Is the accompanying Action Plan necessary and adequate for implementing the LTAM? If you believe that not, what would you propose?

The LTAM should be concrete and actionable. Therefore, the European Union favours integrating the relevant actions directly into the LTAM. Several relevant actions, tools and initiatives could (also) be incorporated or referenced in the guidance notes on the GBF targets that are available on the CBD webpage (e.g. under ‘F – relevant resources that can assist implementation’).

Spain considers that the Action Plan should be used as a voluntary guidance tool and encourage Parties and relevant stakeholders to take into account the catalogue of possible mainstreaming actions.
The Voluntary Action Plan could work in the current format or integrating the main elements in the LTAM itself to have just one document.

The LTAM should be concrete and actionable. Therefore, integrating the relevant actions directly into the LTAM could be an option to reduce the number of documents. Several relevant actions, tools and initiatives could (also) be incorporated or referenced in the guidance notes on the GBF targets that are available on the CBD webpage (e.g. under ‘F – relevant resources that can assist implementation’).

Canada believes that the action plan is necessary for the implementation of the LTAM, however certain changes should be made to reflect the work that has been completed in the interim.  First, the action plan is understood to be a voluntary set of actions, as such, it should be communicated in the text.  Second, as stated in the previous question (Acceptable Basis), Canada proposes that the resources collected from notification 2023-120 (tools and guidance) should be incorporated into the action plan.

No, the current Action Plan is neither necessary nor adequate for implementing the LTAM. First we need major revision of the LTAM with far great participation from Parties, civil society, in particular women, IPLCs, and small farmers who feed millions of people without destroying biodiversity. Then we should write a completely new Action Plan that genuinely reflects the urgency and primacy of the biodiversity issue.

The development of the current Action Plan in particular was dominated by business interests.

An extract from the current draft Action Plan shows some of the business interests and coalitions playing an active role in the discussions:

Platforms and coalitions that are registered with CBD initiatives, such as the GPBB, Action Agenda, and regional/national platforms. World Economic Forum, World Business Forum for Sustainable Development, sectoral and trade associations in all sectors (International Council on Mining and Minerals, International Petroleum Industry Environmental Conservation Association, Global Concrete and Cement Association, Cross-Sector Biodiversity Initiative, Union for Ethical BioTrade, Friends of Ocean Action, Food and Land Use Coalition).

These groups need to be regulated by government in the interests of people and biodiversity, not allowed to dominate the mainstreaming discussion in their own interests.

The fact that they are dominating it, means that the LTAM and Action Plan in particular both have many references to offsetting, voluntary commitments, etc:

No net loss/net gain, ecosystem accounts, natural capital accounting, biodiversity offsets and compensation mechanisms, voluntary certification, voluntary climate and biodiversity commitments, biodiversity metrics, payment for ecosystem services (PES), multi-stakeholder platforms, …

The Action Plan should therefore be put aside while we rewrite the LTAM, after which a new Action Plan can be developed.

Its development should involve all sectors of society because we depend on biodiversity for life, and the threats to biodiversity and ecosystems, particularly to the poor and disadvantaged, are materialising faster than most expected. This means that we need urgent collective action, according to CBDR, to correct power imbalances, inequity and injustice at all levels.

Above all, biodiversity and ecosystems must not be exploited for offsets or carbon markets, which are a means to delay the reduction of climate forcing emissions. This is currently the strategy of a number of major emitters.

Nor must biodiversity and ecosystems be monetised (eg: through natural capital accounting) as a potential precursor to marketing them more widely – for example through Natural Asset Companies, which the New York Stock Exchange has been considering for listing. Since scarcity often increases market value, degrading ecosystems could increase the market value of those which remain more intact, something which could benefit investors in the short term while further undermining the planetary systems on which all life depends.

Like Spain, Germany and the European Union, Belgium sees the value in the accompanying action plan and considers that this could be a useful tool to help Parties and stakeholders ensure that mainstreaming actions are fully taken into account.  Belgium agrees with Canada that certain changes should be made to reflect the work that has been completed in the interim, such as the proposal to incorporate into the action plan the resources which have been collected from notification 2023-120 on tools and guidance, and to also communicate in the text that the action plan is understood to be a voluntary set of actions. 

Belgium also agrees that the Action Plan could be integrated within the LTAM itself to avoid having too many separate documents.

Like Canada, Spain, Germany, the European Union, and Belgium, as an observer to the CBD the Capitals Coalition sees the Action Plan accompanying the LTAM as a necessary element, as it makes LTAM concrete and actionable. Of course, we see a need to update the Action Plan on the basis of the Kunming-Montreal agreement and we would like to urge the CBD and its Parties to ensure participation of non-state actors in that process. Also, we agree with the EU that the Action Plan contains elements that could be directly integrated in guidance notes on GBF targets, as this would really mainstream the mainstream agenda.

FOEI believes that, as the current LTAM is found to be insufficient and, in many parts, inadequate, it needs to be significantly reworked. No Action Plan can be approved without a further process after the approval of the LTAM.
However, given the difficult timelines and the fact that many of the measures in the Action Plan are controversial, it may be better to decide NOT to have an Action Plan at all.

In any case, greenwashing measures should be removed from the text. Examples are all offsetting proposals (including “No Net Loss”, “Net Gain”, “Nature Positive” and “Biodiversity Credits”), certification organised by corporate controlled platforms, multistakeholder platforms, and corporate social responsibility.

Like Canada, Spain, Germany, the European Union, and Belgium, the Netherlands regards it important that the LTAM is an actionable document so that it facilitates implementation. The Voluntary Action Plan could work in the current format or integrating the main elements in the LTAM itself to have just one document.