The Brazilian Coalition on Climate, Forests and Agriculture sees with concern the draft Bill on the National Policy on Climate Change (PNMC in Portuguese acronym), which is available for public consultation until Saturday, December 4th.
The draft text erroneously proposes to repeal the current legislation on the matter, Law 12.187/2009, and weakens the principles, guidelines, commitments, and governance mechanisms that are key to guide the Brazilian climate policy.
Furthermore, the draft bill reduces the participation of civil society and subnational governments in decision making related to the PNMC, centralizing governance in the Interministerial Climate Change and Green Growth Committee, whose framework is not further detailed – not even the concept of “green growth” is described in the draft.
This is therefore a step backwards, considering that civil society, the academia, the private sector, and subnational governments, which are excluded by the proposed governance, are essential for the creation and promotion of sectorial actions for the mitigation of greenhouse gas emissions.
Among other critical points in the draft include:
The Brazilian Coalition considers that the PNMC law of 2009 already establishes the appropriate parameters for the national policy on climate change. It is desirable to direct the effort to its implementation and to updating the described targets, and not to repealing the law. Hence, the Coalition supports that the new bill, a draft of which was released by the Ministry of the Environment, should not be presented.
The debate about updating the PNMC is underway in the federal legislative branch, through bills already approved in the Senate, and which now go to the House of Representatives. The Coalition defends having this debate continue in Congress, with the due participation of the different sectors of society to improve the proposals currently at stake. It is important to emphasize that the new PNMC version must encourage reforestation actions and recovery of degraded areas as a joint and complementary effort to combat deforestation.
If, however, the draft is taken to the legislature, the Brazilian Coalition recommends that it proceed after a series of content adjustments and insertions, as presented here. These suggestions, however, do not represent the movement’s endorsement of the proposal presented by the Ministry of the Environment.
Find here the contributions sent by the Brazilian Coalition to the public consultation, in Portuguese.