Government support for fossil fuels reached at least USD 1.5 trillion in 2023. This is the second highest annual total on record after 2022, when Russia’s invasion of Ukraine triggered a global fossil fuel price crisis.

The latest data on fossil fuel subsidies, capital investment by state-owned energy companies, and international public finance shows financial flows are far from aligned with low-carbon and resilient development (Figures 1–3).

There is a huge opportunity to redirect this money for the benefit of people and planet.

• Fossil fuel subsidies to consumers, producers, and general services: data for 2023 covers 83 economies as estimated by the International Energy Agency (IEA) and the Organisation of Petroleum Exporting Countries (OECD). Until 2022, this data is complemented by International Monetary Fund (IMF) estimates of fossil fuel subsidies in the rest of the world. The 2022 figure has been revised up from USD 1.5 trillion previously estimated to USD 1.7 trillion in real term, based on more precise data from IEA and the OECD. 
• State owned enterprise (SOE) investment: USD 368 billion in 2023 as estimated by IISD.
• International public finance: Estimated at USD 29 billion in 2023, based on average of 2020-22 figures from Oil Change International, as published on EnergyFinance.org.

Regulated consumer prices

The largest component of support to fossil fuels was subsidies for consumption, at USD 1 trillion. Despite falling oil and gas prices, many measures put in place to ease the impact of high fuel costs on households and businesses in 2021 and 2022 continued into 2023.

It can be challenging to remove subsidies when people rely on fossil fuels to get around or heat their homes. However, untargeted fuel subsidies mainly benefit wealthy individuals, who use more energy. Ending these subsidies and redirecting funds to targeted social protection can reduce poverty and inequality, cut air pollution, and level the playing field for clean technology. 

Ultimately, clean energy can cut household bills and reduce exposure to fossil fuel price swings, but this depends on upfront investment reaching those who need it.

Fossil fuel lock-in

Alarmingly, around one third (USD 447 billion) of the support locks in new fossil fuel production through subsidies (USD 36 billion), capital spending by state-owned companies (USD 368 billion), and international public finance (USD 29 billion). This is likely to be an underestimate for two reasons. First, domestic public finance is not included. Second, while the dataset includes producer support estimates for such large producers as Argentina, Australia, Brazil, Canada, China, Norway, the United Kingdom, and the United States, it has blind spots on others such as Iraq, Iran, Kuwait, Russia, the United Arab Emirates, and Venezuela.

The science is clear: there is no room for new fossil fuel projects under a 1.5°C global warming limit. Existing oil and gas fields, if fully exploited, would burn through the entire carbon budget for a 50% chance of limiting warming to 1.5°C.

No government can claim to be a climate leader while backing fossil fuel expansion through public subsidies and investments. Instead, they should make the industry pay its fair share of taxes and channel investment into accelerating the rollout of clean energy.

Unmet pledges

Countries have agreed at the G7, the G20, and UN climate talks to phase out “inefficient” fossil fuel subsidies. While there have been pockets of progress, we have not seen a downward trend in the sums involved.

The onus is on wealthy countries to lead the way with reforms, because of their historic responsibility for climate pollution and greater resources to invest in the transition.

Accordingly, the G7 set a deadline for its fossil fuel subsidy phase-out commitment: 2025. The updated Fossil Fuel Subsidy Tracker shows that they are far from meeting it. G7 countries provided at least USD 282 billion of fossil fuel subsidies in 2023, nearly three times the amount in 2020. Subsidies continued to rise last year despite a decrease in the international oil price.

Germany’s measures to shield industries and households from high international gas prices explain much of that increase. Its fossil fuel subsidies grew by USD 64 billion from 2022 to 2023, to become the second highest in the world, after Russia and before Iran.

Japan, the Netherlands, and France were also among the top 10 subsidizers of 2023.

More broadly the 23 developed countries responsible under the UN climate convention for providing climate finance to the developing world spent USD 378 billion supporting fossil fuels. When other countries the World Bank classifies as “high income” are included, the figure is USD 508 billion (Figure 4).

This puts into context the pact at last month’s COP 29 summit to mobilize USD 300 billion a year in climate finance by 2035. It shows that public money is available but flowing in the wrong direction. Some of the fiscal space freed up by fossil fuel subsidy reform could be used to meet those climate finance commitments.

Walking the talk

There are initiatives to turn high-level pledges into action. For example, the Coalition on Phasing Out Fossil Fuel Incentives Including Subsidies (COFFIS) launched at the 2023 climate conference in Dubai with 12 countries (later joined by four more) promising to publish national inventories of fossil fuel subsidies, create domestic subsidy phase-out implementation plans, and work together to overcome international barriers to reform. The Agreement on Climate Change, Trade and Sustainability signed between four countries last month advances the issue through legally binding trade disciplines. Such initiatives need to deliver and inspire more countries to join.

Emerging market and developing economies also provide large amounts of government support for fossil fuels, mostly by capping retail prices below international prices.

Subsidy reform offers a tremendous opportunity for these governments to free up budget for other priorities. India, for instance, cut subsidies to oil and gas by 76% between fiscal years 2014 and 2017, thanks to reforms coupled with decreasing international oil prices. During the same period, government support to renewable energy grew almost sixfold, from INR 2,608 crore (USD 431 million) in FY 2014 to INR 15,040 crore (USD 2.2 billion). Fuel taxes were also ramped up, creating the fiscal space for India to connect every household to electricity, among other development actions.

At the international level, shifting financial flows from fossil fuels to clean energy is set to come under focus in 2025. Talks under “Article 2.1(c)” are mandated to reach a decision at COP 30 climate talks in Belem, Brazil, potentially paving the way for a substantive agreement on the issue. This should include agreeing to immediately stop subsidies for fossil fuel expansion, end public finance to fossil fuels, pivot state-owned enterprises to clean energy, and support people not fuels.

COP 28 delivered several breakthroughs for food systems and agriculture, including the first leaders’ level declaration on food and agriculture at a COP and the inclusion of food in the global stocktake and Global Goal on Adaptation. In contrast to the spotlight on the intersection between food and climate at COP 29, food systems, biodiversity, and ecosystems barely featured in the COP 29 final outcomes. Indigenous representation was similarly limited, and we witnessed pushback on the use of inclusive language.

However, it wasn’t all doom and gloom for food systems and land use at COP 29. A number of positive developments emerged that the food systems community can continue to foster and grow ahead of COP 30 next year in Belem.

1. We saw an increased focus on the need to mitigate non-CO2 greenhouse gas emissions in food systems. The COP 29 Declaration on Reducing Methane from Organic Waste, signed by over 30 countries representing almost 50% of global methane emissions from organic waste, shone a spotlight on the importance of reducing food loss and waste for methane abatement, including the need to leverage funding and build synergies with related objectives on issues such as food security, soil health, and energy. At the United States, China, and Azerbaijan Summit on Methane and non-CO2 GHGs, donors announced new finance for tackling methane mitigation, including in the agriculture sector, as well as new policy commitments and research covering both methane and nitrous oxide emissions.  
    
2. There was continued momentum from a coordinated food systems community and around a range of existing initiatives. The Alliance of Champions for Food Systems Transformation, launched at COP 28 in Dubai, shared a progress update and welcomed two new members to the Alliance: Tanzania and Vietnam. Although progress toward the Emirates Declaration on Sustainable Food and Agriculture has been slow to date, parties did emphasize the need to mainstream food systems into nationally determined contributions (NDCs) and national adaptation plans, as well as for additional finance for food systems transformation.
    
3. Brazil and the United Arab Emirates (UAE) announced updated NDCs at COP 29, including emissions relating to food systems, land use, and nature. Brazil pledged to reduce emissions by 59%–67% by 2035, with a strong emphasis on reducing deforestation as well as reference to existing measures to support sustainable agricultural practices, such as the ABC+ Plan. The UAE pledged to cut emissions by 47% by 2035, including a commitment to cut emissions from agriculture by 39% and to address emissions from energy use in the sector.

As the year draws to a close and policy-makers look ahead to the coming year, work remains to be done ahead of COP 30 in Brazil. Ambitious outcomes across a range of agenda items are critical for food systems transformation; however, enhancing synergies between food systems and climate is similarly critical for mitigating emissions from food systems and building their resilience to climate impacts:

1. Developing countries need financial support to transform their food systems. Therefore, the commitment from developed countries to raise USD 300 billion per year in climate finance should be viewed as a floor, not a ceiling. Developed countries must deliver on their promise and mobilize climate finance to support developing countries. With an estimated annual investment of USD 1.1 trillion needed to align food systems alone with climate goals, it is vital for our food systems that the Baku to Belem Roadmap identifies new and innovative sources to rapidly scale climate finance and match the annual USD 1.1 trillion need. Emphasis must also be placed on the accessibility of finance to vulnerable and marginalized groups, such as women, youth, Indigenous Peoples, and smallholder farmers.
    
2. Efforts must be taken to strengthen the commitment made at COP 28 to “transition away from fossil fuels” and to underscore the role food systems play in this transition. Energy systems and food systems are inextricably linked, with an estimated 15% of annual global fossil fuel use driven by our food systems. Food systems are also highly vulnerable to the climate impacts driven by emissions from a continued reliance on fossil fuels across all sectors of our economies. Policy-makers need to address these interlinkages and develop integrated approaches to transitioning both our food and energy systems away from fossil fuels, including in progressing outcomes from the global stocktake.
    
3. Ambitious food systems- and nature-related targets are needed in countries’ 2035 NDCs. Updated NDCs must recognize the interlinkages between food systems, climate, and biodiversity and be well integrated with national biodiversity strategies and action plans. They should include actionable, measurable targets across the whole food system—harnessing the potential of both production- and consumption-side measures.  Additionally, they should cover issues including, but not limited to, food loss and waste, soil health, habitat restoration, and deforestation-free supply chains.  The COP Presidencies’ Troika of the UAE, Azerbaijan, and Brazil must step up their commitment to cooperate and build a coalition to support parties on the path to ambitious NDCs.

COP 29 made little progress on the foundations laid at COP 28 and failed to make any substantial headway on commitments recognizing the critical role food systems play in climate action. However, progress did not backslide. In Baku, an increasingly well-coordinated, motivated food systems community cooperated to keep moving forward. Much remains to be done ahead of COP 30, however, and this community will be critical in continuing to build momentum.

The road from Baku to Belem starts now.

A consistent theme at the climate talks in Baku, Azerbaijan, was extreme frustration from the poorest and most vulnerable countries at the inadequate finance offered by developed countries—finance they sorely need to address the ravages of climate change on their economies and communities.

This frustration, building from one climate conference to the next, is not only because poor countries are bearing the brunt of climate change while having done little to cause it—it is because of the hypocrisy they see on the part of rich countries who claim they are unable to provide more to developing countries while continuing to subsidize the fossil fuels causing climate change.

The deal reached in Baku to mobilize USD 300 billion a year by 2035 is a progression on previous commitments but falls short of developing countries’ assessed needs. It also falls short of the estimated amount of public money that developed countries are providing to fossil fuels.

Despite the commitment to make “finance flows consistent with a pathway towards low greenhouse gas emissions and climate resilient development pathways,” domestic fossil fuel subsidies in 23 developed countries—those who are responsible for providing climate finance under the Paris Agreement—totalled at least USD 378 billion in 2023. And outside of national borders, rich countries still provide export credit finance of USD 41 billion per year to oil and gas, following their earlier agreement to end export credit support for coal.

Members of the Organisation of Petroleum Exporting Countries (OECD) have a critical and immediate opportunity to address at least the export credit finance element of public finance for fossil fuels to show they are serious about shifting funds from fuels that are exacerbating climate change to solutions that will protect planet and people, especially those in the poorest countries.

For a year now, OECD governments have been negotiating an agreement that could put an end to oil and gas export finance. Originally put forward by the United Kingdom, the European Union, and Canada, the proposal is now backed by nearly all OECD countries. If the few holdouts can be persuaded, this deal could only be reversed if all negotiating countries agreed to undo it.

Following the acrimony in Baku, this would be a very real way for the mostly rich countries of the OECD to show policy coherence, respond to calls from the poorest countries to stop subsidizing the fuels that are causing the climate crisis, and shift public finance to solutions.

A restriction on export credit support to oil and gas is also pro-development in another way. To the extent that these credits are being offered for projects in the developing world, they are placing these economies at increased risk. The International Energy Agency projects that oil and gas demand will both peak before 2030, even if no new climate policies are rolled out. New oil and gas infrastructure, such as gas-fired power plants, are at risk of becoming stranded assets unable to recover the original investment costs.

Public financing for fossil fuels has an outsized impact compared to private finance. Since it is government-backed and often provided at preferential below-market rates and longer time horizons, it helps leverage additional investment for proposed projects. It makes viable polluting projects that might not otherwise be financially feasible.

We have seen the potential of multilateral leadership in export finance before. In 2021, the OECD ended coal-fired power export credit financing, a key milestone in the phase-out of international public finance for coal. Now OECD countries have the opportunity to replicate this success for oil and gas. This could free up much-needed public finance to accelerate the uptake of clean energy.

This article originally appeared on the SDG Knowledge Hub on 27 November 2024

The ENB summary report of COP 29 notes that the NCQG decision “calls on all actors to work together to scale up financing to developing countries for climate action from all public and private sources to at least USD 1.3 trillion per year by 2035.” It sets a goal of at least USD 300 billion per year by 2035 for developing countries’ climate action. This money is to come from a wide variety of sources, including public and private, bilateral and multilateral, as well as alternative sources, with developed countries taking the lead. “Developing countries are encouraged to make contributions on a voluntary basis,” ENB writes.

Also in the context of the NCQG, countries agreed “to pursue efforts to at least triple annual outflows from the key climate funds from 2022 levels by 2030 at the latest.” “The decision also acknowledges the need for public and grant-based resources and highly concessional finance, particularly for adaptation and responding to loss and damage,” especially for the least developed countries (LDCs) and small island developing States (SIDS), among other vulnerable countries with significant capacity constraints, ENB notes.

The NCQG is an extension of the USD 100 billion per year by 2020 goal, and negotiations towards it were difficult. According to ENB, developed countries wanted to expand the contributor base to include “other parties in a position to contribute,” while developing countries called for a higher quantum. Some called for specific targets on the provision of public finance and finance mobilization. LDCs and SIDS called for minimum allocation floors for their groups.

The Baku Climate Change Conference saw the many years of negotiations on the modalities for setting up the Paris Agreement’s carbon markets come to conclusion. “The Article 6.2 decision will allow the Secretariat to provide registry services to countries that request it, allowing them to issue mitigation outcomes as units, and these services would be interoperable with the international registry,” the ENB analysis of the meeting explains. The Article 6.4 methodologies and removals requirements were also adopted, and “[t]he first Article 6.4 issuances can roll out as early as 2025.”

Countries also:

• Extended the work programme on gender;
• Provided further guidance on defining indicators for assessing progress toward the Global Goal on Adaptation (GGA);
• Adopted arrangements with the new Loss and Damage Fund; and
• Extended the mandate of the working group facilitating the implementation of the Local Communities and Indigenous Peoples Platform.

Parties could not reach agreement on, inter alia:

• The dialogue on the implementation of the outcomes of the Global Stocktake (GST);
• The just transition work programme;
• Review of the progress, effectiveness, and performance of the Adaptation Committee;
• Second review of the functions of the Standing Committee on Finance;
• Seventh review of the Financial Mechanism;
• Linkages between the Technology Mechanism and the Financial Mechanism;
• Further guidance on features of nationally determined contributions (NDCs);
• The report on the annual dialogue on the GST informing NDC preparation; and
• Procedural and logistical elements of the overall GST process.

According to ENB, many were disappointed about the lack of agreement in Baku on whether and how to take forward the GST outcomes, especially considering the importance of the next round of NDCs, to be submitted in 2025, to avoid overshooting the 1.5°C goal.

The Baku Climate Change Conference convened from 11-22 November 2024 in Baku, Azerbaijan. It consisted of the 29th session of the Conference of the Parties (COP) to the UNFCCC, the 19th meeting of the Conference of the Parties serving as the Meeting of the Parties to the Kyoto Protocol (CMP 19), the sixth meeting of the Conference of the Parties serving as the Meeting of the Parties to the Paris Agreement (CMA 6), and the 61st sessions of the Subsidiary Body for Scientific and Technological Advice (SBSTA 61) and the Subsidiary Body for Implementation (SBI 61). [ENB Coverage of Baku Climate Change Conference]

The world’s first international treaty to combat plastic pollution will be finalized during the fifth session of the Intergovernmental Negotiating Committee (INC-5) in the Republic of Korea. As delegates were arriving in Busan to negotiate the final text, there was already an important meeting underway. The day before INC-5 officially began, youth from 30 different countries gathered for a full day of discussions on what they expect to see from the treaty at the Youth and Stakeholder Assembly on Plastic Pollution.  

The day started with a High-Level Opening Plenary: Multilateralism for a Plastic Pollution-Free Future, featuring Inger Anderson, the Director of the United Nations Environment Programme (UNEP), who gave the gathered youth an update on what to expect from the negotiation.  

The final say on the high-level panel went to Zuhair Ahmed Kowshik, the Global Coordinator of Official Youth Constituency to UNEP and of the children and youth major group (CYMG). Kowshik outlined the position of CYMG: while it is crucial to have a deal signed this week, the negotiators must ensure they are representing their people, not just the big economic actors. Kowshik also stressed the importance of remembering that plastics are closely linked to other environmental issues like climate and biodiversity. This is why CYMG supports a high-ambition treaty that encompasses the whole plastics life cycle. 

Following the initial panel, several youth-led thematic panels focused on issues ranging from financial instruments to inclusive involvement of all stakeholders. Throughout the day, young people flagged three key major concerns and hopes for this plastics treaty.

• Inclusive and active stakeholder and rights holder engagement is crucial. Youth see it as vital that marginalized groups be included at all stages of decision making. This means that not only must marginalized groups have access to seats at the table, but they must also have access to clear and inclusive language and financial support to attend meetings. 
• The treaty must focus on the whole life cycle of plastics. The youth want to see this treaty encompass the entire plastics life cycle, including production. Turning off the tap should be the highest priority. 
• Youth need to be consulted. National delegations should be actively engaging with youth from their countries and reflecting their views in the negotiations process. 

IISD actively supports young people in their holistic vision for the treaty. In fact, some of these asks are already reflected in our own five key expectations for the plastics treaty. In short, the agreement must be inclusive, and it can only be effective if it tackles plastics across their entire life cycle—from production to waste management. We must start reducing and restricting certain types of plastic production if we truly want to eliminate plastic from our food, bodies, environment and, of course, freshwater supplies.

Throughout the day, some more artistic representations of what the treaty means for youth were included. An art exhibition was visible throughout the day, featuring pieces by youth from around the world. After lunch, we were also treated to a music video inspired by the plastics treaty and an appearance by the plastic monster mascot. 

Events such as this assembly are important for youth to engage on meaningful policy and climate concerns that have very real impacts on our future. Together, these events provide a platform for youth to advance advocacy efforts, develop better understanding of the issues at hand, and create cohesive policy stances to provide a voice for the younger generation.  

It remains to be seen whether negotiators will listen to the demands of youth this week. In the meantime, any youth who wish to have their voices heard on the treaty can participate by responding to the plastic action survey by CYMG.  

 

Header photo: United Nations Environment Programme under Attribution-NonCommercial-Share.

If you’re a young person interested in learning more about policy and its impact or want to prepare for a career in sustainable development, IISD Next hosts a Campus Workshop Series on Sustainability each academic year.  

Sign up to learn more about the series.

Stabilization clauses are provisions in investor–state contracts designed to protect the investor from changes in the host country's laws or regulations that could affect their operations.

The term might not immediately get your pulse going. But developing countries must get their approach to these increasingly contentious clauses in investment contracts right to protect and promote revenue collection and attract foreign investment that supports sustainable development, human rights, and a just energy transition.

Stabilization clauses will be on the agenda at next week's session of the International Institute for the Unification of Private Law and the International Chamber of Commerce Institute of World Business Law Working Group on International Investment Contracts.

Launched in 2023, the Working Group is looking to develop guiding Principles, model provisions, and commentary for investment contracts. While these address corporate social responsibility and sustainability, the Working Group's guidance is also set to include stabilization clauses. This means there's a risk that the Working Group could end up legitimizing these clauses as an automatic part of "modern" investment contracts.

Any new efforts to revisit stabilization clauses must instead reflect the latest norms and standards, most recently the Organization for Economic Co-operation and Development's (OECD's) Guiding Principles for Durable Extractive Contracts from 2020, seizing the opportunity to better align investment contracts with modern standards of sustainability, transparency, and fairness.

Stabilization clauses should no longer automatically be included in investment contracts. Laws and regulations on climate change, environmental protection, human rights, or labour rights should never be subject to legal guarantees of stabilization. If fiscal issues are subject to stabilization, the investor should demonstrate a legitimate commercial need—and if that’s the case, the time and scope should be limited, with the option for review. Governments should remain free to align regulations with internationally recognized rules to address tax avoidance—for example, the Global Minimum Tax.

What Are Stabilization Clauses?

Stabilization clauses are provisions that can be included in contracts between investors and states. These clauses typically lock in specific laws and regulations of the country where the investment takes place at the time the contract is signed and for a specific period (the stability period).

This shields investments from subsequent changes in those laws and regulations, including on issues such as taxation, climate mitigation, environmental protection, and human rights. In many investment contracts, the stability clauses cover all or large parts of domestic law, and the periods often extend over several decades.

Stabilization clauses are particularly common in developing countries' investment contracts, especially within the mining industry. They have been most prevalent in sub-Saharan Africa and essentially non-existent in OECD countries. They also tend to be the most generous in developing countries, both on substance and the time period they cover. This can be explained by the power imbalance between large companies and developing country governments, which isn't the case in developed countries, where stabilization is uncommon (and may even be considered unconstitutional).

These clauses are also sometimes enforced through international arbitration between investors and states. This means that when a country changes a law or regulation supposedly stabilized by these clauses, the investor can seek monetary compensation from the government by suing it in arbitration tribunals, so-called investor–state dispute settlement.

OECD Principles a Starting Point for Wider Reform

States looking to modernize their investment contracts should base their efforts on the OECD's 2020 Guiding Principles for Durable Extractive Contracts, which reflect the most recent normative understanding of stabilization clauses.

The Principles were developed over 5 years by an inclusive process that included industry, international organizations, civil society, academia, developed countries, and developing countries. They build on several earlier standards, beginning with John Ruggie's efforts in 2007–2011 as Special Representative of the UN Secretary General on Business and Human Rights.

They propose several fundamental changes in how to approach stabilization.

First, they distinguish between stabilization of fiscal issues and non-fiscal issues, underlining that non-fiscal stabilization is no longer acceptable. This means that laws and regulations on climate change, environmental protection, human rights, or labour rights should be clearly excluded from the scope of any such clauses.

Second, they are clear that fiscal stabilization clauses should be seen as a choice for governments and investors based on commercial and investment-related issues and not a presumptive legal requirement for governments.

Third, to the extent that they are required, the Principles point to reduced and narrower uses for fiscal stabilization clauses—such as reducing the scope to select fiscal terms, limiting the time period, and possibly applying a stability premium to the tax rates so the stabilization regime is in effect purchased from the state.

Finally, they introduced a concept of revenue certainty. Whereas stabilization has always been addressed from the investor's perspective, the Principles seek to untie governments' hands to address corporate tax avoidance or evasion and protect government revenues when a sharing-of-benefits agreement between the parties is in place.

An upcoming practice note by the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF), whose Secretariat is hosted by IISD, will provide further guidance on the content and implementation of the OECD Principles, emphasizing their approach to more limited and narrow uses of stabilization clauses in mining and other investment contracts.

Freezing Clauses and Economic Equilibrium

While the OECD Principles don't discuss the different types of stabilization clauses, several reports have shown that a shift is taking place away from traditional freezing clauses toward so-called economic equilibrium clauses.

As the name suggests, freezing clauses freeze specific laws and regulations as of the time of signing the contract and for a specified period. Any attempt by the state to make subsequent changes in these laws and regulations will automatically lead to a breach of the clause. When investors decide to sue states in investment tribunals for breaching freezing clauses, states usually end up being ordered to pay monetary compensation to the investor.

Economic equilibrium clauses are another form of stabilization. These clauses aim to restore the economic balance between the parties as it existed when the contract was signed. If a change in law has had a demonstrably negative economic impact on the investor, this will trigger economic compensation from the state to the investor—for the expense of complying with the legal change—or at least efforts to negotiate.

The advantage of this approach is that governments retain the flexibility to change laws that cover existing investments. The risk is that if economic equilibrium isn't well-defined in the contract, arbitration tribunals can later interpret it as having the same effect as a freezing clause and order states to pay similar levels of monetary compensation to the investor.

Experience shows that no approach to fiscal stabilization is without risk for host governments, which is why the OECD Principles also propose an alternative to legal guarantees of stability. They suggest that a predictable fiscal regime for investors—one that adjusts how the financial benefits are shared between the parties when factors affecting the investment project's profitability change (such as prices and costs)—can contribute to contracts' long-term sustainability and reduce incentives for renegotiation.

Opportunity to Revisit Investment Contracts and Stabilization

Amid the growing focus on investment contracts, developing country policy-makers should take this opportunity to revisit their approach to stabilization clauses based on the path set out by the OECD's Principles and with the following guardrails:

• Laws and regulations on climate change, environmental protection, human rights, or labour rights should never be stabilized.
• Fiscal stabilization clauses should not automatically be included in investment contracts. They should only be used if the investor can demonstrate a legitimate commercial need.
• If they are included, fiscal stabilization clauses should be limited in scope and time and may include a premium.
• Fiscal stabilization should never limit governments' ability to align regulations with bona fide, internationally recognized rules to address tax avoidance. Nor should they limit governments' room to protect against investors shifting profits and eroding the country's tax base.
• Governments should consider designing their fiscal regime to be responsive to changes in profitability. A flexible regime is more likely to be sustainable over the longer term, making the investment environment more predictable and reducing the need for renegotiation.

Intersectional approaches aim to address the complexity of social systems by recognizing the ways in which different structures of inequity—gender inequality, racism, ableism, and ageism, for example—overlap and are interdependent. The term intersectionality was coined by Black feminist Kimberlé Crenshaw in 1989; however, the concept existed previously within certain social movements and in some Indigenous ways of knowing.

Intersectionality shifts the focus from individual identities to structures of inequity, providing the foundation for systemic approaches that address discrimination and injustice.

It is fairly well established that gender inequality is a factor that influences how people experience and respond to climate change, as well as their opportunities to participate in decision making. However, other inequities have typically received less attention, obscuring differences among people of the same gender. It may also mean that we are overlooking other factors—such as being Indigenous or having a disability—that may lead to overlapping forms of discrimination that exacerbate vulnerability to climate change and create barriers to engaging in the solutions. An intersectional approach provides a framework for understanding these interconnected issues and what they mean for climate action.

The concept of intersectionality is becoming more prominent in climate policy discussions. In the UNFCCC, it is showing up more frequently in the negotiations. Notably, it was mentioned in the United Arab Emirates Framework for Global Climate Resilience (UAE FGCR), which emphasizes that adaptation action should be based on and guided by intersectional approaches. It has also been raised in the discussions around the review and update of the Lima work programme on gender and its gender action plan (GAP), where the draft negotiating text that will be further discussed at the 29th UNFCCC Climate Change Conference (COP 29) includes references to intersectionality. However, there has been some resistance to integrating intersectionality language in UNFCCC discussions, with some arguing that it is an academic concept that is not relevant in all country contexts.

Intersectionality is applicable across all areas of climate action, including adaptation, just transition, loss and damage, and climate finance. If we focus specifically on adaptation to illustrate its importance, we cannot deny that structures of inequity, such as colonialism, racism, and ableism, have an influence over people’s vulnerability to climate change and the opportunities they have to adapt. These structures intersect with each other and with gender inequality. Understanding how these intersecting forms of discrimination shape people’s adaptive capacity is fundamental to building resilience in a way that is inclusive and sustainable. This is clearly stated in the latest report on adaptation from the Intergovernmental Panel on Climate Change (IPCC), which affirms that intersectional approaches are central to understanding differential vulnerability.

Though intersectionality may appear to be an academic theory, it is clear that we should centre the most vulnerable people in our efforts to manage climate risks and that often, the most vulnerable people are those who face intersecting forms of discrimination.

And there is scientific evidence that backs up this assertion. Working Group II of the IPCC highlights the ways in which climate risks vary for different people due to intersecting structures of inequity based on gender, ability, and ethnicity, among other factors. It notes that deliberate attention to intersectionality in community engagement for adaptation can help to empower excluded groups and highlight justice issues while advancing local development priorities.  It asserts that there is high confidence that intersectionality is important to just environmental policies but that there is limited evidence of its integration in adaptation policies. The IPCC, the most important scientific body on climate change, identifies intersectionality as a “fundamental question” about equity and justice in adaptation.

In fact, adopting an intersectional approach provides more flexibility, as it does not predetermine which groups require particular attention in relation to climate change adaptation. Instead, it allows for analysis to determine which structures of inequity need more consideration in a given context. Using intersectionality as a lens can help us move toward a more nuanced analysis of the power structures and systemic barriers that undermine resilience and inhibit people’s opportunities to participate in climate action. Focusing on these structures of inequity is firmly in line with a gender-responsive and human rights-based approach to adaptation, which is enshrined in the Paris Agreement.

What Needs to Happen at COP 29?

At  COP 29, negotiators have an opportunity to ensure that the next phase of the Lima work programme and an updated GAP provide a framework for climate action that confronts the complexity of social systems and centres the people who have the most to lose in a changing climate. Globally, there is progress on integrating gender considerations into climate action. We see it in the establishment of a target for gender-responsive adaptation planning in the UAE FGCR. We see it in countries’ efforts to incorporate gender issues in their nationally determined contributions and national adaptation plans. We see it in the work of gender advocates and women on the frontlines of climate change who are taking action to reduce greenhouse gas emissions and build resilience. But there is more to do, and an intersectional approach will only strengthen these efforts. Ensuring that intersectionality is captured in the Lima work programme, the GAP, and other key decisions coming out of Baku represents a small but important step on the pathway to climate justice.

This article draws on discussions held at a knowledge co-production workshop on intersectionality and climate change adaptation earlier this year. We are grateful to the following individuals who shared their insights and experiences during this event: Joanita Babirye, Gabriela Balvedi Pimentel, Natalie Cleveland, Tsitsi Chataika, Ashlee Christoffersen, Diego De Leon, Ignatius Dube, Kudakwashe Dube, Ivana Feldfeber, Alex Gordon, Menka Kalisha Goundan, Young Hee Lee, Phelister Rosa, and Jhannel Tomlinson.
 

At this critical moment, Indonesia's energy policies will shape the country's economic dynamics and either provide a solid foundation for the transition to clean energy or limit the country's progress. With a fresh mandate for action, the newly elected president will have the opportunity for bold policy-making and delivery.

Four key actions for the incoming government to consider include the following: implementing a legally binding energy transition roadmap in the form of a presidential decree (Perpres) or government regulations, reforming harmful fossil fuel subsidies, reducing Indonesia’s dependency on coal, and accelerating growth in renewables.  

The new government’s plan to cut energy subsidies and compensation for the 2025 budget year could be a bold policy move that mirrors Jokowi’s first term back in 2014.

However, in order to evaluate Prabowo’s potential approach, it is essential to examine energy policy dynamics over the past decade and where they leave Indonesia today.

Early Ambition

During the previous government’s first term from 2014 to 2019, it set out ambitious energy transition goals. The measures included the reduction of energy subsidies, biofuel initiatives, encouraging investment in renewable energy through tariff system reforms, and achieving a 100% electrification rate nationwide while eliminating electricity subsidies and reducing production costs.

During this first term, Indonesia continued its commitment to achieve 23% renewable energy in its energy mix by 2025, pledged to reduce greenhouse gas (GHG) emissions by 29% (unconditional) and up to 41% (conditional on international support) by 2030. In 2022, these targets were increased to 31.9% (unconditional) and 43.2% (conditional), respectively, with a goal of net-zero emissions by 2060. It also partially removed subsidies on premium gasoline and introduced a new pricing mechanism.

These reforms led to budget savings of around IDR 211 trillion (USD 15.6 billion) in 2015, which was then reallocated to other sectors and widely regarded as a step in the right direction.

Setbacks and Subsidies

Despite initial reforms and pledges, subsidies for fossil fuels have gradually crept back up, reaching their peak in 2022 at IDR 551 trillion. It is particularly concerning that a significant portion of Indonesia’s energy subsidies are directed toward fossil fuel industries, with no indication of this trend reversing.

Support for Indonesia’s coal industry persists, and it is increasingly shifting toward downstream activities such as coal gasification. Recent legislation offers tax incentives for coal liquefaction and gasification, while coal-producing companies now enjoy free royalties for coal derivatives.

Energy Emissions Rising

Progress on GHG emission reduction has been mixed. While Indonesia’s overall GHG emissions have fallen, energy sector emissions have steadily increased over the past decade (except for 2021–2022 due to the COVID-19 pandemic).

This trend is likely related to the government’s limited progress in reducing the country’s coal dependency. Despite USD 20 billion pledged to transition to renewables through the Just Energy Transition Partnership (JETP) in 2022, the JETP Comprehensive Investment and Policy Plan (JETP CIPP) only plans to retire 1.7 GW of coal power plants while an additional 23.5 GW of new coal power plants are still in the pipeline.

High fossil fuel subsidies and inconsistent government messaging create investment uncertainty, hindering the growth of renewables. In 2023, renewable energy investment hit a 6-year low, contributing to stagnating renewable energy growth, with only 13.1% achieved in 2023. Instead of coming up with strategies to accelerate this growth, the government opted to update the target for renewable energy mix, lowering it to 17%–19% by 2025. Not only is this lower than the previous 23% by 2025 target, but it also threatens the new, more ambitious target set by JETP of 44% by 2030.

A Way Forward

Indonesia’s energy transition plans launched with ambitious goals a decade ago but faced challenges in implementation due to policy inconsistencies and entrenched interests.

There is no denying that the energy sector in Indonesia is tightly interwoven with politics and fossil fuel interests. It is also undeniable that the transition to a cleaner energy system demands fundamental reforms to the country’s energy policy that can only be achieved through strong political will. With his landslide victory in the election, Prabowo has a strong foundation to begin his term with necessary actions, such as energy subsidy reforms, despite the potential for pushback from critics.

Energy transition cannot be achieved without the government addressing the roadblocks that have been hampering the development of renewable energy, such as the issues of local content requirements, renewable energy tariffs, and the fossil fuel subsidies that tip the scales against renewables. A stable investment climate can be created if the government comes up with a clear and legally binding roadmap, such as the ones already identified in the JETP CIPP.

The government won’t be short of recommendations, but what has been lacking is the commitment to take action. Prabowo’s proposed cabinet with approximately 108 ministers and vice ministers, including representatives from nearly all political parties in Indonesia, as well as his plan to split eight existing ministries into 18, could make it easier for him to start his term with decisive actions or may prove challenging due to the competing political interests at play.

Whatever path he chooses, given the growing climate concerns, it is crucial for Prabowo to begin his first term with the momentum needed to bring Indonesia’s energy transition commitment back on track. After all, further delays will only cause more problems down the road.  

Anissa Suharsono is an energy policy associate with IISD’s Energy Program. She holds a BSc in physics from the Bandung Institute of Technology and an MSc in sustainable energy technology from Technische Universiteit Delft, the Netherlands.

She specializes in renewable energy policy, fossil fuel subsidy reform, coal and power sector dynamics, and just energy transition, with 13 years of experience working in the energy industry.

What are the main items to follow during this meeting?

The CBD has a very broad agenda, but I would highlight three main areas to watch.

First, the multilateral benefit sharing mechanism from the use of digital sequence information (DSI) on genetic resources. Discussions will center on the foundations and mechanisms for contributions to the benefit-sharing fund, as well as the methodologies and criteria for allocating those funds.

Second, the review of implementation of the Kunming-Montreal Global Biodiversity Framework through national action, but also through resource mobilization and financial arrangements, as well as the global review of collective progress.

And third, the new work programme on Article 8j and related provisions of the Convention, which refer to Traditional Knowledge of Indigenous Peoples and local communities.

What exactly is DSI and how does it figure into these negotiations?

The genetic material of living organisms is used to develop products, including food, cosmetics, vaccines.  To ensure that the innovation process is more fair and benefits us all, the Convention on Biological Diversity establishes a framework that requires acquiring consent from the countries that host these genetic resources and giving back to them a share of the benefits derived from their utilization.

But there is a gap.

Recently, technological developments have made it easier to share and analyze genetic data. We no longer need access to the physical component of the genetic resources for innovation purposes. We can simply rely on digital sequence information available in scientific databases.

This runs the risk of bypassing the current benefit-sharing requirements under the Convention and under different countries’ legislation.

At the last meeting of the Conference of the Parties in 2022 in Montreal, parties achieved a major breakthrough on access and benefit sharing as part of the Global Biodiversity Framework. They agreed to establish a multilateral benefit-sharing mechanism from the use of DSI, including a global fund. In Cali, parties are expected to operationalize—to put in effect—this multilateral benefit-sharing mechanism based on the negotiations of an intersessional working group.

Many issues still need to be worked out. These include the basis and modalities of contributions to this benefit-sharing fund, as well as the methodology and criteria for allocating the funding. Also, data governance is a big issue, with regard to the relationship of the multilateral mechanism with public databases. But it is important to highlight that at the last meeting of the working group in August in Montreal, there was broad support—though not consensus—toward a sector-based approach to benefit sharing from DSI. This means that all companies in sectors depending highly on use of digital sequence information—including agriculture, pharmaceuticals and cosmetics—would be required to contribute to this fund.

Has this breakthrough in the biodiversity talks influenced other negotiations in the past two years?

I would note that benefit sharing from DSI is under consideration in other relevant international fora, including the revision process of the International Treaty on Plant Genetic Resources for Food and Agriculture (ITPGRFA), as well as negotiations for a treaty on pandemics under the World Health Organization.

Of course, we cannot be certain to what degree decisions in one negotiation influence another, but we can assume some influence. For instance, the fact that the BBNJ agreement—the agreement on marine biodiversity beyond the limits of national jurisdiction—accepted the same principle [i.e. benefit-sharing from DSI use] in the text of its treaty. This was a major development.

What are the financial implications of the DSI benefit-sharing fund – both agreeing on who pays into the fund and who receives funding? Thousands of dollars? Millions of dollars?

It really depends on what percentage countries will agree upon. And the working group has not discussed this at all. Even the basis of payments is not agreed upon yet. It might be from some hundreds of thousands a year to maybe some billions a year.

Imagine: if we're talking about the annual turnovers of the entire pharmaceutical, agriculture and cosmetics sectors, then we are talking about billions and billions of dollars. But what percentage exactly from this income will go into the DSI fund is another question.

Realistically speaking, benefit-sharing from DSI use will not close the multibillion-dollar gap we need to fill for biodiversity governance as stated in the Global Biodiversity Framework. It will not cover it.

We need also other sources of funding.

How will COP16 try to support implementation of the Kunming-Montreal Global Biodiversity Framework?

In 2022, the Conference of the Parties adopted the Kunming-Montreal Global Biodiversity Framework, which seeks to reverse current rates of biodiversity loss by addressing both the direct and the indirect causes of biodiversity loss. To do this, it aims to guide global biodiversity policy through four overarching goals for 2050 and a set of 2030 targets.

It's important to mention that it's not legally binding, but it guides implementation by countries. It also integrates a human rights-based approach and the whole of society approach, aiming to integrate a broad set of actors into biodiversity governance.

Implementation of the Global Biodiversity Framework is supposed to be promoted through National Biodiversity Strategies and Action Plans (NBSAPs), which is the tool the Convention on Biological Diversity provides to help countries in biodiversity planning. So as part of their commitments under the Convention, governments must translate the goals and targets of the Global Biodiversity Framework into their own national targets and actions to support implementation.

In addition, other actors are invited to develop and communicate their own commitments. Governments, in particular, needed to submit to the CBD Secretariat the revised NBSAPs by COP 16.

Not all countries have done so to date. Approximately 60 to 70 countries have submitted at least one national target. About 50 have submitted targets for every target included in the Global Biodiversity Framework, and approximately 20 have submitted updated NBSAPs in line with the GBF. This is the first step for national implementation. These strategic documents should then be supported by legislative and policy frameworks to support better implementation and compliance. Timely submission of NBSAPs would also facilitate the global review of collective progress in GBF implementation for the first time under the CBD.

It will be interesting to see the degree of party participation at the pilot forum for voluntary country review, which will take place during the meeting of the Subsidiary Body on Implementation immediately prior to COP 16.

Resource mobilization and financial arrangements are also linked to GBF implementation. Historically, these deliberations have been extremely controversial, with developing countries urging developed countries to fulfill their financial commitments under the convention—Articles 20 and 21—to close the biodiversity finance gap. Under this issue area, COP 16 will focus on a new resource mobilization strategy, a global instrument on biodiversity finance, and the role of the Global Environment Facility vis a vis the Convention.

How effective have NBSAPs been to date?

It really depends on the context. There is some research out exploring exactly how NBSAPs are implemented at the national level. Some NBSAPs are being implemented successfully, others less so. But the Convention does not engage in a qualitative review of NBSAPs. There is no international mechanism to examine whether countries are sincere in their NBSAPs and how far they are going with their implementation. It's up to the individual governments to formulate and submit them. Their implementation depends on a holistic framework of regulations and policies, touching upon not only on biodiversity or even environmental policies, but also on productive sectors that traditionally destroy biodiversity.

What is on the agenda for COP16 when it comes to Indigenous Peoples and local communities and their Traditional Knowledge?

The COP will address a new work programme on Article 8j and related provisions on Traditional Knowledge, customary sustainable use, and other items related to Indigenous Peoples and local communities. Importantly, parties will discuss creation of a permanent subsidiary body on Traditional Knowledge to replace the current ad hoc working group.

Deliberations of this issue are expected to focus on controversial terminology following a recommendation by the UN Permanent Forum on Indigenous Issues to distinguish between Indigenous Peoples, on one hand, and local communities on the other—mainly due to the elevated status of Indigenous Peoples as right holders under international human rights law.

Separating these two terms will be a matter of controversy. Many parties do not acknowledge a difference between them in the context of biodiversity conservation and sustainable use under the Convention. Either they don't recognize Indigenous Peoples as such under their national laws or, as in the case of many African countries, they consider all local communities as Indigenous, so there is no need for differentiation.

Those supporting the differentiation between the two are afraid that grouping them together risks limiting the rights Indigenous Peoples have under international law.

It’s worth noting their importance for the Convention refers to their contribution to the conservation and sustainable use of biodiversity. The CBD does not, in some abstract term, talk about Indigenous Peoples and local communities, but only as far as conservation and sustainable use of biodiversity diversity is concerned.

Why is the Colombian Presidency is hosting this meeting under the theme "peace with nature"?

Their idea is to emphasize that the integration of biodiversity considerations across the production sectors and the economy is very much lacking, along with the political will to address vested interests and extractive activities that exploit both humans and nature.

It is also worth highlighting a series of agenda items on collaboration with other multilateral environmental agreements and between the Rio Conventions—CBD, UNFCCC, UNCCD—to explore opportunities for more synergetic, holistic action to achieve their goals.

You attended many of the intersessional meetings since CBD COP15 in Montreal. How would you characterize the moods and the progress at those talks?

We had very mixed signals during the intersessional work. During the meetings of the working group on DSI, the atmosphere was indeed very positive, surprisingly positive. It was not the same atmosphere at the subsidiary bodies—the SBSTTA, the SBI meetings. And this is reflected in the fact that most of the recommendations of the subsidiary bodies are filled with brackets. There are many, many issues that still need to be agreed upon.

The recommendation from the DSI working group is also fully bracketed. But somehow, yes, there was a palpable positive spirit at that meeting.

During our halfway point webinar at CBD COP15 in Montreal, you remarked that an unfair narrative exists around the CBD and the GBF as the only avenue to reverse biodiversity loss. How high should our expectations be for COP16? What kind of mindset should people bring with them to biodiversity negotiations?

We have to remember that CBD negotiations reflect country positions. At the end of the day, reversing biodiversity loss goes down to national level action—legislative and policy action by parties, by governments. The CBD can do much to guide global biodiversity policy and inspire through goals, but implementation rests with governments. This is very clear both in the Convention text and also in the talks.

So, what exactly governments will choose to do, we will see.

Nature-based solutions (NbS) have the potential to address multiple societal challenges while providing benefits for human well-being and biodiversity. But some Indigenous Peoples and local communities are raising concerns about the risks of parachute science, the commodification of nature, a lack of recognition of nature’s intrinsic value, and the fairness of benefit distribution from NbS projects. They are therefore calling upon Global North governments, organizations, and practitioners to adopt more inclusive and respectful engagement strategies in NbS projects that properly value their unique knowledge, traditions, and contributions.

Indigenous Peoples: Local environmental stewards

While NbS are still a relatively new concept, measures to protect, conserve, restore, sustainably use, and manage ecosystems to benefit human well-being and biodiversity are not. Indigenous Peoples have practiced environmental stewardship for millennia, guided by knowledge that is deeply rooted in the local context and has been passed down through generations. Today, they protect 80% of all biodiversity on the planet within their traditional territories.

Along the northeastern coastline of Quadra Island, British Columbia, clam gardens dating back 3,500 years provide an abundance of food for not only humans but also coastal wildlife. Built by the coastal First Nations, the clam gardens have been and continue to be sustainably managed through traditional management practices and harvest restrictions.

Further north lies the expansive and pristine wilderness of the Kaska Dena Ancestral Territory. The Kaska Dena are First Nations people whose land spans across British Columbia, Yukon, and the Northwest Territories. The British Columbia portion is stewarded through an Indigenous Guardians program called the Dane Nan Yḗ Dāh Network, which means “people taking care of the land.” The Guardians use Traditional Knowledge and community input to guide the sustainable management of their land and wildlife and monitor climate change.

It is important to note that while some local communities are Indigenous, not all are. Regardless of indigeneity, it is crucial to recognize the valuable insights and deep understanding these communities have of their local context. Their lived experiences and connection to the Earth are essential in shaping effective NbS projects.

Building Bridges Between Western Science and Traditional and Local Knowledge

Given the international nature of many NbS projects, practitioners with Western views and ideologies often work in countries outside of their own. This context can create power imbalances and requires practitioners to learn from communities about local contexts. A crucial first step is acknowledging that Western science is just one of many valuable knowledge systems. Traditional and local knowledge tend to be overlooked but can be complementary to Western science. So, how can NbS practitioners work with Indigenous Peoples and local communities to enhance their projects without being extractive and reinforcing Western dominance?

The answer lies within the question itself: working together. Indigenous Peoples and local communities worldwide have repeatedly expressed their desire to be included in NbS projects, given their years of experience and unparalleled expertise in environmental management.

Communities are upset and tired of being the front page of the magazine or a part of the video; they want to be part of the solution.

Constantino Aucca Chutas, Acción Andina

Making space for co-creation and finding ways to weave different knowledge systems together can result in more effective, sustainable, and inclusive NbS projects that truly address the needs and priorities of the communities they aim to serve.

While this is no easy endeavour, encouraging examples have emerged from academia and practice. For instance, Kate Raworth, author of Doughnut Economics, is collaborating with Native Hawaiian Professor Kamanamaikalani Beamer on a new conceptualization of her economic approach that centres entire ecosystems rather than just humans. This aligns with the beliefs of many Indigenous Peoples and local communities that humans are part of nature rather than a separate entity.

In Zanzibar, a climate resilience planning toolkit was designed with local cooperatives by combining the technical expertise of the International Institute for Environment and Development on intersectional approaches with community expertise on climate risks and adaptation strategies. The co-creation of this toolkit addressed shortcomings from previous climate adaptation investments in the communities that overlooked gender inequalities and the inclusion of youth. The collaboration has since fostered more intersectional adaptation planning within the cooperatives, demonstrating that combining diverse forms of knowledge can lead to more effective, inclusive, and sustainable projects.

When it comes to working together with Indigenous Knowledge and Western science, IISD Experimental Lakes Area (IISD-ELA) has been building relationships and collaborating in areas of common interest for nearly a decade—including research projects, cultural events, and the inclusion of Indigenous Knowledge in educational programming. The Manoomin (wild rice) project partners freshwater science with traditional ways of knowing to bring wild rice back to Indigenous communities in a way that will strengthen Indigenous economies, help the environment, see communities reclaim powers over their food systems, and have a lasting impact on the cultural preservation of wild rice. IISD-ELA explores how Western and Indigenous approaches to science can, and should, be working in tandem to further understanding and protection of fresh water and the environment overall.

Practitioners must adopt approaches that respect and incorporate the priorities, cultures, values, and knowledge of Indigenous Peoples and local communities.

Growing Positive Change

While NbS remain contentious, if done right, they have the potential to address climate change, biodiversity loss, and other societal challenges. This means adopting approaches that respect and incorporate the priorities, cultures, values, and knowledge of Indigenous Peoples and local communities.

Practitioners must act on calls from Indigenous Peoples and local communities to adopt more inclusive and respectful engagement strategies that allow for learning and community input from the outset of a project. A few ways to start are to build trust and relationships with Indigenous Peoples and local communities from the outset of projects, be open to learning about and understanding different types of knowledge, establish grievance mechanisms, adapt projects to communities’ needs and priorities (including being open to shifting the direction of project activities), and ensure that there is enough time and money available to do so.