low-carbon development.

e goals identi ed in India’s INDC submission include:

• To reduce the emissions intensit of its DP b 33 to 35 percent b 2030 from 2005 level.

• To achieve about 0 percent cumulative electric power installed capacit from non fossil fuel based energ resources b 2030 with the help of transfer of technolog and low cost international nance including from Green Climate Fund (GCF)

• To create an additional carbon sink of 2.5 to 3 billion tonnes of CO2 e uivalent through additional forest and tree cover b 2030.

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• National daptation Fund (N F): The N F has an initial allocation of IN 3 500 million and aims to nance national and state level adaptation measures in areas that are particularl vulnerable to the

adverse effects of climate change. The N F supports adaptation measures in agriculture water forestr and other sectors.

• National Clean nerg Fund (NC F): India’s coal cess at IN 200 per ton of coal (previousl IN 50 per ton of coal) is a form of carbon ta . Proceeds from the coal cess form the corpus for the N CF a fund created for supporting research and innovative pro ects in clean energ technologies. The N CF has collected a sum of IN 1 0 billion as on nancial ear 201 15.

• s stated in India’s INDC document it is also banking on funding from developed countries for addressing the domestic resource gap for implementing climate change mitigation and adaptation measures. Funding can potentiall be obtained through the Green Climate Fund founded b UNFCCC as a mechanism to assist developing countries in adaptation and mitigation practices. Multi lateral development banks such as the World ank and D have recentl committing increasing funding towards climate change mitigation and adaptation. India can be a recipient for a portion of this funding.

• The budget provision of IN 3 500 million is for the nancial ears 2015 16 and 2016 1 . The disbursement of the funds will depend on acceptance of proposals from states / union territories for adaptation projects.

• While the NC F was setup as earl as 2000 the disbursement of this fund to the renewable energ sector has been lagging. The effectiveness of this fund will depend on how ef cientl the Government can mobilize the fund to augment growth in renewable and clean energ technologies going forward.

• Man developed countries have been publicl announcing their pledges to contribute nancial resources for climate change. Some e amples include 5. billion pledged b the U (for the period 2016 2021) 900 million pledged b Spain b 2020 and US$ 00 million annual funds pledged b the US b 2020.

• Developed countries announced pledges totalling US$ 10.1 billion during the initial resource mobilization of the Green Climate Fund.

• The World ank Group recentl pledged a one third increase in climate nancing. The total of direct nancing and co nancing from the World ank group is e pected to reach US$ 29 billion per ear

b 2020.

• Globall multi lateral development banks have been ver active in issuing green bonds which have been used to nance climate change projects in various developing countries (US$ .5 billion issued b I D and US$ 3. billion issued b IFC).

Outlook

Outlook

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Private sector

• The private sector speci call banks and non nancial banking companies (NF Cs) have been pla ing an increasing role in funding clean energ projects in India. For instance an Indian private bank issued green infrastructure bonds resulting in total subscription of IN 10 billion in Februar 2015. The amount raised from these bonds will be used primaril for funding renewable energ projects.

• Going forward instruments such as green bonds can be e pected to have a greater role in nancing climate change mitigation through clean energ projects in India.

• However for nancing of adaptation a range of specialized banking and insurance products need to be designed and support from the Government or development partners is necessar to mobilize such nancial products.

• n increasing number of Private banks and NF Cs ma adopt voluntar Principles to Mainstream Climate ction within Financial Institutions which were recentl adopted b 26 nancial institutions in developed and developing countries.

Outlook

part from the above Public Private Partnerships have been emerging as an important mechanism to nance large scale adaptation projects and mitigation projects. Other sources for climate nance which are being deplo ed mostl in developed countries include Sovereign Wealth Funds (SWF) and Pension Funds. For instance Norwa ’s SWF of US$ 90 billion (the largest in the world) has announced that it would divest from companies which rel on more than 30 per cent coal. Climate nance in India needs to come from a balance of different sources including domestic and international and both public and private sources.

For achieving low carbon development India has detailed its strategies which include policies supporting renewable energ enhancing energ ef cienc developing climate resilient urban centres (smart cities) promoting waste to energ decreasing emissions intensit of transportation planned afforestation and others. One of the most ambitious aspects of India’s strategies for low carbon growth is its program for e panding solar power. With a target of 100 GW b 2022 India has initiated projects for 25 Solar Parks Ultra Mega Solar Power Projects canal top solar projects one hundred thousand solar pumps for farmers and solarisation of 55 000 petrol pumps across the countr .

India had also declared in its INDC its intentions to anchor a global solar alliance InSP (International genc for Solar Polic pplication) of all countries located between the Tropic of Cancer and the Tropic of Capricorn. The alliance would allow India to leverage on cooperation among countries for further augmenting its ambitious solar program.

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International Alliance for Solar Energy4

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e features of the declaration include:

• shared vision to bring clean affordable and renewable energ within the reach of all

• im to reduce the costs of nance and cost of technolog for immediate deplo ment of competitive solar generation assets

• Financial instruments to mobilize more than 1000 Billion US Dollars of investments that are needed b 2030 for the massive deplo ment of affordable solar energ

• Creation of an International Steering Committee open to interested counties to provide the necessar guidance direction and advice to establish the international solar alliance

With policies and collaborative efforts of governments channelizing funds and resources towards clean energ sources and low carbon growth businesses can no longer afford to ignore climate change. In fact business leaders have been working with polic makers to push for an ambitious global climate change agreement and have voiced their solidarit with the Paris greement.

India and France launched an International Solar Alliance on the opening day of COP 21 to boost solar energy in developing countries. Indian Prime Minister Narendera Modi and French President Francois Hollande announced the alliance, which includes around 120 countries that support the “Declaration on the occasion to launch the international solar alliance of countries dedicated to the promotion of solar energy.”

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What the Paris Agreement means for business

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The We Mean Business CoalitionCorporate organizations were active stakeholders in the process that led up to the signing of the Paris

greement and will have a crucial role to pla in the efforts towards achieving the targets set out under the agreement. The We Mean Business Coalition brought hundreds of companies and investors to the climate negotiations at Paris to push for an ambitious global climate change deal.

Low Carbon Technology Partnerships Initiative

One of the ke collaborative platforms for businesses to address climate change led b the World Business Council for Sustainable Development (WBCSD) is the Low Carbon Technolog Partnerships Initiative (LCTPi). LCTPi brings together several initiatives including WBCSD’s ction2020 Business Solutions SDSN’s Deep Decarbonisation Pathwa s and I ’s Technolog oadmaps. The LCTPi aims to:

• ccelerate the diffusion of e isting technologies b removing technological market and social barriers and introducing re uired polic and nancial instruments

• Develop Public Private Partnerships (PPPs) on the esearch Development Demonstration and Deplo ment ( DD D) of potentiall game changing new technologies

Leading up to COP21 the LCTPi developed actions plans for deplo ment of low carbon technologies and held regional dialogues with polic makers around the world. set of concrete actions plans were presented at COP21 and will now be implemented through collaborative efforts between businesses and polic makers.

e focus areas of low carbon technolog identi ed b the LCTPi include

• Low carbon freight

• Renewables

• Carbon capture and storage

• nerg ef cienc in buildings

• Cement

• Low carbon transport fuels

• Climate smart agriculture

• Forests

• Chemicals

South Africa3 and 4 September 2015

LCTPiRoundtable II

May 2015Paris

WBCSD MeetingApril 2015Montreux

India14 September 2015

25 September 2015LCTPi Roundtable III

NYC

JapanICEF

7 and 8 October 20

JapanCEO dialogue

6 October 2015

Create ambitious solutions

Agree on ambitionTest actions in regional dialogues

and with policy makers

Finalise action plansDevelop action plans that remove

barriers and build partnerships

Integration of low carbon growth in business strategyIt is clear that the climate change risks and opportunities can no longer be ignored by businesses. The evolving national and international regulatory climate as well as stakeholder’s expectations and new avenues for revenue generation are driving organizations to adopt strategies for managing risks and harnessing opportunities presented by the challenge of climate change.

Roadmap for for LCTPi for Paris and beyond

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Brazil7 and 8 October 2015

3 November 2015LCTPi Roundtable IV

(Co-leads only)London

China11 November 2015

Australia12 November 2015

ParisDecember 2015

COP2115

Final messages

Implement beyond Paris

Development of company contributionto support sector/value-chain action plan

Development of sector/value chain action plan

Positive stories of action

Key communicationJanuary to March 2016

Carbon taxation and removal of subsidies on fossil fuels are some of the scal measures countries like India are adopting to augment low-carbon growth. The cost of carbon if ignored can have adverse implications for the competitiveness of energy intensive businesses.

In order to develop an implementable roadmap for low-carbon growth an organization will typically need to develop a governance structure for facilitating implementation of climate change projects set long term targets for low-carbon growth allocate budgets develop implementation timelines and identify partnerships with other industries institutions or government for achieving low carbon growth objectives. Leading organizations are focusing on innovation as part of the low-carbon strategy including:

• Product innovation: how products can be designed in a way that reduces embedded carbon and the resource-intensity of product use

• Technology transfer: how the organization can collaborate with other industries / institutions / governments to increase the usage of innovative technologies for low-carbon and climate-resilient development

• Innovative nancing: how nancing mechanisms can be leveraged to ensure maximum penetration of low-carbon technologies

An effective low-carbon strategy will ultimately allow the organization to manage risks and harness opportunities related to climate change meet the organization’s objectives for low carbon growth help stakeholders to address climate change risks and opportunities and strengthen the brand image of the company.

While most leading global organizations have already integrated low-carbon growth in their business strategies they are likely to re-assess their strategies to align with the evolving regulatory environment. A key feature of the Paris Agreement is that it calls for countries (both developed and developing) to re-visit their contributions every ve years and each successive Nationally Determined Contribution will represent a progression beyond the country’s previous contribution. Leading companies are already working with policy makers to gain greater visibility on the direction of climate change regulations based on Nationally Determined Contributions. Companies which do not have a clear strategy around low-carbon growth are likely to lose out. Early action on low carbon technologies would help improve bottom lines and avoid lock-in of carbon intensive technologies.

Reference: Road to Paris and Beyond LCTPi web-site http://lctpi.wbcsdservers.org/ accessed 16 December 2015.

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Way forward for businesses and policy makers in India

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Both businesses and policy makers will have to get to work and collaborate to achieve the targets set out in India’s INDC. Some of the action points which would help India live up to its commitments include:

• Engage with industries / power generators for developing clear policies for incentivizing low-carbon growth

• Build capacities for diffusion of low carbon technologies and climate resilient technologies based on local re uirements

• Develop roadmap for achieving 40 contribution from non-fossil fuel based sources in power generation capacity by 2030

• Identify the gaps in domestic budgets for achieving roadmap implementation and uantify the external support re uired

• Identify / develop climate change mitigation and adaptation projects and where there are existing resource gaps for implementing projects mobilize funds using an appropriate nancing mechanism (e.g. National Adaptation Fund Green Climate Fund or other sources)

• Develop robust monitoring and veri cation protocols for all climate change programs / projects

• Engage with policy makers (through industry associations or other platforms) on the direction of climate change regulations to gain greater visibility and to provide feedback on proposed changes

• Consider developing partnerships with organizations or institutions dedicated to low carbon growth

• Adopt innovative approaches to addressing climate change including innovation with respect to products technology and

nancing

• Act proactively to avoid lock-in of carbon-intensive infrastructure (i.e. include low-carbon technologies in the designing of new facilities / units as replacing or retro tting capital intensive infrastructure is not always feasible)

• Explore alternative sources of nancing for low carbon technologies including nancing from multi-lateral development banks green bonds private-public partnerships and others

Policy makersBusinesses

While the price tag for low-carbon growth and climate resilient growth is high the bene ts will be multitude including addressing India’s energy security needs contributing to access to energy for millions poverty alleviation and making businesses in India more sustainable.

End note: In-spite of the terror attack on Paris on 13 November 2015 COP 21 continued as scheduled. The Paris Agreement would not have been possible without the resolve and solidarity shown by the people and leadership of France.

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UNFCCC COP 21 Adopts Paris Agreement IISD web-site http://climate-l.iisd.org/news/unfccc-cop-21-adopts-paris-agreement/ accessed 16 December 2015

United Nations Framework Convention on Climate Change Newsroom UNFCCC web-site http://newsroom.unfccc.int/paris/ accessed 16 December 2015

India and France Launch International Solar Energy Alliance at COP21 UNFCCC web-site http://newsroom.unfccc.int/clean-energy/international-solar-energy-alliance-launched-at-cop21/ accessed 16 December 2015

Business leaders: Paris Agreement will accelerate shift to thriving clean global economy We Mean Business Coalition web-site http://www.wemeanbusinesscoalition.org/blog/business-leaders-paris-agreement-will-accelerate-shift-thriving-clean-global-economy accessed 16 December 2015

Press Information Bureau Government of India 2nd October 2015 http://pib.nic.in/newsite/PrintRelease.aspx relid 128403 accessed 16 December 2015

India’s Intended Nationally Determined Contribution: Working Towards Climate Justice UNFCCC web-site http://www4.unfccc.int/submissions/INDC/Published 20Documents/India/1/INDIA 20INDC 20TO 20UNFCCC.pdf accessed 16 December 2015

Analysis: India’s climate pledge suggests signi cant emissions growth up to 2030 Carbon Brief web-site http://www.carbonbrief.org/indias-indc accessed 16 December 2015

COP21: What does the Paris climate agreement mean for me BBC web-site http://www.bbc.com/news/science-environment-35092127 accessed 16 December 2015

Understanding green bonds and greener way of nancing The Hindu web-site http://www.thehindu.com/business/what-are-green-bonds/article7070840.ece accessed 21 December 2015

List of Recent Climate Funding Announcements UNFCCC webi-site http://newsroom.unfccc.int/ nancial- ows/list-of-recent-climate-funding-announcements/ accessed 21 December 2015

The World Bank Group: Climate Finance: Overview The World Bank web-site http://www.worldbank.org/en/topic/climate nance/overview accessed 21 December 2015

References7

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EY of cesAhmedabad2nd oor Shivalik Ishaan Near C.N. idhyalayaAmbawadiAhmedabad 380 015Tel: 91 79 6608 3800Fax: 91 79 6608 3900

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10th Floor Tower D E Cyber Green DLF Phase-3 Gurgaon 122 002Tel: +91 124 671 4400

3rd 6th Floor World Mark-1 Asset 11 IGI Airport Hospitality District Aerocity New Delhi 110 078 Tel: +91 11 6671 8000

4th 5th Floor Plot No 2B Tower 2 Sector 126 Noida 201 304 Gautam Budh Nagar U.P. Tel: +91 120 671 7000 Fax: +91 120 671 7171

PuneC-401 4th oor Panchshil Tech ParkYerwada (Near Don Bosco School)Pune 411 006Tel: +91 20 6603 6000Fax: +91 20 6601 5900

The Paris Agreement | 18

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19 | The Paris Agreement

Notes

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The Paris Agreement | 20

Notes

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