Principles for a Post-2012 International Climate Change Agreement
This document lays out the views of the International Emissions Trading Association (IETA) in relation to the development of a post-2012 international climate change agreement. These positions explicate how the agreement could best draw in private sector participation and capitalize upon the strengths of the private sector in addressing climate change efficiently and effectively. This document is the first produced as a result of IETA’s efforts to provide clear, relevant private sector input into the negotiation process. In this work and subsequent documents, IETA aims to clarify the basic requirements for essential private sector participation as well as identify the practical implications of proposed new treaty arrangements for the private sector. IETA’s views are shared with regard to the following issues: Goals and Targets Commitment Period Duration Enforcement New Forms of Differentiation and Commitment Inventories and MRV Flexible Mechanisms Transition Period Management Supplementarity Carbon Market Design Emission Reduction and Sequestration in the Land-Use Sector
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1. Goals and Targets
IETA believes that the Parties should agree firm targets for the next commitment period; indicative medium-term (~2030) targets that lay out a series of ‘rolling targets’ for subsequent commitment periods; and a long-term (~2050) global goal. The Bali Action Plan makes it clear that these goals and targets should be in accordance with the principle of common but differentiated responsibilities and respective capabilities, and predicated on the need to ensure comparability of effort among all Annex-I Parties. To ensure the predictability and effectiveness of international climate efforts, IETA believes that it is essential that the Parties establish a clear timeframe of emission reduction goals and targets that extend over the next several decades, and that those goals and targets are enshrined in national legislation to ensure their credibility. The provision of such goals, and their subsequent translation into domestic legislation, will ensure that carbon pricing becomes embedded in long-term capital asset planning. Long-term certainty of carbon constraints is required to drive the research, development, and deployment of new technologies in countries facing emissions caps - especially in key energy production and industrial sectors - as well as to enhance the predictability of carbon finance availability for countries whose emissions remain uncapped. IETA advocates the use of ‘rolling targets’ as a means of strengthening the credibility of goals and targets set beyond the next commitment period. Rolling targets establish a series of indicative targets for successive commitment periods. They leave some flexibility to incorporate scientific or political developments through allowing the targets to be set anywhere within a small, pre-established range. A series of rolling targets, if incorporated in domestic legislation, would go a long way to ensuring the credibility of medium-term emission limitations by setting each Party firmly on a trajectory toward the medium-term target it agreed at the international level.
2. Commitment Period Duration
To accommodate the need for long-term investment certainty as well as the need for flexibility to set targets based on scientific or political developments over the mediumterm, IETA advocates for the adoption of commitment periods with a duration of at least 8 years combined with a system of rolling targets, as explained above.
For the private sector, longer commitment periods provide increased predictability and certainty for business decisions and so facilitate private sector investment in the necessary research, development, and deployment of low-carbon technologies. Longer commitment periods also give investors increased flexibility to deploy resources for emission reduction when most cost-effective for their business as well as to offset short-term fluctuations in emission levels resulting from economic cycles or unpredictable and one-off occurrences, like natural disasters. If no other factors bore on the decision of commitment period duration, IETA would advocate, very simply, for very long periods, approaching twenty years. IETA understands, however, that there will likely be a need to allow for adjustments to emissions limits based on political developments and improved scientific understanding of the climate situation, within shorter periods of time than would be ideal for investor certainty. For this reason, IETA advocates the aforementioned hybrid solution that aims for a strong, credible signal of a long-term carbon price (provided by rolling targets of a binding nature) while maintaining flexibility for businesses (through a minimum 8 year commitment period) and flexibility for political and scientific developments (through the provision of a range of acceptable targets, within which the fixed target will be decided based on the available
scientific data and political developments at the time). those proposed for the UK and Australia.
Such a system would be similar to
The choice of 8-year periods would bring the international commitment period in line with commitment periods already established at the domestic level in some countries. Private sector capital has already been adjusted to these established domestic emission trading systems and, once in motion, investment planning is not easily redirected or enhanced. IETA believes, therefore, that accommodating existing policy would be beneficial but is not the only way forward.
IETA believes that the new international climate change agreement should include clear, meaningful, credible, and enforceable commitments for appropriate national and international action by Parties to reduce greenhouse gas emissions and to monitor progress toward them. IETA understands the difficulties of making targets formally binding under international law, but clear targets with enforcement provisions at the international level should lead to the establishment of strong and enduring domestic policies. As implied in the previous sections, it is the strength of domestic policies that guides the private sector and drives investor behavior. IETA believes that international climate policy enforcement between governments should take place through the UNFCCC enforcement regime, which should be made more effective than the current Kyoto provisions have proven in practice. Whether under UNFCCC or trade instruments, Parties should agree to use the multilateral system of settling disputes instead of taking action unilaterally.
4. New Forms of Differentiation and Commitment
IETA believes that changes to the current state of differentiation among the Parties, whether through the inclusion of new countries under Annex I or the incorporation of new forms of commitment under the treaty, must be guided by clear criteria made explicit in the new agreement. IETA also believes that any new forms of commitment, such as the use of sectoral targets, should only be agreed after careful consideration of and provision for the challenges likely to arise in their implementation and monitoring. IETA does not take positions on what the commitments of Parties should be, or how they should be differentiated under the UNFCCC and its Protocols. IETA’s comment on these issues is a practical reaction to strong indications that new forms of differentiation and commitment may exist among the Parties post-2012. These indications include the submissions from Parties to the UNFCCC noting that possibility as well as the Bali Action plan’s assertion that all countries should act to address climate change in accordance with the principle of common but differentiated responsibilities and respective capabilities. If such a situation were to arise, IETA, first and foremost, believes that clarity in terms of each Party’s commitment, status, and legal obligation under the treaty is essential for the private sector in each country to know and best prepare for its role. It is critical, therefore, that the criteria for differentiation is clearly elaborated so to allow for forewarning about when and how certain Parties, and the entities operating within them, will be expected to make contributions. In addition, to accommodate the need to move to longer commitment periods, it is essential that the next agreement clearly provides procedures by which non-Annex I countries are able
to move to a new form of commitment or join the ranks of Annex I mid-period. Without this ability clearly outlined in the new agreement, Parties that come to meet the criteria for a change in contribution during the interim will need to wait, unnecessarily, until the beginning of the next commitment period before they shift to a new form of contribution. Finally, while open to considering the incorporation of new forms of commitment under the UNFCCC, such as sectoral agreements, sectoral no-lose targets, or Nationally Appropriate Mitigation Actions (NAMAs), IETA believes that each of these ideas requires further exploration, especially in terms of their practical implementation and how they will obtain necessary funding.
4. Inventories and MRV
IETA believes that any serious effort to address climate change over the long-term must be based upon the establishment of an increasingly standardized, global network of national emission inventories and the development of strong, consistent and compatible monitoring, reporting and verification (MRV) systems, where necessary. In order to accurately define mitigation commitments and nationally appropriate mitigation actions, and monitor progress against them, emission inventories should be developed for all major economic sectors in all countries except LDCs. IETA recognizes that inventories will take significant time to build up, that they will take shape in developed and the most advanced developing countries first, and that they may differ in form and function from country to country for some time. Significant efforts should be made immediately, however, to develop and implement compatible standards for data collection, analysis, and reporting across countries. Similarly, IETA believes that to ensure the complete fungibility of like emission reduction units,1 MRV must be required for all credited emission reductions, and MRV standards should be compatible and based upon accepted protocols and standards, for example, the 2006 IPCC Guidelines and ISO 14064, which would need to be accompanied by guidance to enable detailed and consistent MRV at the appropriate sector level. Above all, and from the beginning, the Parties, domestically and internationally, should focus on the creation of emission monitoring systems that are transparent, credible and as consistent as possible across borders. Doing so will better facilitate the development of a truly international carbon market with optimal economic efficiency.
5. Flexible Mechanisms
IETA strongly supports the continued operation, reform and expansion of the Kyoto Protocol’s flexible mechanisms - emissions trading, the Clean Development Mechanism, and Joint Implementation - which have been key to jump-starting emission reduction activities in the private sector globally as well as facilitating the flow of technology and know-how to, between, and within developing countries. IETA believes that negotiators should build upon and refine these efforts in the next period. Indeed, IETA supports the development of new flexible mechanisms to further encourage critical private sector investments in the areas of emission reduction and technology development and deployment.
This is meant to indicate that, where emission reduction units appear to represent the same underlying asset, i.e. one tonne of emission reduction, that they should be fungible. It is not meant to indicate that different emission reduction ‘products’, e.g. technology transfer credits, with different defining characteristics, could not be developed or that they would need to be fungible with ‘traditional’ emission reduction units.
The Kyoto Protocol’s market-based mechanisms were created in order to allow greater flexibility to Annex I countries in meeting their emission reduction obligations, to lower the overall societal cost of mitigating climate change, and to spark emission reduction activities in non-Annex I countries. These motivations have not changed, and IETA feels strongly that, regardless of any moves to differentiate among developing country Parties post-2012, the operation of the existing flexible mechanisms should continue. Indeed, the depth of reductions required in developing countries and the extent of private sector investment envisioned by economists and the Parties alike mean that expanding market-based activities through increasing the scale of existing mechanisms and developing new mechanisms will be critical in the post-2012 period. Emissions Trading The IPCC and most climate economists, including Lord Stern, agree that international emissions trading constitutes an essential tool as the Parties endeavour to achieve global emissions reduction at lowest cost. Under the Kyoto Protocol, however, the emissions trading mechanism was designed to legitimize trading between governments, not between the private entities that are now increasingly becoming legally responsible for reducing emissions and trading emission reductions in the disparate national and regional trading systems being developed around the world. In the new international agreement, IETA believes that there is a critical need to focus clearly on the provision of a firm international framework for the development of a global carbon market that facilitates trading between private entities and Parties. The creation of a truly global carbon market should be a pillar of the next and all subsequent international climate change agreements. Clean Development Mechanism (CDM) Continued access to the CDM will allow developing countries that do not move to a new form of commitment and sectors not involved in ‘new mechanisms’ the chance to enhance sustainable development and build emission reduction capacity. Indeed, the CDM constitutes the greatest and most visible delivery upon developed country obligations to developing countries, as envisioned under the Convention and Protocol; IETA believes that ensuring that projects registered or under development continue to have value post-2012 is crucial to maintaining trust between the Parties. Certified Emission Reductions (CERs) will, in addition, continue to serve as an indirect link between different regional trading systems in the foreseeable future, a crucial function until direct-linkage is achieved. IETA believes, however, that while the CDM has been successful to date, it requires reform so that activities can be scaled-up, geographical distribution enhanced, and environmental integrity fully assured. The necessary reform will require significant changes to the CDM’s governance and management system, and reform is likely to lead to an increase in CDM activities overall, as well as the welcome expansion of activities into under-utilized host countries and new project types.2 Finally, and very significantly, IETA believes that concerns about the environmental integrity and regional distribution of CDM project activities should be addressed within the UNFCCC system. IETA hopes that explicitly addressing concerns about environmental integrity within
IETA has made significant and detailed proposals for the reform of the CDM concerning, e.g. reform of the CDM’s governance structure, problems in the development of Programmes of Activities, and the market unacceptability of temporary credits for Aforestation/Reforestation. We will continue to expand upon our work in this regard and engage with the CDM Executive Board and the Parties whenever possible to advance these proposals.
the CDM will remove the inclination to add qualitative or quantitative restrictions to the CDM on a unilateral or bilateral basis. Adding unilateral or bilateral rules to the CDM not only adds uncertainty and confusion into the market and creates distrust among developing and developed country Parties, it also moves the international community farther away from a global market. Joint Implementation (JI) and Domestic Offsets IETA believes it likely that a JI-like mechanism, which has been under-utilized to date, will have an increasingly significant role to play in a post-2012 international climate change regime, as more Parties take on binding emission reduction limitations. As this occurs, IETA believes that JI projects and domestic offset projects will become a complement to cap-and-trade regimes, as they promote emission reduction within those Parties’ economies. Numerous opportunities exist for altering the rules and expanding the scope of the current JI mechanism to facilitate the scale-up of this approach. There are also a number of opportunities to enhance the use of domestic offsets alongside more traditional cap-and-trade mechanisms, particularly in areas such as forestry, agriculture, land-use change and waste. IETA looks forward to working with the Parties to open up these opportunities in the future. A key consideration for the existing carbon market is the transition from CDM to JI (or domestic offset) as countries or sectors formally adopt emissions limitations. IETA believes that the post-2012 international climate change agreement should provide a clear pathway for CDM projects that have been approved or were under development before the host country or sector accepted a new form of contribution. This pathway could include the shifting of the status of these projects from the CDM to JI (or domestic offset). IETA believes that any such conversion should ensure eligibility for issuance to the project proponents until the end of the project’s remaining crediting periods. New Flexible Mechanisms IETA welcomes the continued consideration of new market-based mechanisms - such as the sectoral, no-lose, and NAMAs crediting mechanisms under consideration by the Parties– as complements to the existing market-based mechanisms. IETA believes that these proposals require much more thoughtful contemplation before they can be fully endorsed and urges the Parties to engage with the private sector when further exploring these mechanisms. IETA particularly urges the Parties to focus on the key issue of whether or not a funding source (e.g. demand for emission reduction credits) exists that is commensurate with the mechanism’s ambition. IETA is concerned that several of the new mechanisms under discussion by the Parties could issue emission reduction credits at a scale that could have significant and devastating consequences on the international carbon market if demand for these credits is not considered beforehand.3 If a demand source can be identified, IETA urges the Parties to design that mechanism with the explicit intention of attracting that source. In other words, mechanisms aimed at attracting private sector investment must entail a reasonably secure investment environment and clear rules for participation and crediting.4
The level of demand will reflect the ambition of targets accepted by Parties as well as the extent of supplementarity limits applied by domestic governments in the next crediting period. 4 IETA has developed an accompanying document explaining the economic, legal and regulatory criteria that new mechanisms should meet if they are to successfully attract private sector participation.
6. Transition Period Management
IETA believes that in order to avoid slowing private sector momentum toward achieving greater emission reductions and, in turn, avoid the collapse of existing emission reduction capacity, the Parties must do the following: explicitly provide for the continuation of existing mechanisms during the transition period; ensure the viability of projects developed under them; and agree to prompt-start crediting for new mechanisms created, where appropriate. IETA believes that the management of the transition between the Kyoto and post-2012 commitment periods will have critical implications for the ability of the international community to quickly take up the task of lowering emissions to the levels called for by the most recent scientific analysis. A significant private sector community focused solely on discovering economically efficient emission reduction activities has developed around the world over the past decade. This community could easily collapse if a protracted transition leaves them without the opportunity to earn economic reward for the provision of an environmental benefit. For that reason, IETA strongly encourages the Parties to consider the extensive time frame that may be needed to set up new governance structures, complete all preparatory activities in host countries, and ensure that private sector actors are capable of taking advantage of opportunities created by any new mechanisms. The creation of a prompt-start crediting phase for new mechanisms, where appropriate, will be absolutely critical to jump-starting private sector activities in these areas. Even more important to preventing the collapse of implementation capacity will be the assurance by the Parties that CDM projects will remain viable investments in the post-Kyoto period. Indeed, IETA believes it critical that the Parties agree that all projects registered or in development before a country agrees to join the ranks of Annex I, remain eligible for both their current and remaining crediting periods. The Parties should establish regulations for the management of the resulting emission reductions units in the applicable host country or sector inventories, where necessary.
IETA opposes the imposition of limits on the use of emission reduction credits (i.e. “offsets”) in Annex I Party emission trading systems, as doing so will entail a greater societal cost for the same atmospheric benefit and could derail political efforts to reach ambitious mitigation levels. From the perspective of the atmosphere, the location of emissions reduction activities is inconsequential, and they should be incentivized wherever most cost-efficient. IETA understands that some Parties believe that supplementarity limits are necessary to ensure equitable domestic abatement. It must be recognised, however, that limits on the availability of lower cost emissions reductions increases the societal cost of mitigating climate change, and, as a result, will inevitably increase political opposition to reaching the levels of mitigation called for by science. The argument that developed country decarbonisation is being avoided through the use of offsets is false: provided that the Parties create a clear longterm signal of a carbon price, the use of emission reduction credits merely smoothes the path and avoids the early retirement of valuable assets. IETA believes that as countries agree to take on much higher levels of ambition, any supplementarity limits set should be loosened to a similar degree.
8. Carbon Market Design
IETA believes that decisions taken by the Parties in the next agreement will combine with decisions taken by regional and national governments as they develop emission trading systems to determine the efficiency and effectiveness of the carbon market. In addition to the key issues already discussed in this document, IETA believes that ambition levels and the extent and nature of regulation will prove critical to the market’s success. The ambition levels agreed by the Parties and enshrined in national legislation provide the incentive to reduce emissions in the market, and for that reason, are obviously a central element in market design. That being said, the levels agreed by the Parties constitute a scientific and political issue that lies beyond IETA’s mandate. Underlying the incentive that ambition levels create, however, markets require a regulatory framework focused on facilitating efficient, effective emission reduction. This framework must be clear in terms of compliance obligations, the rules governing the provision and use of instruments to meet those obligations, and the enduring nature of the market itself. As noted earlier, it must also entail compliance flexibility, in terms of time and the availability of supporting instruments. Finally, a market-based solution is made less efficient if alternative or additional regulatory instruments prevent market participants from discovering the lowest cost solution. For this reason, policymakers should carefully consider the possible impact of any proposed market management and oversight tools before applying them to the market.
Ultimately, a uniform, global carbon market would produce emissions reductions most efficiently and effectively. It is clear to IETA, however, that the achievement of a global market will come from links and economic attraction between the emission trading systems now developing at national and regional levels, rather than from the imposition of a top-down structure. Taking into consideration the benefits of allowing the widest scope for the search for emission reductions, IETA urges the Parties to attach a high priority to avoiding the implementation of design features or elements of market regulation that will, in the longerterm, forestall the achievement of a broader, more global market. Indeed, every effort should be made towards the standardization or compatibility of market “building blocks,” such as accounting principles, offset standards, features of registry design, and MRV systems.
9. AAU Surplus
To encourage the linking of trading systems and address competitiveness issues, IETA believes that the Parties should endeavour to ensure that emission reduction targets for the next commitment period represent comparable effort, as stated in the Bali action plan, and that the transfer of surplus AAUs into the post-2012 period is carefully managed. Failing to consider the transfer of large numbers of surplus AAUs could undermine the achievement of real emission reductions and prove detrimental to the international carbon market. For these reasons, IETA is willing to deviate from its traditional support for unhindered banking between periods and argue that the discussion on surplus AAU banking from the first commitment period of the Kyoto Protocol should either precede or occur in parallel with the negotiations to set goals and targets. Permitting the unqualified transfer of the expected AAU surplus into the post-2012 crediting period, or neglecting to consider the effects of such a transfer when negotiating new emission targets for countries holding significant surpluses, could seriously undermine efforts toward the achievement of the UNFCCC’s core objective. Moreover, failing to carefully consider the existence of large AAU surpluses in some countries will cause great uncertainty in the post-
2012 carbon market until clarity is reached about the intended use of those AAUs. The introduction of such a surplus into the market could have a drastic, downward effect on the global carbon price and the incentive to reduce emissions. For these reasons, IETA believes that it is of utmost importance to effectively address this issue and is willing, therefore, to deviate from its traditional support for unqualified banking of all compliance units between crediting periods. IETA believes that large amounts of “hot air” surplus AAUs should be filtered out at the end of the first crediting period through the adoption of more ambitious targets that ensure the comparability of effort of those countries holding large surpluses. If this is not politically acceptable, Parties could strive to limit the per-Party carryover of AAUs into the subsequent commitment period. Limited banking of AAUs could be defined via a firm quantity of units, through a percentage of the country’s original AAUs, or through a percentage of the volume remaining in a Party’s reserve at the end of the period. Another option would be an amendment to the Kyoto Protocol to the effect that any surplus AAUs must be compulsory greened, with the CMP providing clear guidance on the requirements for the greening process and enforcing rules for transparency. IETA is aware of the unambiguous wording of Article 3.13 of the Kyoto Protocol, and the likely political consequences of trying to amend it, but believes that the possible consequences are significant enough to make this argument. Finally, to ensure that this situation does not repeat itself, IETA believes that the Parties should endeavor to ensure that emission reduction targets are evaluated against a standard that is relative to current emission levels. The next international climate agreement, therefore, should reference targets to either a new, up-to-date base year or an average of a Party’s emissions taken over the span of recent years in order to create a realistic baseline by which future commitment will be measured.
10. The Land-Use Sector5
IETA believes that reducing emissions from and enhancing biological sequestration in the land-use sector is a critical component of any effort to comprehensively combat dangerous climate change and must be urgently addressed at the international and domestic levels. IETA believes that the solution to reducing emissions and enhancing sequestration in the land-use sector must be market-led if the challenges facing this sector are to be successfully met in due time. IETA also recognizes, however, that efforts to reduce emissions and enhance sequestration in the land-use sector require a harmonized approach between the public and private sectors; a comprehensive, successful effort necessitates the development of an enabling environment and the provision of incentives for action immediately, and increasingly over time. The role of the terrestrial biosphere in regulating the world’s climate, and the potential for emission reduction and sequestration in the land-use sector,6 must finally receive due
IETA defines the ‘land-use sector’ as including the following activities: agricultural land use, management of pastoral land, grassland and peatland; afforestation; reforestation; and avoided deforestation and degradation (or, REDD). IETA believes that appropriate incentives should also be provided for managing emissions from long-term harvested wood projects. In policy discussions, the land-use sector is most often separated into the ‘forestry,’ ‘agriculture,’ and ‘other land-use’ sectors, however these activities are closely inter-related. Please see “IETA’s Principles for Reducing Emissions and Enhancing Sequestration in the LandUse Sector” for a more in-depth explanation of IETA’s decision to aggregate all of these activity types in the ‘land-use sector’. 6 According to McKinsey & Company’s latest analysis of global abatement opportunities, approximately 46% of the global emissions reduction and sequestration potential by 2020 exists in the agriculture and forestry sectors. McKinsey & Company, “Pathways to a Low-Carbon Economy: Version 2 of the Global Greenhouse Gas Abatement Cost Curve,” 2009, ppg 157. Please note that the agricultural sector as defined in the McKinsey study entails all agricultural emissions, not only emissions from agricultural land-use.
attention by the Parties, and the focus of international efforts in this sector must be on developing countries, where the greatest proportion of reduction and sequestration activity must be undertaken. The solution to reducing emissions and enhancing sequestration in the land-use sector must be market-led, because only strong, early incentives for private sector investment across the entire land-use sector will stimulate the necessary emission reduction and sequestration activities at the speed and breadth required. IETA believes that emission reduction and sequestration activities in this sector can deliver real, additional emissions reductions, with leakage7 addressed at the project level, and with permanence dealt with through the use of market-based tools, such as buffer reserves and insurance. The use of these tools will allow activities in this sector to result in the creation of credits that are equivalent to and fungible with those achieved in other sectors. Indeed, IETA believes that the credits issued for activities in the land-use sector must be permanent, equivalent and fully fungible with all other compliance credits8 in the UN, regional and domestic markets. Temporary crediting must be avoided; it seriously discourages investment in the sector by creating a complex crediting system that inhibits full commoditization and attaches an unjustified stigma of weak environmental integrity. In addition, efforts to reduce emissions and enhance sequestration in the land-use sector must entail a harmonized approach between the public and private sectors to create the required enabling environments and incentives for emission reduction activity. Since most activity in this sector must take place in developing countries, IETA calls for public sector funding to be made available in the period from 2009 to 2013 for capacity building, institutional development and the establishment of MRV systems in countries that require assistance.9
In the land-use sector, as in most other sectors, leakage must be considered and addressed at various levels – project, national, and international. Ways to manage the concerns about leakage at the project level have been carefully developed by practitioners over the years and do not require more concern in this sector than in others. Also similar to other sectors, concerns about leakage at the national and international level lie outside of the purview of a project-by-project system and must be handled by policymakers. IETA urges governments to coordinate efforts nationally and internationally to ensure that leakage does take place across borders but adamantly believes that these concerns can no longer hold back efforts to reduce emissions in this sector. 8 IETA’s position is that one credit from the land use sector must be legally equivalent to one credit or allowance from other sectors where tradable units (e.g. AAUs, EUAs, CERs, ERUs) represent one tonne of emissions, either emitted or reduced. IETA does not argue that these credits must equate to other (not yet developed) forms of credits created within the context of the international effort to combat climate change, e.g. to represent technology transferred. 9 IETA has developed an accompanying position paper to more clearly explain its views on reducing emissions and enhancing sequestration in the land-use sector. In that document, these points are elaborated upon extensively and concrete action is proposed. Please see “IETA’s Principles for Reducing Emissions and Enhancing Sequestration in the Land-Use Sector,” available at www.ieta.org.
Please contact Kim Carnahan at email@example.com if you have questions or comments, or require further information in relation to the positions contained in this document.