BASD comments on zero draft

BUSINESS AND INDUSTRY MAJOR GROUP
COMMENTS TO ZERO DRAFT
MARCH INTER SESSIONAL MEETINGS

The private sector has a key role to play in helping to achieve the goals of sustainable development, in
particular poverty eradication. This fact is noted in paragraph 19 of “The Future We Want”. The private sector
generates most of the goods and services that are utilized every day and therefore must be actively engaged to
address the implementation gaps that have limited achievements of the sustainable development goals.
Business and Industry is pleased to submit the following comments on the zero draft text for the consideration
of member states.

Para 18
We recognize that improved participation of civil society depends upon strengthening the right to access
information and building civil society capacity to exercise this right, ADD: bearing in mind the need to balance
the right to access to information and balanced with the right of protection of personal data and Intellectual
Property Rights [alternatively to IPR refer to: the right to own property and to be compensated for inventions].
Technology is making it easier for Governments to share information with the public and for the public to hold
decision makers accountable. In this regard, it is essential to work towards universal access to information
and communications technologies.
Business supports the principle of public access to information, however the application of the principle
needs to be done in such a way that it balances the need to support innovation and protect IPRs with the
benefits of access information. It is also important to consider how data is accessed and information shared -
data can easily be misinterpreted when stripped out of context

Para 24
We call for [DELETE a global policy framework requiring all listed and large private companies to consider
sustainability issues]ALT: increased participation of companies as well as other stakeholders such as local
authorities in voluntary sustainability reporting schemes and to integrate sustainability information within the
reporting cycle.
Compulsory CSR disclosure is difficult to achieve and unlikely to encourage more genuine transparency, in
addition to being a lengthy and costly process to establish. It also risks creating an unfair playing field for
companies or different countries. There are many voluntary mechanisms which have been created that could
be supported and expanded. The specific focus on ‘large’ companies is not justified and what constitute ‘large’
would need to be defined. Also if disclosure is so important, why should it only be businesses? (and not local
governments etc).

Para 26
We view the green economy as a means to achieve sustainable development, which must remain our
overarching goal. We acknowledge that a green economy in the context of sustainable development and
poverty eradication should protect and enhance the natural resource base, increase resource efficiency,
promote sustainable consumption and production patterns, and move the world toward low-carbon
development. ADD: In this regard, the following core items describe the high level system conditions
that are required to transition towards a green economy, from both business and governments:
Social innovation 1. Awareness 2. Education and skills 3. Employment; Environment innovation
4.Resource efficiency and decoupling 5. Life cycle approach; Economic innovation 6. Open and
competitive markets 7. Metrics, accounting, and reporting 8. Finance and investment; Mutually
enforcing cross-cutting elements 9. Integrated environmental, social and economic policy and
decision making and 10. Governance and partnerships.

BASD page 7

Para 27
We underscore that green economy is not intended as a rigid set of rules but rather as a decision-making
framework to foster integrated consideration of the three pillars of sustainable development in all relevant
domains of public and private decision-making
This is valid and needs to be better reflected in other parts of the text, in particular #74

Para 31
We note that the transformation to a green economy should be an opportunity to all countries and a threat to
none. We therefore resolve that international efforts to help countries build a green economy in the context of
sustainable development and poverty eradication must not:
a) Create new trade barriers;
b) Impose new conditionalities on aid and finance;
c) [DELETE Widen technology gaps or exacerbate technological dependence of developing
countries on developed countries]ALT: Undermine countries’ ability to invest in research and
development, adoption, deployment, and diffusion of technology
d) Restrict the policy space for countries to pursue their own paths to sustainable development.
This is potentially problematic language that could open the door to argument for special measures on
IPRs. Focusing on what is needed to foster innovation and adoption of technologies needs to be broader than
a focus on ‘obstacles’ interpreted as IPR barriers.

Para 40
We strongly encourage business and industry – [DEL organized by industrial sectors,] cooperating across
countries and in consultation with governments, workers and trade unions and other stakeholders – to
develop green economy roadmaps [DEL for their respective sectors,] ADD: along supply and value chains,
taking into account the potential for synergies within each sector, with concrete goals and benchmarks of
progress, including for net creation of jobs.
While the notion of improving mechanisms for sector-wide learning and progress is valuable, it would be
difficult for most sectors to establish joint roadmaps for several reasons: anti-trust and other regulations limit
common goal setting and other similar activities; most companies and industries work not so much as a sector
as much as part of a value chain. Additionally, many sectors do not operate on a national basis and setting
global goals for one sector would be extremely difficult, in particular given the variety of situation and
circumstances. Value chain, supply chain and lifecycle approaches may be more realistic and productive way
to approach sustainability improvements

Para 42
We realize that to make significant progress towards building green economies will require new investments,
new skills formation, [DEL technology development, transfer and access],ALT [based on UNFCCC agreed
definition of technology transfer] enhanced research and development, demonstration, deployment, diffusion
and transfer of technology (hereinafter referred as technology development and transfer)and capacity building
in all countries. We acknowledge the particular need to provide support to developing countries in this regard
and agree:

a) To provide new, additional and scaled up sources of financing to developing countries;
b) To launch an international process to promote the role of innovative instruments of finance for
building green economies;
c) To gradually eliminate subsidies that have considerable negative effects on the environment and
are incompatible with sustainable development, complemented with measures to protect poor and
vulnerable groups;
d) [DELETE: To facilitate international collaborative research on green technologies involving
developing countries, ensuring the technologies so developed remain in the public domain and

BASD page 7

are accessible to developing countries at affordable prices; ]ALT: [using language from the
agreed UNFCCC AWG LCA text on technology transfer as the reference]: Promote and enhance
national and international cooperative action to facilitate research, development and
demonstration of new technologies which are required to meet the key objectives of sustainable
development;

e) ADD: Support and complement the work under way in the UNFCCC through the creation of the
Climate Change Technology Center and Network and encourage creation of ADD additional
Centres of Excellence as nodal points for green technology R&D where needed;

The notion of technology transfer tends to be framed is a limitative manner which only focuses on transfer
North to South and ‘barrier’s, rather than the capacity to innovate, the underlying conditions needed to
facilitate deployment and adoption, as well as the importance of developing predictable regulatory frameworks
and good governance to attract investment both local and foreign.
The suggestion of the Centers of Excellence risks being duplicative of what is going on under UNFCCC.
Greater clarity on how coherence with activities under other UN conventions should be achieved would is
necessary.

Para 43
We recognize the importance of measuring global progress. In this regard, we will be guided by a roadmap
that contains the following indicative goals and timeline:
a) 2012~2015: establishment of indicators and measures to evaluate implementation;
[DEL:establishment of mechanisms for the transfer of technology],ALT: commit to supporting the work
of the Technology Mechanism established under UNFCCC to facilitate research, development, and
deployment of technologies, as well as that of other similar mechanisms and programmes
b) sharing of know-how, and enhancement of capacities;
c) 2015~2030: implementation and periodic assessment of progress;
d) 2030: comprehensive assessment of progress.

This also seems duplicative of work done under UNFCCC and is narrowly focused on transfer only

Para 64
We reaffirm the right to food and call upon all States to prioritize sustainable intensification of food production
through increased investment in [DEL local] food production, [ADD research/ R&D/ innovation] improved
access to local and global agri-food markets, and reduced waste throughout the supply chain, with special
attention to women, smallholders, youth, and indigenous farmers. We are committed to ensuring proper
nutrition for our people.

Welcome the introduction of ‘sustainable intensification’ but focus only on local food production is limitative.
In addition, it contradicts with #65, which calls for “open trading system”. We believe that open trade in
agricultural goods is important to guarantee food security. The multi-agency report that was prepared for the
G20 Agricultural Ministerial clearly demonstrated that the food crisis in 2007/08 was worsened by barriers
imposed on the trade of agricultural inputs and goods.

Para 66:
We further support initiatives at all levels that improve access to information, enhance interactions among
farmers and experts through education and extension services, and increase the use of appropriate
technologies for sustainable agriculture. ADD: We specifically call on all actors to increase support for
agricultural knowledge systems including research, advisory services, vocational training, and farmer-to-
farmer training.
language on knowledge sharing is welcome as a fundamental element to any sustainable agricultural
development strategy; specific commitments in that direction would be useful

BASD page 7

SUGGEST ADDING key reference text from CSD 17 clause 2 and partial clause 8 such as:
64 bis Boosting agricultural productivity, improving soil quality, ensuring the safety of food and, as
appropriate, enhancing the nutritional quality of food is essential and needs to be done in ways that are
socially, economically and environmentally sustainable. Moreover, a comprehensive approach integrating
post-harvest storage and processing to reduce losses and add value, distribution and marketing infrastructure
to link to markets and capacity building at all stages, particularly in developing countries, is needed. Farmers
and farm workers, female and male, especially small, and resource-poor, indigenous people and rural
communities, need to be central actors in a green revolution in a sustainable way, with a sound balance and
mutually beneficial linkages among small- and large-scale agricultural enterprises.

64 tre: A healthy and dynamic agricultural sector is an important foundation of rural development, generating
strong linkages to other economic sectors. Rural livelihoods are enhanced through effective participation of
rural people and rural communities in the management of their own social, economic and environmental
objectives by empowering people in rural areas, particularly women and youth, including through
organizations such as local cooperatives and by applying the bottom-up approach.

Para 68
We recognize the necessity of setting goals for wastewater management, including reducing water
pollution//[ADD others, such as mining OR DELETE ALL]from households, industrial, and agricultural sources
and promoting water efficiency, wastewater treatment and the use of treated wastewater as a resource,
particularly in expanding urban areas
Either all sources of pollution should be mentioned or none. Agricultural sources do not constitute the major
source and a lot of other sources could be included.

Para 74
We also recognize that significant job creation opportunities can be availed through investments in public
works for restoration and enhancement of natural capital ADD and degraded land, sustainable land and water
management practices, [DEL family farming, ecological farming, organic production systems,] ALT: replace
by ‘Sustainable farming/agricultural systems, OR ADD other examples: ‘climate smart agriculture,
conservation tillage, integrated farming, precision agriculture,sustainable forest management, rational use of
biodiversity for economic purposes, and new markets linked to renewable and unconventional energy
sources. We encourage business and industry to contribute to green job creation throughout their global
supply chains, including through support to small and medium enterprises.
The narrow selection of the examples of farming systems is problematic. Either additional examples should
be included, or a broader term should be used, such as ‘sustainable farming/food production systems’. This
would be more consistent with the mention of sustainable intensification earlier on in the text which is much
broader than the three types of farming cited here. As discussed under #27, the green economy is not meant
to be a set of prescriptive rules or a blueprint. The reality of farming worldwide requires solutions adapted to
the diversity of scales, conditions, tools, techniques that best suit farmers wherever they are.

Para 89
89. We encourage international initiatives and partnerships to address the interrelationship among water,
energy, food, ADD land use and climate change in order to achieve synergies as well as to minimize conflicts
among policy objectives, being particularly sensitive to impacts on vulnerable populations.

Para 91
We welcome the Nagoya Protocol adopted at the tenth meeting of the Conference of the Parties to the
Convention on Biodiversity. We support mainstreaming of biodiversity and ecosystem services in policies and
decision-making processes ADD through positive incentive mechanisms at international, regional and national

BASD page 7

levels, and encourage investments in natural capital ADD that balance food security needs and environmental
impacts through appropriate incentives and policies, which support a sustainable and equitable use of
biological diversity and ecosystems.
it is important to emphasize that systems for ecosystem services should be based on an incentive system
(rather than a penalty system) which would enable farmers to positively contribute and which do not create
negative incentives to diminish food production. With regards to biodiversity, adopting landscape approaches
to understanding benefits and tradeoffs is a more realistic way of assessing issues and allows weighing the
different roles and goals of agriculture in a more thorough and holistic way; instead the focus at field level fails
to take into account the environment in which farms exist and the dynamics of farm relationships to that
environment.

Para 92-93
We recognize the economic and social significance of land, particularly its contribution to growth, food
security, and poverty eradication, and note that the intensity of desertification of most of Africa’s arable land is
a serious challenge to sustainable development in the region. We call for enhanced support by the
international community to the implementation of the United Nations Convention to Combat Desertification
(UNCCD).

We agree to support partnerships and initiatives for the safeguarding of soil resources such as the Global Soil
Partnership (GSP). ADD: we recognize the important role of Integrated Soil Fertility Management (ISFM) in
providing appropriate techniques to farmers facing depleted soils, and encourage supporting the
dissemination of these best practices.
We also encourage scientific studies and initiatives aimed at raising wider awareness of the economic
benefits of sustainable land management policies that achieve healthy and productive land and soil.

Recognition and action on land degradation and desertification should be a priority. We would recommend
that a reference be made to the important role of Integrated Soil Fertility Management (ISFM) in providing
appropriate techniques to farmers facing depleted soils, in particular in Africa.

Para 95
We call for strengthening the Strategic Approach to International Chemicals Management (SAICM), to ADD:
achieve DEL:step up efforts towards a more robust, coherent, effective and efficient international regime for
ADD: the sound management of chemicals throughout their lifecycle ADD: so that by 2020 chemicals are
used and produced in ways that lead to the minimization of significant adverse effects on human health and
the environment. Sustainable and adequate long-term funding will be important to assist developing countries
with sound chemical and waste management through an integrated approach.

Para 96
We commend the increased coordination and cooperation among the Basel Convention, the Rotterdam
Convention and the Stockholm Convention on Persistent Organic Pollutants, and call for public-private
partnerships aiming to enhance capacity and technology for environmentally sound waste management. We
also note DEL: with concern the emerging challenges of ADD: used and obsolete electronics and call for
continued support of the Basel Convention activity on used and obsolete electronics, including implementation
of the technical guidelines for the sound refurbishment and end of life management of electronics under the
Basel Convention Partnership for Action on Computing Equipment (PACE). We further note the emerging
challenge of plastics in the marine environment, which should be addressed inter alia through appropriate
programmes and environmentally sound technologies for material and energy recovery.
…
The chemical industry supports efforts made through SAICM, but we are concerned that the wording of
these paragraphs suggests SAICM should be transformed into a global and unique chemical regime, which
we do not see as a constructive way forward. Strengthening the SAICM process is more helpful.

BASD page 7

Para 105
We recognize that goals, targets and milestones are essential for measuring and accelerating progress
towards sustainable development and agree to launch an inclusive process to devise by 2015:a set of global
Sustainable Development Goals that reflect an integrated and balanced treatment of the three dimensions of
sustainable development, are consistent with the principles of Agenda 21, and are universal and applicable to
all countries but allowing for differentiated approaches among countries. ADD: the process shall consider the
resources that would be needed to meet and report on the SDGs and possible trade offs in achieving current
goals to ensure any new goal adds synergies to existing efforts. ADD: The Sustainable Development Goals
should reflect the balance of the three pillars of development and be focused on measuring the outcomes of
efforts, not the processes.
Goals should focus on outcomes (such as food security) rather than processes and ensure that the balance
of social/economic/environment that is core to the concept of sustainability is reflected, without undue bias
towards measuring one of the three pillars. This could results in setting perverse incentives in programmes
and policies.

Para 106
We invite all stakeholders to join this process and request the UN Secretary-General to coordinate this
process. ADD: We recognize the important role of Major groups in moving the sustainable development
agenda forward. We also acknowledge the critical role of the private sector to make practical and substantial
contributions to sustainable development and multilateral processes. In this regard, we welcome a more
meaningful engagement of the private sector in these processes and call for the development of a roadmap
(with timeline) that would define the enhanced role of the private sector.

Para 107
We propose that the Sustainable Development Goals should include sustainable consumption and production
patterns as well as priority areas such as oceans; food security[DEL and sustainable agriculture]; sustainable
energy for all; water access and efficiency; sustainable cities; green jobs, decent work and social inclusion;
and disaster risk reduction and resilience.
Defining sustainable agriculture for the purpose of a Goal could be very limitative and will strain to represent
the variety of farming methods and context around the world. Food security is the outcome of agriculture and
should be the focus.

Para 116
We reaffirm the key role of the private sector in promoting sustainable development including through multi-
stakeholder partnerships. Public policy should create a stable investment climate and regulatory framework
conducive to long-term investment and ADD: public-private collaborations to further positive social and
environmental impacts. [DELETE socially and environmentally responsible behaviour by business and
industry. ]
PPPs are potentially one of the best technology transfer systems. It is very clear that policies should help to
create an enabling environment for innovation and diffusion and which support collaborations.

Para 119
We recognize the importance of strengthening the scientific, technological and innovation capacities of
countries to promote sustainable development. In this regard, we stress the need for effective mechanisms,
enhanced means, appropriate enabling environments, ADD enhanced actions to facilitate[DELETE removal of
obstacles to] the scaling up of the development and transfer of technology to developing countries ADD as
well as local innovation and development capacity
Once again, this appears to narrow down the discussion on technology transfer to ‘barriers’ when it is clear
from experience that many elements contribute to successful technology development and deployment. In
particular, more focus on how to develop local talent and local innovation capability is necessary

BASD page 7

120. We agree to strengthen international cooperation conducive to investment and technology transfer,
development and diffusion.
ADD:
120 (bis). We recognize the role of information and communication technologies (ICT) in enabling the green
economy and providing the intelligent products that support solutions in the areas of water resources, energy
efficiency, sustainable cities, sustainable biodiversity and ecosystems and education. We call for policy
actions that encourage the development and deployment of ICT-enabled solutions to achieve sustainable
development goals.

BASD comments on zero draft

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BASD comments on zero draft