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Tracking The Brazilian Climate Policy Implementation

Implications For The Nationally Determined Contribution

This report analyzes the limits, challenges, opportunities and lessons learned related to the implementation of the Brazilian climate policy – and proposes recommendations for its improvement. The analyzes are useful for the debate between the government and civil society on the implementation strategy of the Brazilian NDC.

Key Findings

Executive Summary

In recent years, nations have advanced in the development of climate mitigation and adaptation policies. To ensure that such polices are effectively implemented, a set of monitoring and evaluating tools have been created globally. Such tools aim to promote greater transparency for the governments to establish and implement goals, identify barriers and promote adjustments when necessary. As a result of the Paris Agreement, the evaluation and monitoring became more relevant, since the role of measurement, report and verification (MRV) systems has been strengthened and periodical revisions of the nations’ NDCs became necessary.

In Brazil there is a lack of studies, evaluations and tools aimed at monitoring the level of implementation of the national climate policy, especially with an emphasis on governance aspects that can influence the degree of efficacy and impact of the policy. Traditionally, the studies and evaluations focus mainly on the quantitative monitoring of greenhouse gas (GHG) emissions and on the government commitments in reducing emissions. This type of analysis, if considered individually, may led to a circumstantial bias, such as, for example, a reduction in emissions caused by an economic recession.

Objective and methodology

The objective of this work is to analyze the limits, challenges, opportunities and lessons learned regarding the implementation of the Brazilian climate policy, and to propose recommendations for its improvement.

By using a climate policy tracking tool created by the Open Climate Network (OCN) led by WRI, the level of implementation of the national climate policy in Brazil was analysed. “Climate policy” in this work refers to a set of mitigation and adaptation policies, plans and actions established by the federal government under the National Policy on Climate Change (PNMC) of 2009, and the strategies involved in the implementation of the Brazilian Nationally Determined Contribution (NDC), ratified by the National Congress in 2016. After the ratification of the Paris Agreement, the Brazilian government highlighted that the policies, measures and actions to implement the country’s NDC will be conducted recognizing the regulatory framework already established by the PNMC.

The OCN tool offers a methodological road map that can contribute to a monitoring system for the Brazilian climate policy. As shown in the figure below (Figure SE), in the first phases an identification and characterization are undertaken on the object to be monitored and evaluated (the policy or plan), as well as the regulatory framework relating to the adoption of the policy. Selected indicators are components of a system to track the level of the policy implementation, which should be done in a systematic manner, over time, making the appropriate adjustments when necessary.

The OCN tool is innovative because it does not only analyze the level of a climate policy implementation but it also considers governance as an important condition for a proper implementation. The tool has guidelines to assess five governance aspects: (i) clarity of role and responsibility; (ii) institutional capacity; (iii) policy coordination; (iv) transparency; (v) stakeholder engagement. The OCN tool is not focused on evaluating a policy impact. If that is the case, the tool would need to be applied and assessed in conjunction with other tools that encompass additional political and nonpolitical factors that have implications on the intended policy outcomes.

Final Considerations

Based on the evaluation steps and selected indicators, the OCN climate policy implementation tracking tool enabled the identification and mapping of a series of institutional, sectorial and economic instruments that still need to be implemented in their totality or that already exist but need to be strengthened, as determined by regulatory framework of the Brazilian climate policy. For example, the lack of a Brazilian Emissions Reduction Market (BERM) and a monitoring and evaluation system on the results of the climate policy. Both market and system are foreseen under the regulatory framework, but haven´t been established yet. In the case of instruments such as climate financing (the Climate Fund and Low-Carbon Agriculture (ABC) programme), their financial capacity is still marginal, especially if compared to funds to support activities that are not aimed at the decarbonization of the economy.

Regarding the participative instruments (under the Brazilian Forum on Climate Change and on consultation processes for the formulation of mitigation and adaptation plans), the analysis highlights the challenge of increasing social mobilization around the climate agenda, which is still low, as well as guaranteeing greater transparency in the decision-making process concerning the inclusion or not of civil society contributions in the public consultation process.

The institutional framework of the Brazilian climate policy clearly defines the roles and responsibilities of each governmental agency involved, with an emphasis on the role of the Executive Group on Climate Change (GEx) in the intersectorial and interministerial coordination of the climate policy, although it is expected that it will resume its function. The design in itself does not provide the conditions to ensure the effective performance of GEx, which in recent years has acted in a limited manner, if compared with the initial periods of its establishment. The sectorial mitigation and adaptation plans and the National Plan on Climate Change are delayed with their revision processes. With the establishment of the Brazilian climate policy in 2009, it is important for the government to evaluate whether the institutional structure for policy governance remains appropriated and what are the main reasons to justify GEx´s current performance.

The Brazilian climate governance requires greater transparency and the expansion of spaces for public participation to increase civil society participation in the monitoring and co-management of the climate policy. Although there is some progress on public hearing processes on the creation of climate policy instruments, the government does not explain the rationale to accept or decline the suggestions offered by civil society. The recurrence of such cases overtime may discourage civil society participation in the climate agenda. Simultaneously, there is not a systematic process making publicly available the minutes from the meetings with the various Working Groups, GEx and other agencies, except within of the Reducing Emissions from Deforestation and Forest Degradation – REDD+, which has built an online platform ( to provide greater transparency concerning decisions, progress, and minutes from its meetings. The Brazilian Forum on Climate Change (FBMC), established to mobilize society for the discussion and decision-making on climate change-related problems, does not manage to have the necessary articulation and capillarity in the country and has limited financial capacity to implement concrete actions.

Recommendation For Public Policy

The results of this work are contributions to the implementation strategy of the Brazilian NDC, currently under discussion by the government and civil society. Beyond an analysis solely focused on the results of greenhouse gas emissions and adaptation measures, the OCN tool highlights the importance of analyzing climate governance elements, which relate to the policy implementation efficacy and values MRV aspects, which play a key role in the context of the Paris Agreement. These elements support the recommendations on public policy for the federal government:

  • Establish a comprehensive and transparent system to monitor and evaluate climate policy implementation, in a way that allows civil society to exercise social control of the policy. The scope of the system should include intermediary policy objectives, such as, for example, the creation of economic, financial and institutional instruments, in the areas of mitigation and adaptation. In addition, it is important that the system is intersectorial to engage different ministries, resuming and strengthening the articulation role of the Executive Group on Climate Change (Gex);
  • Establish a robust and periodic revision process of the climate policies and plans aimed at increasing the level of ambition of the Brazilian NDC implementation strategy;
  • Focus, during the sectoral plan revision process, on the search for technologies and solutions aimed at decoupling GDP and GHG emissions;
  • Accelerate the establishment of relevant economic instruments that support emission reductions;
  • Streamline institutional structures and improve the coordination among ministries for a more responsiveness and efficient climate policy governance, beginning with a revision of the current GEx framework;
  • Achieve greater transparency and public participation in the implementation of the Brazilian climate policy, strengthening the FBMC, increasing the number of seats held by civil society in working groups and commissions, improving the current public consultation processes.

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